MAA MLPFS 2A FOR SELECT PORTFOLIO SOLUTIONS

Managed Account Advisors LLC Merrill Lynch, Pierce, Fenner & Smith Incorporated FORM ADV PART 2A FIRM BROCHURE Managed Account Advisors LLC 525 Washington Blvd. Jersey City, NJ 07310 201.557.0504 Merrill Lynch, Pierce, Fenner & Smith Incorporated One Bryant Park New York, NY 10036 800.637.7455 ml.com This Brochure provides information about the qualifications and business practices of Managed Account Advisors LLC (“MAA”) and Merrill Lynch, Pierce, Fenner & Smith Incorporated (“MLPF&S” or “Merrill”). If clients have any questions about the contents of this Brochure, please contact us at 201-557-0504. 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. Investment adviser registration does not imply a certain level of skill or training. Additional information about MAA and Merrill also is available on the SEC’s website at www.adviserinfo.sec.gov. The advisory services described in this Brochure are not insured or otherwise protected by the Federal Deposit Insurance Corporation or any other government agency; are not a deposit or other obligation of or guaranteed by MAA, MLPF&S, Bank of America, N.A., or Bank of America Corporation (“BofA Corp.”) or any of their affiliates; and involve investment risk, including possible loss of principal. September 18, 2026 Investment products: Are Not FDIC Insured Are Not Bank Guaranteed May Lose Value MAA-MerrillSPS-09-2026 ITEM 2 MATERIAL CHANGES On March 20, 2026, MAA and Merrill together filed their last annual update for their Form ADV Part 2A (“Brochure”). This summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last interim update on June 26, 2026, or that may be important to them. MATERIAL CHANGES AND ENHANCEMENTS MADE AS PART OF THIS INTERIM UPDATE • We have added disclosure, including as to associated conflicts of interest, regarding new fees (Support Fees), also referred to as a type of revenue sharing, that we anticipate beginning to receive, as of January 1, 2027, from certain Third-Party Firms that sponsor, manage, construct, advise or distribute investment products available in certain of our advisory programs or through brokerage relationships. These investment products include: (1) mutual funds; (2) ETFs that do not seek to track the performance of a specified market index (actively-managed ETFs); and (3) certain annuities. We will also receive Support Fees from Third-Party Firms or their Affiliates relating to assets invested in Strategies by Merrill’s clients and other separately managed account strategies made available in certain investment advisory programs. Merrill will not receive Support Fees in connection with Accounts enrolled in the Program, including Program assets invested in Funds and Strategies. See Item 11. “Support Services Fees and Data Analytic Services Fees Received by Us from Certain Third-Party Firms.” • We have added disclosure regarding optional data reporting services (Data Analytics) that we intend to make available to certain Third-Party Firms as of January 1, 2027 for fees typically ranging from $125,000 to $860,000 per year as well as for Data Analytics related to passively-managed ETFs for fees ranging from $25,000 to $550,000 per year. We have also added disclosure related to associated conflicts of interest. As it relates to the Program, Data Analytics does not include information about Representatives. See Item 11.“Support Services Fees and Data Analytic Services Fees Received by Us from Certain Third-Party Firms.” • We have augmented our disclosure regarding a Third-Party Firm’s reimbursement of costs related to Conferences to allow for Third-Party Firm reimbursement of the costs of travel and accommodation for CIO employees who are not members of the CIO due diligence team. See Item 11. “Relationships With Asset Managers, Sponsors and Style Managers.” MATERIAL CHANGES AND ENHANCEMENTS MADE SINCE THE LAST ANNUAL UPDATE Set forth below are material changes and enhancements that we made to the Brochure since the last annual update in March 2026: June 26, 2026 Brochure Update Material Changes and Enhancements. • We have updated the business address for Managed Account Advisors LLC from 101 Hudson Street, Jersey City, NJ 07302 to 525 Washington Blvd., Jersey City, NJ 07310. • We have included additional information regarding Merrill’s error correction-related activities. See Item 12. “Brokerage Practices- Transactions in Program Accounts.” 2 MAA-MerrillSPS-09-2026 ITEM 3. TABLE OF CONTENTS ITEM 4. ADVISORY BUSINESS. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 The Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Available Strategies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 Reasonable Investment Restrictions. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 MAA’s Role and Authority . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Replacing a Strategy . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 7 Treatment of Cash Balances . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 ITEM 5. FEES AND COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 Account Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 IM&T Fee . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Style Manager Expense. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 How the Account Fee is Determined . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Deduction of Account Fees . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 Ability to Obtain the Program Services Separately . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .10 ITEM 7. TYPES OF CLIENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Client Eligibility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Account Minimums . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Closing an Account and/or Terminating Participation in the Program. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Methods of Analysis . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Investment Strategies. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 Investment Risks . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .12 ITEM 9. DISCIPLINARY INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 15 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .16 ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING. . . . . . . .17 Conflicts of Interest and Information Walls. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 Code of Ethics . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 Agency-Cross and Other Cross Transactions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .17 Funds and Fund Compensation . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .18 Offering of Related Strategies and Use of a Related Strategy in a Client’s Account . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 Style Manager’s Use of Affiliated Investments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 Provision of Diversified Financial Services . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .19 Other Relationships and Interests; Activity by MAA, Merrill and their Personnel and Affiliates . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20 Cash Balances and the Cash Sweep Program . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .20 Relationships with Asset Managers, Sponsors and Style Managers . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .21 Support Services Fees and Data Analytic Services Fees Received by Us from Certain Third-Party Firms . . . . . . . . . . . . . . . . . . . . . . . . .22 Offering of Investments or Programs Managed by Us or Our Affiliates. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .24 ITEM 12. BROKERAGE PRACTICES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 Transactions in Program Accounts . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .25 ITEM 13. REVIEW OF ACCOUNTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 Program Account Reviews . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 Client Reports. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .26 Trade Confirmations . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27 ITEM 15. CUSTODY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27 ITEM 16. INVESTMENT DISCRETION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .27 ITEM 17. VOTING CLIENT SECURITIES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 ITEM 18. FINANCIAL INFORMATION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 ADDITIONAL INFORMATION. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 Covered Entities under the Volcker Rule . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 GLOSSARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .28 3 MAA-MerrillSPS-09-2026 ITEM 4. ADVISORY BUSINESS This Brochure relates to Managed Account Advisors LLC (“MAA”) and Merrill Lynch, Pierce, Fenner & Smith Incorporated (“Merrill” or “MLPF&S”). MAA is a direct wholly-owned subsidiary of Merrill and both Merrill and MAA are indirect wholly owned subsidiaries of Bank of America Corporation (“BofA Corp.”). MAA provides investment advisory services to Bank of America, N.A. (the “Bank”) in connection with investment management and trust services offered by the Bank to the Bank’s fiduciary account clients under its Select Portfolio Solutions (the “Program”) as discussed in this Brochure. MAA is registered with the U.S. Securities and Exchange Commission (“SEC”) as an investment adviser and began providing advisory services in 2007. As of December 31, 2025, MAA manages $994.99 billion in client assets on a discretionary basis and no client assets on a non-discretionary basis. Merrill provides non-discretionary investment advisory services to the Bank by providing certain managed investment strategies that the Bank makes available in the Program. These strategies are constructed by Merrill investment professionals in the Chief Investment Office (“CIO”) and are implemented by MAA as further discussed below. Merrill is a global financial services firm that offers a broad range of brokerage, investment advisory, retail and other services. Merrill is registered with the SEC as a broker-dealer and has been registered as an investment adviser since 1978. It acts as an investment adviser to its clients in other managed account programs it sponsors, including with MAA. As of December 31, 2025, Merrill had assets under management of $1,781.57 billion, of which $441.30 billion was managed on a discretionary basis and $1,340.27 billion was managed on a non-discretionary basis. As further described in this Brochure, transactions in an account through the Program (an “Account” or “Program Account”), except as otherwise provided, are effected by or through Merrill or its Affiliates, acting as agent, and in doing so, Merrill and its Affiliates will be acting exclusively as broker-dealer. The Bank pays an asset-based fee for these and other services provided by Merrill through the Program. Both MAA and Merrill also provide investment advisory services to clients primarily through managed account programs they sponsor. Information pertaining to the investment advisory programs through which MAA and Merrill together and Merrill separately provide investment advisory services that are similar to the Program can be found in separate brochures for each program, which are available from each client’s representative (“Representative”) from Bank of America Private Bank or Bank of America Workplace Benefits, each a division of the Bank, or on the SEC’s website at adviserinfo.sec.gov. This Brochure relates solely to the advisory services MAA and Merrill provide to the Bank in connection with the Program. Additional information about the Program can be found in the Bank’s Select Portfolio Solutions Disclosure Statement (“SPS Disclosure Statement”) provided to clients by their Representative. Capitalized terms that are not defined in this Brochure have the meanings provided in the Glossary. When we use the terms “Merrill,” “we,” “our” or “us” in this Brochure, we are generally referring to MLPF&S. We also use the terms “Merrill,” “we,” “our” or “us” to apply to both MLPF&S and MAA for those aspects and services of the Program that MLPF&S and MAA perform jointly. We also indicate where certain services are provided by MAA in its separate capacity. The Program The Program is an investment service offered and administered by the Bank that is designed to help its fiduciary account clients meet their investment objectives by offering managed investment strategies (“Strategies”) as described below. To participate in the Program, a client must maintain an investment management, trust or similar relationship directly with the Bank, such as when the Bank serves as trustee for a trust on a client’s behalf or when the Bank provides investment management or other services in connection with a client’s account. Clients are required to enter into a Client Agreement with the Bank (or provide to the Bank other relevant documentation governing that relationship) prior to the investment of client assets in an Account. Typically, each Account will consist of a single Strategy selected by the Bank for its client. The Bank through the client’s Representative collects information about the client’s financial circumstances, investment objectives, tax situation, time horizon, risk tolerance and other relevant information to help the Bank determine the appropriate selection of Strategies. Available Strategies Each Strategy available through the Program has been identified and approved by the Bank for the Program. Each Strategy is constructed or managed by an investment manager (a “Style Manager”) which includes third-party investment managers and Affiliates of BofA Corp. or an entity in which BofA Corp. or its Affiliate has a material ownership interest (“Related Entities”), such as the Bank, Merrill and MAA. Strategies of Related Entities are referred to as “Related Strategies.” As for the third-party investment manager, it can be a single Style Manager or it can collectively serve as Style Manager with an affiliated or unaffiliated investment manager. The Style Manager is described in the Strategy Profile for a Style Manager Strategy. A Style Manager can also engage a third-party administrator to provide administrative services. Each third-party Style Manager files its own Form ADV Part 2A brochure with the SEC or has an equivalent document that describes their investment advisory services and role and each Style Manager (including those that are Related Entities), where required and as applicable, makes available Form ADV Part 2B-Brochure Supplements for its investment professionals providing portfolio management services for the Strategies. We make these materials available to clients through their Representative. Related Strategies available in the Program include those constructed by the CIO. Certain of the Related Strategies are constructed by Bank-employed CIO investment professionals. There are also available Related Strategies that are constructed by Merrill-employed CIO investment personnel. In addition, MAA is the Style Manager for a suite of equity Related Strategies that are developed based 4 MAA-MerrillSPS-09-2026 on investment models and lists published by the BofA Global Research Group (“BofA Research”), a division of BofA Securities, Inc. (“BofAS”), a Related Entity. Additional information about each of these types of Related Strategies and which Related Entity is acting as a Style Manager is available in the applicable Strategy Profile available upon request from a Representative. Strategies are generally organized according to a shared characteristic such as asset class or investment style. The Style Manager, including a Style Manager that is a Related Entity, constructs, implements and/or manages its respective managed portfolios and determines the asset classes, security holdings and weightings in the Strategy. Depending on the nature of the Strategy and the determination made by the Style Manager, a Strategy consists of individual securities (e.g., equities, fixed-income securities, mutual funds, money market mutual funds, exchange traded funds and nontraditional mutual funds), other Strategies and/or cash and/or cash alternatives (a “cash allocation”). The cash allocation is held as a cash balance and/or invested in cash alternatives such as money market funds as determined by the Style Manager. If no action is taken by a Style Manager, cash balances will automatically be swept pursuant to the cash sweep option for the client’s Account under the terms of the client’s account agreement or other arrangements with the Bank (“Cash Sweep Program”). The available automatic cash sweep options under the Cash Sweep Program vary based on the account type. The cash allocation can be higher at certain times depending on the nature of the Strategy, the asset allocation, the investment determinations, rebalancing, market conditions and the Style Manager’s cash management approach and market view and concerns. Some types of Strategies include investments that take an extended period of time to purchase due to the types of security, market availability and selection criteria. Until invested, the cash for these investments is typically held in the Cash Sweep Program or invested in cash alternatives or other investment products as determined by the Style Manager as a temporary investment pending purchase of the individual security. For more information on the treatment of cash balances, see “Treatment of Cash Balances” in this Item 4. Depending on the particular Strategy, the Style Manager can provide investment recommendations to MAA in the form of model portfolios and investment guidelines and instructions (a model-based Strategy) or manage and implement its recommendations for the investment portfolio on a full or partial basis (a “Discretionary Strategy”). A Style Manager can have Strategies in the Program that are model-based Strategies and Discretionary Strategies. A Style Manager of a Discretionary Strategy is sometimes referred to as a Discretionary Manager. The Program’s Strategy Profiles contain information relating to the Strategy and Style Manager. For a model-based Strategy, the Style Manager provides advisory services under an agreement with MAA by furnishing to MAA investment recommendations for the Strategy in the form of model portfolios or other investment guidelines and/or instructions. MAA will generally implement the Style Manager’s recommendations without change, subject to the application of any Reasonable Investment Restrictions (as defined below) which MAA has determined to accept as reasonable, cash commitments and other operational or investment considerations, including frequency of rebalancing. MAA may determine, in light of operational or investment considerations in its sole discretion, to deviate from the model portfolio on a limited basis (i.e., to select another security or increase the cash allocation within a model portfolio). Through the selection of a model-based Strategy, MAA is granted investment discretion and trading authority for investments occurring in that Strategy. Through this authority, MAA has complete and full trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets, without any prior notice. This authority will remain in place until MAA has received and accepted instructions from the Bank to either change the Strategy or terminate the Account from the Program. Certain Style Managers with model-based Strategies may place trades themselves after consulting with MAA. In this case, you grant the Style Manager trading authority on a partial basis for certain investments. In these situations, the Style Manager is considered a Discretionary Manager for trading authority only for the Account. Certain model-based Strategies categories available in the Program are positioned as “taxable” for low tax-sensitivity investors or “tax aware” for high tax-sensitivity investors (i.e., investors in the top U.S. federal income tax bracket). The CIO’s tax aware approach for the Related Strategies that it positions as “tax aware” assumes forward-looking tax-adjusted return estimates based on the asset classes’ respective market indices as part of its strategic asset allocation framework for such high tax-sensitivity investors. These Related Strategies seek higher allocations to tax-efficient asset classes, including tax exempt bond exposure. “Tax aware” should not be understood to mean investors can avoid taxes on investment income, such as dividends and interest, and capital gains generated from investments held or resulting from active portfolio management. For a discretionary Strategy, by agreement with the Discretionary Manager, MAA arranges for investments to be implemented within the Account directly by such Discretionary Manager. The Discretionary Manager executes trades through Merrill or a Merrill Affiliate or through a broker or dealer other than Merrill or a Merrill Affiliate (an “Unaffiliated Trade Counterparty”). MAA does not exercise investment or trading discretion or responsibility for implementing investment or trade execution decisions other than enforcing any Reasonable Investment Restrictions in the Account. Through the selection of a Strategy with a Discretionary Manager for an Account, the Discretionary Manager is granted investment discretion and trading authority for investments occurring in the Strategy in the Account. Through this authority, the Discretionary Manager has complete and full trading authority to invest, reinvest, purchase, sell, exchange, convert and otherwise trade assets, without any prior notice. The investment discretion and trading authority will remain in place until MAA receives and accepts instructions from the Bank to either change the Strategy or terminate the Account from the Program. The Discretionary Manager has the authority to determine whether a requested restriction is reasonable for their Discretionary Strategy. MAA and Discretionary Managers may use different vendors and/ or providers in considering whether restrictions requested by clients are reasonable. Certain Style Managers will respond to requests for customization such as state specific or state preference, credit quality maturity or duration and sector and employ those on a best efforts basis and subject to certain limitations as described in the Strategy Profile. MAA is not responsible for implementing any such customization requests. 5 MAA-MerrillSPS-09-2026 A Style Manager may construct or provide model recommendations for a Strategy that utilizes mutual funds, money market funds, exchange traded funds (“ETFs”), closed-end funds and non-traditional mutual funds (collectively, “Funds”). Any securities issued by a Style Manager or its affiliates will generally not be eligible for investment through the Program other than Manager-Related Funds. Manager-Related Funds are those Funds that are sponsored or advised by the Style Manager or its affiliates designed to only be utilized in investment advisory programs like the Program, have no internal advisory or distribution fees (but do have certain ongoing expenses) and cannot be held outside of the particular Strategy. The Style Manager typically views these as an integral part of its investment strategy with no appropriate substitutions that can be utilized as replacements. Therefore, MAA, the Bank or their Affiliates do not decide whether this type of Manager-Related Fund should be removed or replaced through redemptions from the Strategy or the Program. MAA implements the investment advice from the Style Manager as to the inclusion of these types of Manager-Related Funds in model-based Strategies without change other than as a result of withdrawal requests and rebalancing. To the extent that a Style Manager utilizes a Manager-Related Fund that is charged a Fund management fee by the Style Manager or its affiliate, the Bank, Merrill and MAA will work with the Style Manager to provide a rebate of the Fund management fees paid in respect of the Manager- Related Fund holdings as against the Style Manager Expense. Typically, Strategies have a Style Manager Expense that is charged by the Style Manager. The Style Manager Expense for the Strategy is reflected in the Strategy Profile. Any fee paid to a Style Manager will vary depending on, among other factors, the particular investment style or approach and the type of securities included in the investment strategy. Generally, clients will pay the Style Manager Expense as part of the Account Fee which will be used to compensate the Style Manager. There are third-party Strategies and CIO-constructed Strategies that include an allocation to one or more other Strategies of a third-party Style Manager. The applicable Style Manager Expense for such Strategy will be a blended rate that will include the Style Manager Expense on the pro rata portion of the account assets allocated to the constituent Strategy or Strategies. See “Item 5 Fees and Compensation” for information about the Account Fee and fee information. Certain third-party Style Managers have Strategies for which they do not charge a Style Manager Expense. These Style Managers allocate a significant percentage of their Strategies to investment strategies, mutual funds and/or ETFs for which they and/or their Affiliates serve as the investment manager and as to which they (or their Affiliates) receive compensation that presents a conflict of interest for the Style Manager. Where a Style Manager receives a Manager Fee and utilizes a Manager-Related Fund that is charged a fund management fee by the Style Manager or its Affiliate, Merrill will work with the Style Manager to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the Manager Fee. We make available information about each Strategy through a document known as a “Strategy Profile.” The Strategy Profile describes the relevant objectives, styles and risks of the particular strategy as well as its minimum investment amounts and its Style Manager Expense. It also describes the roles of the Style Manager and MAA in implementing the Strategy. The Strategy Profile typically includes performance history and data as indicated in the Strategy Profile. For model-based Strategies that are implemented by MAA, the Strategy Profile includes actual composite performance data developed by MAA in its implementation of the Strategy. Where the MAA composite data is not available in order to present ten years of performance history, the Strategy Profile typically includes available composite performance data provided by the Style Manager related to its implementation of the Strategy with Accounts and/or other accounts that the Style Manager manages. For Discretionary Strategies, the Strategy Profile includes its performance history and data provided by the Discretionary Manager. Style Managers have the obligation to establish and maintain each Strategy in the manner generally described in the then-current Strategy Profile and to provide notice on a timely basis of any changes made. We cannot guarantee the accuracy or consistency of the information contained in the Strategy Profiles but we obtain periodic confirmations from the Style Managers to help us confirm they continue to be materially accurate and complete. Reasonable Investment Restrictions Clients may request that certain investment restrictions be imposed on the management of the assets in their Account. For a restriction to be acceptable under the Program, it must first be determined to be “reasonable” (a “Reasonable Investment Restriction”). If accepted, the Reasonable Investment Restrictions that MAA is responsible for managing or implementing in the client’s Account will be applied until: (1) the client takes action to change, withdraw or waive the restriction; (2) MAA determines that it is no longer a Reasonable Investment Restriction based on factors it deems relevant in its discretion, including for example, the level of the security holding percentage in the Strategy; or (3) MAA is no longer able to implement the restriction in its systems due to changes in its systems or changes in the security identifier or symbol, corporate action events, or otherwise. MAA reserves the right to modify its practices regarding investment restrictions in its sole discretion at any time without notice. Further, MAA reserves the right to deem any requested investment restriction to be unreasonable and to not accept the requested investment restriction. If one or more investment restrictions are determined to be unreasonable, the restriction will not be applied and the client should consider whether to remain in the Program or consider other investment strategies. Please note that Reasonable Investment Restrictions will not apply to securities that are part of a Fund purchased for the Account. Along these lines, a client’s Reasonable Investment Restriction other than with respect to the purchase of a particular Fund itself would likely not have any practical effect on an Account comprised primarily of Funds. The termination or removal of an Account from the Program will terminate Reasonable Investment Restrictions for that account, and such Restrictions will not be applicable to the account outside of the Program. 6 MAA-MerrillSPS-09-2026 Implementing certain Reasonable Investment Restrictions can result in securities being sold which could result in taxable events. If a client elects to impose Reasonable Investment Restrictions, they accept any effect that such Reasonable Investment Restrictions may have on the investment performance and diversification of the Account. The performance of an Account with a Reasonable Investment Restriction will differ from, and may be lower than the performance of, an Account without such restrictions. In addition, a client’s decision to impose a Reasonable Investment Restriction that alters the allocation of any Strategy exposes the client to additional (and potentially unforeseeable) risks that are inconsistent with the objective of the Strategy. Depending on the Strategy selected, MAA or the Discretionary Manager for the Strategy selected for the Account will determine whether a restriction request is reasonable and how to allocate investments based on an accepted Reasonable Investment Restriction. MAA will allocate the assets that would have been invested in the security impacted by the Reasonable Investment Restriction in one of the following ways: (1) pro-rata across other investments that are part of the Strategy; (2) using one or more replacement securities which could include ETFs; and (3) remaining uninvested in cash. A client can request that MAA or a Discretionary Manager implement available investment screens to restrict investments with a specific identifier (such as a security number or ticker symbol), in certain security types, in companies in certain sectors or industries, in companies that do not meet certain sustainability or impact investing (“SII”) attributes or characteristics, and/or in fixed income securities that have certain credit ratings and maturities. MAA relies on analyses by third-party providers of investment screens, including those offering sector and industry classification and industry grouping data and SII screens. MAA does not guarantee or validate third-party screening or processes nor does it conduct an independent review of the underlying nature of the companies’ businesses or SII characteristics. The screening and processes to implement category investment restrictions are not absolute, could change at any time and could result in investments in companies that derive revenue from the restricted category. MAA and the Discretionary Manager can use different vendors and/or providers in considering whether restrictions requested by clients are reasonable. MAA’s Role and Authority Under the Program, MAA provides a variety of investment advisory services. Specifically, MAA has authority to make certain investment and trading decisions including: • Implementing, as applicable, the model-based recommendations or other investment guidelines and/or instructions of the Style Manager for a model-based Strategy. • Processing all contributions, including initial and any subsequent cash deposited in the Account, withdrawal requests and Account terminations. • Periodically rebalancing the Accounts for a Strategy as further described below. • Implementing a client’s Reasonable Investment Restrictions, if any, as described in the section “Reasonable Investment Restrictions.” • Implementing a client’s tax-selling instructions (if any) where acceptable to MAA. MAA will sell promptly any investments a client contributes that are not eligible or not acceptable for a Strategy. Certain Strategies have target allocations and are subject to automatic rebalancing on a periodic basis. Others are dynamically managed and are not subject to periodic rebalancing in the same manner. In light of other considerations in an Account, MAA can effect rebalancing and other transactions even though they may generate tax liabilities, including short-term taxable income. In its discretion, MAA may decide not to process certain rebalancing transactions. Delays in the processing of any rebalancing activities that MAA undertakes can occur from time to time, based on, among other things, market conditions, illiquid securities or those with limited subscription and redemption schedules, as well as the availability of Funds and other factors. MAA arranges for trades to be executed through Merrill and its Affiliates and may arrange for trades to be executed through an Unaffiliated Trade Counterparty. In its discretion and subject to legal requirements, MAA may utilize its Affiliates and third-party vendors for investment, trading and administrative support. MAA generally takes necessary actions consistent with implementing a Strategy, including for any investments subject to regulatory limitations and restrictions and related internal policies applicable to MAA and its Affiliates’ overall investment activities described further in the section “Other Relationships and Interests: Activity by MAA, Merrill and their Personnel and Affiliates.” Replacing a Strategy Changes to a previously selected Strategy can occur due to: (1) the Bank’s and/or the client’s instruction to replace a Strategy; (2) a Strategy being closed to new investments and/or additional contributions or otherwise; or (3) the termination of a Style Manager from the Program. Where there is a determination to close a Strategy or otherwise require a Strategy held by investors to be replaced, MAA may (1) replace the identified Strategy with another Strategy the Bank selects; (2) maintain current positions in the identified Strategy and invest any new contributions and sale or redemption proceeds in a replacement Strategy the Bank selects; or (3) maintain in cash any new contributions or sale or redemption proceeds relating to the identified Strategy until a replacement is chosen by the Bank. MAA is responsible for implementing the Bank’s decisions and related actions. 7 MAA-MerrillSPS-09-2026 If the Bank determines to replace the identified Strategy, it will endeavor to choose a replacement with an investment style that is consistent with the identified Strategy. The replacement may be subject to higher fees. The client’s continued participation in the Program after any such replacement or other action will be considered their consent to the action, if necessary based on the Bank’s arrangement with the client. If clients hold the identified Strategy, the client will be provided with written notice (if necessary based on the Bank’s arrangement with the client) of any discontinuation, closing or replacement event prior to it taking place; however, they may be notified of such event after action has already been taken. Having the flexibility to act quickly helps the Bank and MAA take action where they believe the replacement and its timing are in clients’ best interest. Treatment of Cash Balances As described in the relevant account agreement and documents that govern a client’s Account, clients consent to having cash held in the Account being treated as a cash balance and being automatically “swept” to the Cash Sweep Program. Unless the cash allocation is invested, either in a cash alternative or in other securities, the cash allocation will be treated as a cash balance in the Account subject to the automatic sweep functionality. Cash held in Accounts with a custodian other than the Bank are not covered by the Cash Sweep Program and will not be subject to the Cash Sweep Program. Cash balances swept to a deposit account of the Bank under the Cash Sweep Program will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts will be periodically set and reset by the Bank in its discretion. The rate is variable and may change at any time after the Account is opened without notice or limit. The interest rate earned in the bank deposit account affiliated with the Cash Sweep Program can be lower than yields on certain money market funds and other cash alternatives. An Account’s cash balance swept to bank deposits of the Bank is insured by the Federal Deposit Insurance Corporation (“FDIC”), up to the applicable standard maximum deposit insurance amount. The FDIC limit is generally $250,000 per depositor, per ownership or a banking Affiliate in the same account ownership category, whether directly, through other accounts or through any other intermediary, would be aggregated for FDIC insurance limit purposes. If a client’s total cash balances held at the Bank in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) and/or in any type of bank product exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. For additional information on FDIC insurance, visit fdic.gov. Neither MAA nor the Bank manages or monitors the deposits swept under the Cash Sweep Program for FDIC insurance limit purposes. Deposits are not aggregated or limited based on the FDIC limits for the same depositor in the same bank across accounts. MAA does not undertake through the Program to provide a client with notice that cash balances in an Account or Accounts or in any other relevant accounts exceeds the FDIC coverage limit. Monitoring FDIC insurance coverage limits is expressly not a Program service. Clients are responsible for monitoring the total amount of deposits held at the Bank in order to determine the extent of FDIC insurance. If a client’s total cash balances held at the Bank in any type of deposit account (whether a direct bank deposit account or a sweep deposit account) and/or in any type of Bank product exceed the FDIC coverage limits, the amount deposited that is over the applicable standard maximum deposit insurance amount will not be entitled to FDIC coverage. Third-party money market funds are available as a sweep option. These money market funds have certain fees, expenses and charges and clients will bear the proportionate share of the sweep money market fund’s fees and expenses including, but not limited to, management fees paid to the Fund’s investment managers or their affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. The Account Fee does not cover or offset any fees and expenses that the sweep money market fund incurs for transactions occurring within the Fund itself. Please consult the prospectuses and offering material for the sweep money market funds for additional information on the fees, expenses, and charges imposed by the money market funds. For additional information and related conflicts of interest related to cash balances and the Cash Sweep Program, see the Bank’s SPS Disclosure Statement and this Brochure at Item 11 “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading” at the section “Cash Balances and the Cash Sweep Program.” ITEM 5. FEES AND COMPENSATION Account Fees The Account Fee for the Program is comprised of: (1) the fee the client currently pays the Bank for its services, as that fee is set forth in the Client Agreement or other relevant fee documentation governing that relationship with the Bank (the “IM&T Fee”) and (2) the fee the client pays for a particular Strategy (“Style Manager Expense”), if applicable. The Account Fee is payable in advance and will be based on the value of assets, including cash and cash alternatives, in a client’s Account. For the advisory services MAA provides through the Program, the Bank pays MAA an asset-based fee. IM&T Fee. The IM&T Fee rates and terms of payment are set forth in the Client Agreement or other relevant account documentation and are subject to change. Clients should consult their Representatives with any questions about the terms of their existing relationship with the Bank. 8 MAA-MerrillSPS-09-2026 The IM&T Fee clients pay may be negotiable depending on a number of factors. Such factors include, but are not limited to the: • Market value and asset allocation of a client’s assets. • Number and size of a client’s related accounts maintained at the Bank and its Affiliates. • Range and extent of services provided or to be provided to a client. • Representative assisting the client. Other pricing arrangements, typically involving multiple accounts, products or services, may also be available to clients. While clients entering into such arrangements may pay higher fees for any particular component being offered, the pricing arrangement as a whole will generally result either in the same or lower fees in the aggregate for all the accounts, products or services provided or for the inclusion of additional products and services. From time to time, MAA and the Bank also may enter into specialized agreements to provide particular or unique services to certain clients, subject to negotiated fees. In addition, the Program may be offered through other lines of business of BofA Corp. Clients of these lines of business may have a limited or different selection of Style Managers, Strategies and/or Funds. Certain additional services also may be provided to such clients. The fees for certain of the services described in this Brochure may be reduced for employees of the Bank and its Affiliates, or such employees and Affiliates may be subject to prior fee schedules. Additional information about Account Fees and other fees and expenses that a client may incur when participating in the Program are discussed in greater detail in the Bank’s Disclosure Statement for the Program. Style Manager Expense. The Style Manager Expense rate for each Strategy is listed in the Style Manager Expense Rate Supplement to the Bank’s SPS Disclosure Statement. Any fee paid to a Style Manager will vary depending on, among other factors, the particular investment style or approach and the type of securities included in the investment strategy. The Style Manager Expense rates generally range from 0.00% to 0.50% annually. The Style Manager Expense rate applicable to a client’s Program Account does not change based upon the value of assets in a client’s Program Account. The Style Manager Expense rate is stated on the Strategy Profile. Clients that invest in a Related Strategy will not be charged a Style Manager Expense that is payable to a Related Entity. The selection of the Strategy with no Style Manager Expense that is payable to a Related Entity results in the client paying only the IM&T fee which is paid to the Bank for the Program Services. This presents an opportunity for the Bank to benefit as the client will not be paying a separate Style Manager Expense from account assets, resulting in more assets and higher fees to the Bank than if the client accounts had a Style Manager Expense. Additionally, the opportunity to negotiate a higher IM&T Fee rate provides the Representatives with an incentive to recommend Strategies with no Style Manager Expense rate over those that do. The ability to negotiate a higher IM&T Fee rate benefits the Bank as well as a Representative since the Bank retains the IM&T Fee. If a new or different Strategy is selected for a client’s Account, the change in Style Manager Expense rate will be processed for the next monthly billing cycle. The Style Manager Expense rate applicable to the former Strategy will apply through the remainder of that calendar month, after which the new Style Manager Expense rate(s) for the new Strategy will automatically be applied. Note that certain Strategies invest in Funds. For such investments, clients will bear their proportionate share of such Fund’s fees, expenses and charges, including, but not limited to, management fees and performance-based compensation paid to the Fund’s investment managers or their Affiliates, fees payable to the Fund’s professional and other service providers, transaction costs and other operating costs. The Account Fee does not cover or offset any fees and expenses that any Fund incurs for transactions occurring within the Fund itself, including commissions and other transaction-related charges incurred by the Fund, even if we or any Affiliate effect these transactions for the Fund or provide services to the Fund. All of these fees, expenses, costs and other charges may be material. How the Account Fee is Determined Account assets will be valued in a manner determined by the Bank and MAA in their sole discretion, and in some cases may be based on prices and/or estimates obtained from various sources, including their Affiliates. Values may vary from prices achieved in actual transactions, especially for thinly traded securities, and are not firm bids or offers or guarantees of any type about the value of assets in a client’s Account. For fixed-income securities, the values assume no unusual market conditions and are generally for transactions of $1 million or more, which may produce values that are higher than the prices that would be achieved in the sale of fewer securities. As a result, the Account Fee may be calculated based on values for some securities that are greater than the amount the client would receive if the securities were sold from the client’s Program Account. The Program Account value used for the calculation of the Account Fee may differ from that shown on a client’s monthly securities account statement and the performance measurement report due to a variety of factors, including trade date or settlement date accounting, the treatment of accrued income, round lot valuation and other considerations. The valuation of Program Account securities reported in the performance measurement report also may be subject to occasional repricing in reasonable and appropriate circumstances, but such repricing will not affect, or result in the adjustment of, previously calculated Account Fees. Deduction of Account Fees Clients or their authorized representatives generally have agreed to the following: 9 MAA-MerrillSPS-09-2026 • Unless otherwise agreed to between the client and the Bank, the IM&T Fee (and any other fees payable under the Client Agreement, if applicable, or other relevant documentation, including any Style Manager Expense) will be deducted directly from a client’s Account. • The Bank is authorized to deduct the Account Fee from the assets held in a client’s Account, to the extent permitted by applicable law, if full payment of the Account Fee has not been timely received or, if earlier, at the time the Account is terminated. • The Account Fee for a client’s Account will be payable, unless otherwise indicated, first from the liquidation or withdrawal by the Bank and to the extent permitted by applicable law, of the client’s shares of any money market fund or balances in any money market or bank deposit account, and second from free credit balances, if any, in the client’s Account, and to the extent that such assets are insufficient to satisfy payment of such fees, the client will be billed by the Bank. • Timely payment of all amounts due to the Bank. • To the extent permitted by law, all assets in a client’s Account or otherwise held by the Bank or its Affiliates for the client (other than retirement accounts guaranteeing the obligations of non-retirement accounts and vice versa) will be subject to a lien for the discharge of client obligations to make timely payment to the Bank of the Account Fee (and any other fees the client is obligated to pay), and the Bank and its Affiliates, subject to applicable law, may sell assets in the client’s Account to satisfy this lien. A client is responsible for paying the full amount of the Account Fee, regardless of whether the client uses all of the services provided or described herein and in the Bank’s SPS Disclosure Statement. Clients may be able to pay the Account Fees from assets held outside of their Account. Clients should contact their Representatives for additional information. Ability to Obtain the Program Services Separately Clients may be able to obtain some of the same or similar services or Strategies available through the Program separately from the Bank, Merrill, MAA and their Affiliates on a separate or combined basis, subject to certain restrictions, including the type of account for which clients are seeking these types of services. Depending upon the factors below, the Program may cost clients more or less than purchasing the services separately. Clients may also be able to obtain some or all of the types of services available through the Program from other firms and account fees may be higher or lower than the fees charged by other firms for comparable services, assuming such services are available. It is the client’s responsibility to review the other services or investments available through the Bank and its Affiliates with a Representative to determine whether the other services or investments may be more appropriate than the Program. In comparing the account types and programs and their relative costs, clients should consider various factors, including, but not limited to: • Client preference for an adviser, brokerage, bank trustee or bank investment management relationship. • Client preference for a discretionary or a non-discretionary relationship. • Client preference for a fee-based or commission-based relationship. • The types of investment products that are available in each program or service. • Whether a particular investment strategy offered in one program or service is available through another Bank or Merrill program or service. • How much trading activity a client expects to take place in his or her Program Account. • How much of a client’s assets are expected to be allocated to cash. • Whether a client wishes to invest in mutual funds, and which mutual funds (if any) are available in particular programs. • The frequency and type of client profiling reports, performance reporting and account reviews that are available in each program or service. • The scope of ancillary services that may be available to a client in a brokerage account, but that are not available in the Program. ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Both Merrill and MAA may manage multiple accounts with different investment objectives, guidelines and policies, and with different fee structures. While neither MAA nor Merrill presently accept performance-based fees, either firm may enter into performance fee arrangements with qualified clients in the future. Such performance fee arrangements would be subject to individualized negotiation with each such client and structured so as to comply with Rule 205-3 under the Advisers Act. Certain Funds available in the Program may be subject to performance-based fees or varying Fund expense charges that are imposed by the manager, adviser or other party that are based on performance of the Fund. 10 MAA-MerrillSPS-09-2026 ITEM 7. TYPES OF CLIENTS Client Eligibility To participate in the Program, a client must maintain an investment management, trust or similar relationship with Bank of America Private Bank or Bank of America Workplace Benefits and establish an account with the Bank. Investors eligible to participate in the Program generally may include individuals, trusts, estates, charitable organizations, corporations, retirement plans, pension and profit sharing plans. As indicated in the Strategy Profile for each Strategy, not all types of investors are eligible for each Strategy. Account Minimums The minimum initial investment in the Program varies depending on the Strategy selected by the Bank for the client’s Program Account. The minimum initial investment for a particular Strategy is generally included in the applicable Strategy Profile. Closing a Program Account and/or Terminating Participation in the Program Clients have the ability to terminate their participation in the Program which may result in a refund or require the client to pay the Bank any remaining fees due for the partial billing period. See the Bank’s SPS Disclosure Statement for more information. Upon termination of the Account enrollment into the Program, MAA will have no responsibility for the investment of assets in the client’s Account. Notwithstanding a client’s instructions to the contrary, certain Funds and other securities held in the client’s Account pursuant to a certain Strategy will be automatically liquidated or redeemed, as described in the applicable prospectus or disclosure document upon termination of an Account’s enrollment in the Program. Liquidation or redemption will generally be effected by the close of the next business day following termination, although for certain securities, such as those traded on a when-issued basis or as odd lots, the liquidation or redemption process may take longer. The termination of a Representative’s employment with the Bank will not automatically terminate the Client Agreement or an Account. If a client’s Representative is no longer able to service the client’s Account, the Bank may transfer that Account to a different Representative and the client will be notified of any such changes. ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Methods of Analysis For the Strategies, a number of investment techniques, including fundamental analysis, may be used. A variety of sources of information may be used to facilitate such analysis. The Strategies also may be invested in a wide range of investments depending on a particular client’s objectives, strategies, policies, applicable law and other relevant factors. General descriptions of the Strategies are included in the Strategy Profiles provided or made available to clients. Clients also may receive brochures of any Discretionary Manager selected to manage their Account or a portion thereof. MAA reserves the right to limit the availability of any particular Strategy at any given time based on factors including, but not limited to, asset class capacity, pre-existing relationships, minimum account sizes, fees and distribution channels. Investment Strategies Strategies are generally organized according to a shared characteristic such as asset class or investment style. The Style Manager will construct the particular investment strategy and select the securities, including, in certain cases, Funds and other types of investment strategies. They also set the allocations or allocation ranges. Please refer to the Strategy Profile for additional information about the Strategy, including further details with respect to the strategy description, portfolio construction and due diligence. The Strategies available in the Program include Related Strategies. The Program offers Related Strategies that are constructed by CIO investment professionals. The Related Strategies constructed by Merrill-employed CIO portfolio teams consist of mutual funds, ETFs and other Strategies that they select and provide to MAA as a model-based Strategy. Other Related Strategies are those that are constructed by CIO portfolio teams employed by the Bank and can consist of equity and fixed income securities as well as Funds. The Strategy Profile will indicate which Related Entity is acting as the Style Manager for the Related Strategy. In addition, certain of the Related Strategies are those constructed and implemented by MAA based on BofA Global Research investment models or lists. These investment models or lists include exchange traded products that are covered by research reports and ratings of BofA Global Research (“Research Ratings”). The CIO, BofA Global Research and other business units of BofA Corp. apply different methodologies in their review of exchange traded products and may arrive at different or inconsistent conclusions. It is possible that certain of the exchange traded products included in the Related Strategies based on the BofA Global Research-based models or lists may not have been reviewed under the CIO Review Process as described below and such review is not required. For its Related Strategies, the CIO determines the allocations or allocation ranges for Related Strategies based on its long-term expected return, risk and correlation assumptions for each asset class (capital market assumptions), its view of the appropriate long term allocation guidelines to follow in light of market conditions, expected trends and, as applicable, corresponding tactical asset allocation adjustments. Tactical asset allocation adjustments are applied to those long-term asset allocations based on the CIO’s near- term market, economic, and asset class expectations. These tactical adjustments overweight or underweight specific asset classes, 11 MAA-MerrillSPS-09-2026 incorporating its investment views on how market dynamics, phases of the economic or business cycle, and particular investment themes may affect the Related Strategies. To determine tactical asset allocations, the CIO utilizes internal as well as third-party research and data at both the macro and micro levels. Once the Related Strategies are constructed, the CIO regularly monitors and reviews them and makes adjustments based on asset allocation changes. The individual securities are also periodically reviewed to ensure they continue to meet the criteria for inclusion. The Related Strategies are also subject to internal governance and oversight processes on a periodic basis, which may include a review of performance against expectations as well as any applicable investment or regulatory restrictions. In constructing the Related Strategies that consist of Funds and/or other Strategies, the CIO portfolio teams select those Funds and other Strategies that are subject to the “CIO Review Process,” an investment review conducted by or under the auspices of personnel of the CIO of investment solutions. The CIO Review Process consists of proprietary processes conducted by the CIO and those processes and reviews provided by third-party reviewers that engaged for this purpose. The third-party reviewer processes and reviews are generally consistent with the review processes that the CIO deploys but they are not identical. The CIO has reviewed such third-party reviewers’ processes and believes they are reasonable and appropriate in light of the objectives of the Program. The CIO Review Process considers whether Funds and/or other Strategies have sufficient assets under management and meet minimum trading volume parameters. In addition, it considers and evaluates their share price or net asset value, along with the corresponding allocation weighting, in light of a Strategy’s investment minimum. The Related Strategies constructed by the CIO are “taxable” for low tax sensitivity investors or “tax aware” for high tax sensitivity investors. CIO’s tax aware approach assumes forward-looking tax-adjusted return estimates based on the asset classes’ respective market indices as part of its strategic asset allocation framework for high tax-sensitivity investors (i.e., investors in the top U.S. federal income tax bracket). As tax aware, the related Strategy seeks higher allocations to tax-efficient asset classes, including with the fixed income allocation’s tax exempt bond exposure, geared to taxable clients and those with higher tax sensitivity. “Tax aware” does not mean investors can avoid taxes on investment income, such as dividends and interest, and capital gains generated from investments held or resulting from active portfolio management. Note that Style Managers include as part of their Strategies’ investment portfolios individual equity and fixed income securities, investment strategies and Funds based on their own review and portfolio management processes and determinations. These individual securities, including Funds, may not be covered, and are not required to be subject to, the CIO Review Process. The Program does not currently offer any Funds sponsored by a Related Entity (“Related Funds”). However, to the extent any Related Funds become available, we may determine to include them in a Strategy constructed by a Related Entity. The Bank offers other investment strategies outside of the Program. Certain strategies may be available only in certain channels or through a purchase of shares of Funds. Investment Risks As with any investment in securities, investments through the Program involve a risk of loss. Clients may lose money by participating in the Program. The Account is not insured or otherwise protected by the FDIC or any other government agency; is not an obligation of the Bank, MAA, Merrill or any of their Affiliates; and is not endorsed or guaranteed by the Bank, MAA, Merrill or any bank or any Affiliate of the Bank. In addition to the risks discussed in this section, clients are encouraged to review the “Risk and Tax Disclosure” section in the Bank’s SPS Disclosure Statement. General Risks Associated with Investments Available in the Program. All investments involve risk, the degree of which varies significantly. Investment performance can never be predicted or guaranteed and the value of a client’s assets will fluctuate due to market conditions and other factors. Investments made and the actions taken respecting Account assets will be subject to various economic, geopolitical, and market conditions, such as changes in interest rates, availability of credit, inflation rates, global demand for particular products or resources, natural disasters, climate change, economic uncertainty, pandemics and epidemics (e.g. COVID-19), terrorism, social and political discord, debt crises and downgrades, regulatory events, governmental or quasi-governmental actions, changes in laws, and national and international political circumstances risks. Investments will not necessarily be profitable. Equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected for a portfolio or the securities market as a whole, such as changes in economic, geographical or political risks. There is equity risk in that stock prices may fluctuate over short or extended periods of time. Fixed income securities have interest rate risk in that they will increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally decline. On the other hand, if rates fall, the value of the investments generally increases. Securities with greater interest rate sensitivity and longer maturities generally are subject to greater fluctuations in value. In general, if interest rates rise, bond prices fall, and if interest rates fall, bond prices rise. These securities also have credit risk where changes in the financial condition of an issuer or guarantor of a fixed-income security or a counterparty to a contractual obligation and changes in general economic conditions may impact the actual or perceived willingness or ability of an issuer, guarantor or counterparty to make timely payments of interest or principal or to otherwise honor its obligations. Such changes may result in a loss. 12 MAA-MerrillSPS-09-2026 In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Investments in some securities can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. Investing in securities exposes the client to market risk, where security prices in a market, sector or industry may fall, reducing the value of a client’s Program Account(s). These securities also bear inflation risk, where returns on fixed-income securities may not keep pace with inflation. Foreign securities are subject to special risks, including, without limitation, limited liquidity, delays in settlement, less publicly available information about companies, the impact of political, social or diplomatic events, taxation, possible seizure, expropriation or nationalization of a company or its assets, and possible imposition of currency exchange controls. Foreign markets may be extremely volatile. Clients should review the offering materials and other disclosure available for each relevant investment security or transaction, including any prospectuses and other offering material produced by issuers and sponsors of investment products, to get an appreciation of its associated risks and fees. Clients are assuming the risks involved with investing in securities and other investment products, and could lose all or a portion of the amount held in the Program. For a discussion of conflicts of interest with the use of certain investments and securities, please review the information in this section and in “Offering of Investments or Programs Managed by Us or Our Affiliates.” Management Risk. Investment decisions might produce losses or cause a client’s Program Account to underperform relative to a relevant benchmark or peer group. The Bank’s decisions or recommendations with respect to Style Managers and Strategies also may cause underperformance of a client’s Account(s) relative to either the client’s expectations or similar programs, and there is no guarantee that the selected or recommended Style Manager(s) and/or Strategies will produce the desired results. SII-themed Strategies or Funds. There are an increasing number of products and services that purport to offer sustainability or impact investing strategies (“SII Strategies”). The variability and imprecision of industry SII definitions and terms can create confusion. Investment managers and product sponsors have designed their own approach to SII investing and how they use SII-related terms for their investment products. Generally, none of MAA, Merrill and the Bank undertake a review of these approaches (including, where applicable, any SII-related investment policy or process followed by the manager) other than as part of the CIO Review Process. The client should review the offering materials and the Strategy Profiles to gain an understanding of how these managers and product sponsors describe their investment approach. SII Strategies, including SII-related mutual funds and ETFs, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an SII or sustainable focus. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries or sectors that share common characteristics and are often subject to similar business risks and regulatory burdens. Because investing on the basis of SII criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by a Style Manager or Fund manager, will align with the beliefs or values of the client. In addition, investments identified as demonstrating positive SII characteristics at a particular point in time might not exhibit positive or favorable SII characteristics across all relevant metrics or methodologies or on an ongoing basis. SII or sustainable investing practices differ by asset class, country, region and industry and are constantly evolving. As a result, a company’s SII-related practices and the Style Manager assessment of such practices could change over time. SII Strategies can follow different approaches. For example, some SII Strategies select companies based on positive SII characteristics while others may apply screens in order to exclude particular sectors or industries from an investment portfolio. Restrictions and exclusions can affect the portfolio manager’s ability to make investments or take advantage of opportunities that may be available to clients that do not choose similar restrictions and, as a result, investment performance could suffer. On the other hand, category restrictions that aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category may not exclude all companies with any tie or revenue derived from such restricted category and require assumptions, opinions and the subjective judgment of the data provider that might not reflect the views or values of the client. If a client holds an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event for the client. For client accounts that can hold Funds, clients cannot prohibit or restrict a portfolio manager of a Fund from investing in specific securities or types of securities that are held within any Fund. Category restrictions will not be applied to strategies that invest only in Funds, nor will they be applied to investments made by Funds, so it is possible that client restrictions would not have any practical effect on an account comprised primarily of Fund investments. When evaluating investments for an SII Strategy, a Style Manager or Fund manager is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause an incorrect assessment of an investment’s SII attributes. None of 13 MAA-MerrillSPS-09-2026 MAA, Merrill or the Bank guarantees or validates any third-party data, ratings, screenings or processes. Moreover the screenings and processes to implement category restrictions are not absolute and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in an Account holding investments in companies that derive revenue from the restricted category. Regulatory Risk. The overall investment activities of the Bank, MAA, Merrill and their Affiliates may limit the investment opportunities for a client’s Program Account(s) in certain markets in which limitations are imposed by regulators upon the amount of investment by affiliated investors, in the aggregate or in individual issuers. From time to time, a client’s Program Account’s activities also may be restricted because of regulatory restrictions applicable to the Bank, MAA, Merrill or their Affiliates, and/or their internal policies. Information Security, Cybersecurity and Artificial Intelligence. With the increased use of technologies to conduct business, like all companies, MAA, Merrill, the Bank and BofA Corp., its Affiliates, customers and clients and service providers are susceptible to operational, information security, and related risks. All are targets of an increasing number of cybersecurity threats and cyberattacks. Cyber-incidents cause disruptions and affect business operations, potentially resulting in financial losses, impediments to trading, the inability to transact business, destruction to equipment and systems, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. Similar adverse consequences could result from cyber-incidents affecting issuers of securities, Style Managers, Funds and sponsors, counterparties, governmental and other regulatory authorities, exchange and other financial market operators, banks, brokers, dealers, insurance companies and other financial institutions (including financial intermediaries and service providers), and other parties. MAA and Merrill, as well as BofA Corp., seek to mitigate cybersecurity risk and associated legal, financial, reputational, operational and/or regulatory risks by employing a multifaceted program through various policies, procedures and playbooks that are focused on governing, preparing for, identifying, preventing, detecting, mitigating, responding to and recovering from cybersecurity threats and cybersecurity incidents directed at BofA Corp. and its Affiliates and its third-party service providers. MAA, Merrill, the Bank and its third-party providers have experienced cybersecurity incidents as well as adverse impacts from such incidents and expect to continue to experience such incidents resulting in adverse impacts with increased frequency and severity due to the evolving threat environment. There can be no assurance that they will not suffer losses relating to cybersecurity attacks or other information security breaches in the future. In addition to cybersecurity incidents and information security breaches, the focus on information security includes the collection, use and sharing of data, the safeguarding of personally identifiable information and corporate data, and the development, implementation, use and management of emerging technologies, including artificial intelligence (“AI”) and machine learning. We rely on our ability to manage and process data in an accurate, timely and complete manner, including capturing, transporting, aggregating, using, transmitting data externally, and retaining and protecting data appropriately. Our data management processes may not be effective and are subject to weaknesses and failures, including human error, data limitations, process delays, system failure or failed controls. Failure to properly manage data effectively in an accurate, timely and complete manner may adversely impact its quality and reliability and could adversely impact our ability to develop our products and relationships with customers, increase regulatory risk and operational losses, and damage our reputation. The Bank, MAA and Merrill and their Affiliates may use programs and systems that utilize AI, machine learning, probabilistic modeling and other data science technologies (“AI Tools”), including those developed by third parties. AI Tools are highly complex and may be flawed, hallucinate, reflect biases included in the data on which such tools are trained, be of poor quality, or be otherwise harmful, which therefore requires supervision and oversight. The legal and regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving, and could require changes in our implementation of AI Tools and increase compliance costs and the risk of non- compliance. There is limited visibility over the accuracy and completeness of AI Tools developed by third parties. AI Tools often use data feeds from a number of sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool will be unable to properly function or their operation may be adversely impacted. The AI Tools’ ability to use the data may also be adversely impacted by any change in the format of data delivered or acquired by the tool. Furthermore, the use of AI tools may lead to increased risks of cyber-attacks or data breaches and the ability to launch more automated, targeted and coordinated attacks due to the vulnerability of AI technology to cybersecurity threats. Crypto Investment Vehicles. As of the date of this Brochure, the Program does not offer any Strategies that invest in ETFs and other investment vehicles (“Crypto Investment Vehicles”) that invest in or hold underlying positions in, or derive value from, cryptocurrency (for example, Bitcoin or Ether) or cryptocurrency derivative contracts (collectively, “crypto assets”). To the extent any such Strategies are offered, the Strategy Profile will describe the potential availability of Crypto Investment Vehicles and crypto assets. The risks of these investments are generally described below. The risks related to an investment in Crypto Investment Vehicles and crypto assets are significant. Crypto assets are highly speculative and have been in existence for only a short period of time. A significant portion of the demand for crypto assets is generated by speculators and investors seeking to profit from short-term holdings. Media headlines, tweets, or influencers’ opinions can significantly influence performance given the speculative nature of cryptocurrency. Historical prices of crypto assets have been extremely volatile. Crypto asset prices can decline rapidly, and investors can lose their entire investment within a short period. Some crypto assets have concentrated ownership or a number of large holders, who may cause unexpected price declines by selling or transferring their holdings without warning. 14 MAA-MerrillSPS-09-2026 Due to the new and evolving nature of crypto assets, the regulatory landscape is uncertain. Future legal and regulatory developments may negatively impact the value of crypto assets and may adversely impact the ability of Crypto Investment Vehicles to operate. There is substantial uncertainty regarding the U.S. federal, state, and local tax treatment of (1) crypto assets and (2) Crypto Investment Vehicles. Additionally, the treatment of crypto assets for tax purposes by non-U.S. jurisdictions may differ from the treatment of crypto assets for U.S. federal, state or local tax purposes. It is possible, for example, that a non-U.S. jurisdiction would levy sales tax or value- added tax on purchases and sales of certain crypto assets, or impose other onerous tax burdens on crypto assets. Future guidance regarding the tax treatment of crypto assets could have an adverse impact on the prices of crypto assets, or increase the expenses of Crypto Investment Vehicles. Certain Crypto Investment Vehicles can generate unrelated business taxable income (“UBTI”) for tax exempt investors like individual retirement accounts. There are no broadly accepted or standardized valuation methodologies or pricing models for crypto assets. The prices at which crypto assets trade may vary widely among different trading venues. As a result, any value and performance data of crypto assets may be difficult to measure or verify. This can, in turn, exacerbate any tracking error of Crypto Investment Vehicles that seek to track the performance of crypto assets, potentially leading such vehicles to trade at significant premiums and discounts. Similarly, this can also exacerbate any adverse impact on the performance of futures-based Crypto Investment Vehicles, cause them to underperform the spot price of the crypto assets associated with them, and/or exacerbate any such underperformance. Certain crypto asset exchanges have experienced failures or interruptions in service due to fraud, Ponzi schemes, bucket shops, pump and dump schemes, security breaches, operational problems or business failure. Similar events could impact the value of a Crypto Investment Vehicle that has exposure to a crypto asset, regardless of whether the Crypto Investment Vehicle relies on such an impacted exchange. Further, certain crypto exchanges are not regulated to the same extent as national securities exchanges or registered futures exchanges, which increases the chance that transactions conducted on such exchanges are subject to market manipulation. Both factors can impact the ability of the Crypto Investment Vehicle to transact in the crypto asset and/or materially and adversely impact its price, thereby decreasing the value of the investment, regardless of whether the Crypto Investment Vehicle relies on an impacted exchange. Furthermore, crypto asset related investments are subject to cybersecurity risks. Crypto assets—including crypto assets of a Crypto Investment Vehicle—could be permanently lost, stolen, destroyed or become inaccessible by virtue of, among other things, the loss or theft of the private keys necessary to access a crypto asset. The network associated with the crypto asset could be subject to attacks by malicious actors, software changes and/or changes in the level of continued engagement by developers, operators and validators of such networks, any of which could have a material and adverse impact on the crypto asset. Crypto assets are not legal tender, and are not backed by any government, corporation or other identified body, other than with respect to certain cryptocurrencies that certain governments are or may be developing now or in the future. Crypto assets are not FDIC insured or covered by SIPC. Due to the anonymity cryptocurrencies offer, they have known use in illegal activity, including drug dealing, money laundering, human trafficking, sanction evasion and other forms of illegal commerce. Abuses could impact legitimate consumers and speculators; for instance, law enforcement agencies could shut down or restrict the use of platforms and exchanges, limiting or shutting off entirely the ability to use or trade crypto asset related products. Certain Crypto Investment Vehicles are not registered under the Investment Company Act of 1940, as amended (“1940 Act”), and are not subject to regulation under the 1940 Act. Investors in such Crypto Investment Vehicles will not, therefore, receive the regulatory protections afforded by funds registered under the 1940 Act. For more information, clients should review the risk factor discussions in the Crypto Investment Vehicle prospectus, periodic reports and/or other offering material. ITEM 9. DISCIPLINARY INFORMATION There are no legal or disciplinary events that MAA believes are material to a client’s or prospective client’s evaluation of MAA’s advisory business or the integrity of MAA’s management. In the past, the Bank and other of its Affiliates, including MLPF&S, have entered into certain settlements with regulators and other third parties and have been the subject of adverse legal and disciplinary events. The following is a summary of certain disciplinary events of Merrill. Clients can find information regarding these settlements in MLPF&S’ Form ADV Part 1A and ADV 2A brochure at adviserinfo.sec.gov. On January 17, 2025, the SEC issued an administrative order in which it found that MLPF&S willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. The order found that, from January 2022 through April 2024, MLPF&S failed to adopt and implement reasonably designed written policies and procedures (i) to consider the best interests of clients when evaluating and selecting which cash sweep program options to make available, specifically its use of the Merrill Lynch Bank Deposit Program and (ii) concerning the duties of its financial advisors in managing client cash in advisory accounts. The order recognized that MLPF&S took certain steps designed to consider the best interests of its clients in operating its cash sweep program and in managing client cash in advisory accounts during the relevant period. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, and payment of a civil monetary penalty in the amount of $25,000,000. On September 25, 2024, the SEC issued an administrative order in which it found that during the period from March 2016 to April 2018, MLPF&S failed to adequately notify certain clients with which it had a fiduciary relationship of their over-exposure to the Harvest Volatility Management LLC’s Collateral Yield Enhancement Strategy, an options overlay strategy for which Harvest was the 15 MAA-MerrillSPS-09-2026 Third-party private investment manager and MLPF&S the custodian. In doing so, MLPF&S willfully breached its fiduciary duty under Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder to such fiduciary clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement and prejudgment interest totaling $2,800,000, and payment of a civil monetary penalty in the amount of $1,000,000. On April 3, 2023, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) and (4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the order found that from May 12, 2016 through June 29, 2020: (1) wrap fee advisory program agreements and ADV brochures contained a material misstatement because, while disclosing that MLPF&S charged a mark-up or markdown on foreign currency exchanges, the disclosure did not also state that an additional fee referred to as a production credit was also charged and (2) there was a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with disclosures relating to currency transfers requiring foreign currency exchanges that it processed for its wrap fee clients. MLPF&S, without admitting or denying the findings, consented to the imposition of a cease-and-desist order, censure, payment of disgorgement, prejudgment interest and a civil penalty totaling $9,694,714. On April 17, 2020, the SEC issued an administrative order in which it found that MLPF&S had willfully violated Section 206(2) of the Advisers Act. Specifically, the order found that from January 1, 2014 to May 31, 2018, it failed to disclose in its Form ADV or otherwise the conflicts of interest related to (1) its receipt of 12b-1 fees and/or (2) its selection of mutual fund share classes that pay such fees. During this period, MLPF&S received 12b-1 fees for advising clients to invest in or hold such mutual fund share classes. In determining to accept the offer of settlement, the SEC considered that MLPF&S self-reported to the SEC pursuant to the SEC’s Share Class Selection Disclosure Initiative and had completed a number of the undertakings in the order prior to issuing the order. In the order, MLPF&S was censured and ordered to cease and desist from committing or causing any violations and any future violations of Section 206(2) of the Advisers Act. It was also ordered to make disgorgement payments of $297,394 and prejudgment interest payments of $27,982 to affected investors. On August 20, 2018, the SEC announced that MLPF&S, without admitting or denying the findings, entered into a settlement related to willful violations of Sections 206(2) and 206(4) of the Advisers Act and Advisers Act Rule 206(4)-7. Specifically, the SEC’s administrative order found: (1) a failure to disclose that the portfolio manager process employed in connection with a January 2013 termination recommendation was exposed to a conflict of interest (less than one-seventh (1/7) of 1% of total advisory accounts (approximately 1,500) were invested in the products subject to the termination recommendation); and (2) a failure to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act. In determining the appropriate sanctions, the SEC considered MLPF&S’ remedial acts promptly undertaken and cooperation afforded the SEC staff. MLPF&S consented to the imposition of a cease-and-desist order, a censure, and disgorgement and a financial penalty totaling approximately $8.8 million. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS MAA, a direct wholly-owned subsidiary of Merrill and an indirect wholly-owned subsidiary of BofA Corp., is an SEC-registered investment adviser that provides investment advisory services to clients that establish accounts under various investment advisory programs and the Program. Merrill, an indirect wholly-owned subsidiary of BofA Corp., is a leading global wealth management firm and a registered broker-dealer and investment adviser. In the United States, Merrill acts as a broker (i.e., agent) for its corporate, institutional and private clients. Through its own arrangements and through Affiliates, it has access to a dealer market in the purchase and sale of corporate securities, primarily equity and debt securities traded on exchanges or in the over-the-counter markets. Merrill also acts as a broker and/or a dealer in the purchase and sale of mutual funds, money market instruments, government securities, high- yield bonds, municipal securities, financial futures contracts, and options. Merrill operates the firm’s U.S. retail branch system and also provides financing to clients, including margin lending and other extensions of credit as well as a wide variety of financial services, such as securities clearing, retirement services, and custodial services. As registered investment advisers, MAA and MLPF&S complete Form ADVs which they publicly file with the SEC (available at adviserinfo.sec.gov). For purposes of Form ADV, certain MLPF&S and/or MAA management persons are registered as registered representatives or associated persons of MLPF&S. In the future, certain MLPF&S and MAA personnel may be considered management persons and, as such, may be registered, or have applications pending to register, as registered representatives and associated persons of MLPF&S to the extent necessary or appropriate to perform their job responsibilities. BofA Corp., through its subsidiaries and Affiliates, provides broker-dealer, investment banking, financing, wealth management, advisory, asset management, insurance, lending and related products and services on a global basis. These products and services include (1) securities brokerage, trading and underwriting; (2) investment banking, strategic advisory services (including mergers and acquisitions) and other corporate finance activities; (3) wealth management products and services including financial, retirement and generational planning, asset management and investment advisory and related record-keeping services; (4) origination, brokerage, dealer and related activities in swaps, options, forwards, exchange-traded futures, other derivatives, commodities and foreign exchange products; (5) securities clearance, settlement financing services and prime brokerage; (6) private equity and other principal investing activities; proprietary trading of securities, derivatives and loans; (7) banking, trust and lending services, including deposit-taking, consumer and commercial lending, including mortgage loans, and related services; (8) insurance and annuities sales; and (9) providing research including global equity strategy and economics, global fixed-income and equity-linked research, global fundamental equity research, 16 MAA-MerrillSPS-09-2026 and global wealth management strategy. BofA Corp. is subject to the reporting requirements of the Exchange Act and additional information about BofA Corp. can be found in publicly available filings with the SEC. The Bank’s Representatives may suggest or recommend that Program clients use its Affiliate’s securities account, execution and custody or other services for the client’s investment activity or use the services of its Affiliate. Similarly, Representatives may suggest or recommend that clients utilize MAA’s, Merrill’s or Affiliates’ products. Where a client uses their services or products, they will receive fees and compensation. Representatives typically do not, but may, as permitted by applicable law, receive compensation (the amount of which varies) in connection with these products and services. The Bank does not currently offer any Related Funds in the Program. The Bank may, however, include Related Funds as an investment product available in the Program in the future. To the extent permitted by applicable law, Merrill and/or its Affiliates would receive compensation with respect to shares of Related Funds in which a Program Account may be invested. MAA, Merrill and the Bank address conflicts from compensation described in this section and throughout this Brochure in a variety of ways, including through disclosure of the conflicts in this Brochure and the Bank’s SPS Disclosure Statement. Moreover, Representatives are required to recommend investment products and securities and services that are appropriate for, and in the best interest of, each client based upon the client’s investment objectives, risk tolerance and financial situation and needs and considering cost. In addition, MAA and Merrill have established a variety of restrictions, procedures and disclosures designed to address actual and potential conflicts of interest – both those arising between and among Program Accounts as well as between Program Accounts and their business. ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Conflicts of Interest and Information Walls The Bank, MAA, Merrill and BofA Corp., engage in a wide range of activities and businesses across a broad spectrum of clients. As a result, we recognize actual, potential and perceived conflicts of interest develop in the normal course of operations in various parts of the BofA Corp. organization. To address these conflicts, information walls are in place which are designed to allow multiple businesses to engage with the same or related clients at the same time, while mitigating any conflicts arising from such a situation. For example, information walls are designed to prevent the unauthorized disclosure of material nonpublic information and allow public side sales, trading and research activities to continue while other businesses within BofA Corp. possess material nonpublic information. Additionally, BofA Corp. maintains a Code of Conduct which outlines the business practices and professional and personal conduct all associates and board members are expected to adopt and uphold. Managing conflicts of interest is an integral part of BofA Corp.’s risk management process. We believe that no organization can totally eliminate conflicts that exist explicitly or implicitly. Each of BofA Corp., the Bank, Merrill and MAA evaluates its business activities and the actual and possible conflicts that may emerge from its activities on an ongoing basis. To the extent that existing or new business activities raise an actual conflict of interest, or even the appearance of a conflict, we endeavor to provide clients with full and clear disclosure or to take action to avoid or manage the conflict. Code of Ethics Each of Merrill and MAA has adopted an Investment Adviser Code of Ethics (the “Code of Ethics”) covering its personnel who are involved in the operation and offering of investment advisory services under the various investment advisory programs for which they are a registered investment adviser. Each Code of Ethics is based on the principle that clients’ interests come first, and it is intended to assist employees in meeting the high standards that each of MAA and Merrill follows in conducting its business with integrity and professionalism. Each Code of Ethics covers requirements relating to employees complying with all applicable securities and related laws and regulations; reporting and/or clearance of employee personal trading; prevention of misuse of material nonpublic information; and the obligation to report possible violations of the Code of Ethics to management or other appropriate personnel. Covered personnel must certify receipt of the Code of Ethics. MAA and Merrill will provide a copy of their Code of Ethics to clients upon request to a Representative. MAA and Merrill each has imposed policy restrictions on all personnel for transactions for their own accounts and accounts over which they have control or a beneficial interest. In addition, both have special policies requiring that certain personnel obtain specific approval of their securities transactions and have implemented procedures for monitoring these transactions, as well as those of all their employees. Agency-Cross and Other Cross Transactions At times, MAA or a Discretionary Manager may consider a security being sold by one investment advisory client to be appropriate for purchase by another investment advisory client account. In such cases, MAA or a Discretionary Manager may arrange to transfer or “cross” the security directly between the affected accounts. Any cross transactions in Accounts would be effected in accordance with applicable law and the Client Agreement, and only when the transaction is in the best interest of each party. Cross transactions generally will be effected at an independently determined market price and will not result in any additional compensation to MAA, the Bank or their Affiliates. 17 MAA-MerrillSPS-09-2026 There may be instances in which Merrill or its Affiliates has the opportunity to act as agent for both buyer and seller in a transaction for a client’s Account, in accordance with applicable law. This is called an “agency-cross” transaction. Since Merrill or its Affiliate generally will receive compensation from each party to an agency-cross transaction, there is a conflict between Merrill’s or its Affiliates’ responsibilities and loyalties to a Program client and to the other party to the transaction. Compensation received by Merrill or its Affiliate from the other party in an agency-cross transaction would be in addition to the fees described in this Brochure. Funds and Fund Compensation The Style Managers may recommend for purchase or purchase Funds, including Manager-Related Funds, for a client’s Account. The fees, expenses, and other charges, of these Funds, are in addition to Account Fees, unless such fees, expenses and other charges are credited to the Account. Each of the Funds pays investment management fees to its investment adviser and incurs other expenses. More complete information about the Funds, including risks, management fees and other charges and expenses, is contained in each Fund’s prospectus or other applicable disclosure document. Merrill earns additional compensation for services rendered in connection with Funds. For example, Merrill or its Affiliate may execute brokerage transactions for a Fund included in a client’s Account or provide shareholder sub-accounting services to a constituent Fund used in a Strategy, for which it will be paid. Mutual funds purchased in a client’s Account will generally consist only of classes of shares with no contingent deferred sales charge (“CDSC”), or front-end sales loads (or with such charges waived). In addition, from time to time, a Fund may authorize Merrill or its Affiliates to make available to clients participating in the Program a class of shares of a Fund with a fee that is more beneficial to clients than the class of shares previously made available. In such circumstances, Merrill will effectuate the exchange to the other class of shares of the same mutual fund. As a general rule, the constituent mutual funds, and share classes that are part of a Strategy offered in the Program pay Merrill to provide the required associated sub-accounting and other services. These sub-accounting and other services include aggregating and processing purchases, redemptions, exchanges, dividend reinvestment, consolidated account statements, tax reporting and other related processing and recordkeeping services (together, “sub-accounting services”). Under Merrill agreements with each mutual fund (or its respective principal underwriter or other agent), Merrill provides daily sub-accounting services (either directly or through a subsidiary) to the holders of these types of mutual funds maintaining shares in Accounts as well as in Merrill securities accounts and receives the agreed-upon sub-accounting services fee. This cost is either borne by the mutual fund (like other fund expenses) as part of its operating costs or by its adviser, principal underwriter or other agent. These service arrangements and the amount of compensation vary by type of mutual funds, the mutual fund itself and by share class. These fees and fee rates are subject to change from time to time and may be received individually or as part of a “bundled” arrangement that includes other types of fees, such as administration and distribution payments. For U.S. mutual funds, depending on the specific arrangements, the sub-accounting services fees are paid from or on behalf of the mutual fund. These fees are either an asset-based fee of up to 0.10% per annum or up to $16 annually per client position in the mutual fund. For U.S. money market mutual funds, the sub-accounting services asset-based fee is generally 0.005% per annum. Merrill does not retain compensation for sub-accounting services for funds held in Retirement Accounts and for Accounts enrolled in the Program. An Account will be credited with the Account’s pro rata share of any sub-accounting services fees paid by a Fund to Merrill related to shares of the Fund held in a client’s Account. Merrill, MAA and the Bank have direct or indirect conflicts of interest in selecting certain Fund products (or share classes) for inclusion as part of their product offering available to clients. Certain mutual funds or share classes that would otherwise meet their criteria for inclusion as part of their product menu but whose principal underwriters, agents or sponsors do not agree to pay the sub-accounting and/or annual shareholder services fees that Merrill charges will not be selected, thereby limiting the available universe of funds (and share classes) available. In addition, the amount of the sub-accounting services fees varies among funds and, in certain instances, between share classes of individual funds. Merrill receives higher sub-accounting fee payments from mutual fund families that have higher fund assets held in its clients’ accounts because the service fee calculation is based off of the level of the asset holdings. Additionally, there is a benefit to Merrill because the aggregate amount of the sub-accounting fees exceed the costs to provide these services. Merrill, MAA and the Bank address these conflicts of interest in the following ways. They disclose the nature of these sub-accounting service arrangements. The Bank also determines the compensation paid to Representatives on the same basis for all Program assets without regard to the amount of compensation it or its Affiliates receive. Representatives do not have an incentive to recommend certain Funds over others because they do not receive additional compensation as a result of these types of arrangements. In addition, the Bank and Merrill select Funds that are available and offered through the Program as well as in Merrill brokerage accounts and other investment advisory programs based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. Furthermore, an Account will be credited with the Account’s pro rata share of any sub-accounting services fees paid by a Fund to Merrill related to shares of the Fund held in a client’s Account. Certain mutual funds offer a fund share class that does not include a sub-accounting services fee. Accordingly, clients should not assume that they will be invested in the share class with the lowest possible expense ratio that the mutual fund provider makes available to the investing public. It is generally in a client’s best interest to purchase lower-fee share classes because the client’s returns 18 MAA-MerrillSPS-09-2026 are not reduced by additional fees and expenses. Representatives do not have an incentive to recommend or select share classes that have higher expense ratios because their compensation is not affected by the share class selected. Certain ETFs engage an Affiliate as an authorized participant. In that role, the Affiliate engages in creation and redemption transactions directly with the ETF and is compensated through its market making activities in the secondary market. To the extent that a Style Manager utilizes a Manager-Related Fund that is charged a fund management fee by the Style Manager or its affiliate, Merrill, MAA or the Bank will work with the Style Manager to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the Style Manager Expense. The Bank, Merrill and MAA may in the future offer Related Funds in the Program. To the extent permitted by applicable law, MAA’s Affiliates would receive compensation with respect to shares of Related Funds in which an Account may be invested. Offering of Related Strategies and Use of a Related Strategy in a Client’s Account The Bank has approved of offering of certain Related Strategies. A client’s Representative can recommend a Related Strategy. In addition, in constructing a Related Strategy, the CIO as the Style Manager may include in its strategy model or recommendations to MAA a Strategy with a Style Manager Expense. Representatives do not have an incentive to recommend certain Strategies over others because they do not receive additional compensation. Merrill earns revenue from fees and payments from what it receives from Affiliates and from third-party investment managers, fund managers distributors and sponsors and other product providers related to certain investments that are part of a Strategy in a client’s Account. Merrill does not retain compensation for Fund fees and expenses paid by Third-Party Firms for Accounts enrolled in the Program and an Account will be credited with the Account’s pro rata share of any such fees paid by a Fund to Merrill related to shares of the Fund held in a client’s Account. Elements of our management compensation are based on revenues to Merrill and management personnel of Merrill and other employees of Merrill, MAA and their Affiliates receive incentive compensation based on a number of factors including the profitability of Merrill and BofA Corp. Their profitability is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank Affiliate cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of the management compensation approach that we follow. There is a financial incentive for Merrill management to structure the scope and approach of the compensation award program to result in revenue for Merrill and BofA Corp. Related Entities may provide advisory services for one or more Strategies available for a client’s selection. To the extent the Bank or its Affiliate is a significant stockholder in a Related Entity, this fact will be disclosed in the relevant Strategy Profile. If a Related Strategy is selected, MAA and its Affiliates can receive an additional economic benefit. For this reason, a conflict of interest exists when the Bank or its Representative selects or assists clients in the selection of, as applicable, a Related Strategy (or replacement Related Strategy, if applicable). Style Manager’s Use of Affiliated Investments Certain Strategies include Manager-Related Funds. The use of Manager-Related Funds creates a conflict of interest for the Style Manager relating to the Style Manager’s selection of Funds for the investment strategy and the receipt of potentially higher compensation or benefit based on the selection. The Style Manager has an incentive to select Manager-Related Funds over other Funds with lower expenses because the fees received for client Account assets in the Manager-Related Funds are their compensation. Style Managers that use Manager-Related Funds have an obligation under their fiduciary duties to select investments that are based on the investment merits of the particular investment products. As to the use of Manager-Related Funds, we obtain the agreement of the Style Manager that any fees or expenses with respect to a Manager-Related Investment, other than certain costs incurred within such product and reflected in its returns, will be borne by the Style Manager. In addition, where a Style Manager uses a Manager-Related Fund that is charged fund management fees by the Style Manager or its affiliates, Merrill will work with the Style Manager to provide a rebate of the fund management fees paid in respect of the Manager-Related Fund holdings as against the Style Manager Expense. The Program may make available Strategies that do not charge a Style Manager Expense. As a general matter, for such Strategies, the third-party Style Manager intends to allocate a significant percentage of the portfolio to investment strategies and Funds for which it and/or its Affiliates serve as investment manager and as to which it receives fees (“Style Manager-Related Investments”). These compensation arrangements create a conflict of interest for the Style Manager relating to the Style Manager’s selection of investments (including from among the Style Manager-Related Investments) for the Strategy and the receipt of potentially higher compensation based on the selection. The Style Manager has an incentive to select Style Manager-Related Investments for the Strategy (including Style Manager-Related Investments with higher expenses) over other investments with lower expenses. This is because the fees that the Style Manager and/or its Affiliates receive for client account assets in the Style Manager-Related Investments are their compensation with respect to the Strategy. This selection could result in less favorable performance for the Strategy than otherwise would be the case if the Style Manager had not allocated to a Style Manager-Related Investment. Provision of Diversified Financial Services BofA Corp. is a diversified financial services company that generally seeks to provide a wide range of services to retail and institutional clients for which it receives compensation. As a result, BofA Corp., Merrill, the Bank and their Affiliates can be expected to pursue 19 MAA-MerrillSPS-09-2026 additional business opportunities with the entities whose investments Merrill, the Bank and its Affiliates recommend or make available to clients. Consistent with industry regulations, these services could include: banking and lending services, sponsorship of deferred compensation and retirement plans, recordkeeping services, investment banking, securities research, institutional trading and prime brokerage services, custody and clearing services, investment advisory services, licensing arrangements involving indices and effecting portfolio securities transactions for clients. Firm professionals involved with the offering of Funds to individual investor clients may introduce Fund distributors, sponsors, service providers or their affiliates to other services that BofA Corp., Merrill, the Bank and their other Affiliates provide and earn additional compensation for the services. In addition, from time to time, BofAS and other of our Affiliates may acquire equity stakes in market centers (e.g., national securities exchanges or alternative trading systems) as part of a strategic investment and therefore stand to participate as a shareholder and investor in the profits that each market center realizes in part from the execution of securities transactions, including transactions for an Account. Additional information regarding these relationships are publicly available in Regulation NMS Rule 606 reports that Merrill files with the SEC. Other Relationships and Interests; Activity by MAA, Merrill and their Personnel and Affiliates MAA, Merrill, the Bank and their Affiliates have business relationships with the officers, directors or employees of a variety of clients, including corporations, pension and retirement plans, and other entities. These business arrangements create a conflict of interest to the extent that these individuals have any role or influence in the hiring or retention of MAA, Merrill, the Bank and their Affiliates. The Bank, Merrill and other of their Affiliates limit the overall aggregate ownership in certain Registered Funds that are mutual funds and ETFs (“In-Scope Funds”) by the Bank, Merrill, their Affiliates and those of their clients that have granted discretion to MAA, the Bank, Merrill, their Affiliates, Bank Representatives, and/or Merrill financial advisors (“discretionary clients”) to avoid potential restrictions on the ability of their Affiliates to engage in principal trading and other transactions with In-Scope Funds. A portion of the aggregate ownership limit is attributed to their Affiliates. When their Affiliates choose to allocate a portion of an investment opportunity in an In-Scope Fund to the Bank, Merrill or their Affiliates, there is a corresponding reduction under the overall aggregate ownership limit of In-Scope Fund shares available for investment by discretionary clients. As a result of these ownership limits and allocations, discretionary clients will face limits on their ability to invest in In-Scope Funds from time to time and can be precluded from investing in certain In-Scope Funds that otherwise might have been the best available investment alternatives. Because the Bank’s, Merrill’s and their Affiliates’ ownership is applied to determine the aggregate ownership limits, such limits create conflicts of interest in determining the amount of investment opportunities in In-Scope Funds that are available to discretionary clients. From time to time, a shareholder of BofA Corp. could acquire a sufficiently large interest in BofA Corp. that the holding triggers statutory or regulatory obligations or restrictions. In such event, our ability to take certain actions or make recommendations within an Account, such as buying or selling securities issued by the shareholder or its Affiliates, will be limited. Cash Balances and the Cash Sweep Program MAA, Merrill, the Bank or their Affiliates receive additional economic benefits from cash held in clients’ Accounts. A Strategy includes a cash allocation for operational and implementation and/or investment purposes as directed by the Style Manager. The cash allocation will be higher at certain times depending on the nature of the Strategy, the asset allocation, the investment determinations or rebalancing being made and market conditions. Until invested, the cash for these investments is typically held in a cash balance and subject to the Cash Sweep Program or invested in cash alternatives or other investment products as determined by the Style Manager as a temporary investment pending purchase of the individual security. To the extent that a cash alternative vehicle is not selected for the Account’s cash allocation by the Style Manager, there is a conflict of interest between the client and Merrill and/or MAA and the Bank because the cash allocation will be maintained in the Account as a cash balance. Until invested, cash balances will be swept to bank deposit accounts at the Bank through the Cash Sweep Program. Depending on the client’s election, cash balances will be swept to the Bank or to a money market mutual fund available under the Cash Sweep Program. If cash balances are deposited in a deposit account with the Bank, the Bank will receive additional economic benefits from cash investments held in the client’s Account and the use of the deposits. The Bank benefits financially from the Cash Sweep Program. Through the Cash Sweep Program, the Bank receives a stable, cost- effective source of funding. The Bank uses the bank deposits to fund its current and future lending, investment and other business activities. Its participation in the Cash Sweep Program increases deposits and accordingly overall profits. Bank profitability is determined, in large part, by the “spread” earned on the deposits — the difference between the interest paid on the bank deposits and other amounts paid out to others related to these deposits, on the one hand, and the interest or other income earned on loans, investments and other assets which may be funded in part by bank deposits, on the other hand. The greater the amount of cash balances maintained in clients’ Accounts that is swept into a bank deposit account affiliated with the Cash Sweep Program and the lower the interest rate paid on the related bank deposit, the more the Bank benefits. Cash balances swept to a deposit account of the Bank will bear a rate of interest that has been established for, and in light of the features of, the Cash Sweep Program. The rate of interest for such deposit accounts is periodically set and reset by the Bank in its discretion. The rate is variable and may change at any time after the Account is opened without notice or limit. The conflicts of interests associated with the Cash Sweep Program and the deposit accounts are addressed in a variety of ways, including through disclosure in this Brochure, oversight and supervision of particular account type relationships and specific investment 20 MAA-MerrillSPS-09-2026 product choices, account and product disclosures and documentation provided to clients throughout their account relationship. There is no charge, fee or commission imposed with respect to a client’s participation in the Cash Sweep Program. Management personnel of the Bank, MAA, Merrill and their Affiliates receive incentive compensation based on a number of factors including the profitability of the Bank, Merrill and BofA Corp., which is impacted by a number of factors including the growth of the business, management of expenses, the amount of Bank cash sweep assets and the rate that is paid on those assets. We have a conflict of interest as a result of this management compensation approach. There is a financial incentive for management to structure the scope and approach of the compensation award program to result in revenue for the Bank, Merrill and BofA Corp. We maintain policies and procedures, including governance approval requirements, that are designed to review and mitigate any financial incentive or conflict to favor any one security type or investment product or service. We also provide disclosures of these conflicts in the Brochure and other client documents. Relationships With Asset Managers, Sponsors and Style Managers MAA, Merrill and the Bank, as well as their other Affiliates, have business relationships with investment managers, including Style Managers, Fund managers, distributors and sponsors, and insurance companies and other product providers (“Third-Party Firms”). Bank Affiliates make available research, execution, custodial, pricing and other services in the ordinary course of business. Third-Party Firms can direct transactions to these Affiliates including effecting transactions in the ordinary course of business for Funds and product vehicles managed or sponsored by them. These Affiliates also make available brokerage services and other Merrill or Affiliate programs and services, including banking and lending services. Any compensation paid to such Affiliates by a Third-Party Firm is additional compensation for services provided. Having business relationships with Third-Party Firms creates a conflict of interest and can affect opportunities to negotiate more favorable financial terms for client investments in the products of the Third-Party Firms. The nature of MAA’s, Merrill’s and their Affiliates’ relationships in general with Third-Party Firms is disclosed. Representatives do not have an incentive to recommend certain investment products, including managed strategies, over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Additionally, Strategies and Funds that are available through the Program and through Merrill investment advisory programs are selected based on qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and on the consistency of the execution of their strategy. Merrill, MAA and the Bank have adopted various policies and procedures reasonably designed to prevent the receipt of such compensation and other business arrangements from affecting the nature of the advice that its representatives provide. In connection with the onboarding, maintenance or support of various investment products, services, platforms or tools, Merrill and MAA reserve the right to seek reimbursement (or participation in the sharing) of costs associated with such onboarding, maintenance or support, including technology-related costs from Third-Party Firms for particular projects. The participation of, and payment of costs by, Third-Party Firms in connection with the onboarding, maintenance or support of their investment products services, platforms or tools creates a conflict with its ability to use strictly objective factors when selecting products and product sponsors to make available on our platform. This conflict is addressed in a number of ways, including those described above in this section. Bank Representatives are not incentivized to recommend the products or services of a Third-Party Firm that makes such payments over those that do not and they do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Furthermore, other Bank, Merrill and MAA employees are not incentivized to approve particular products of a Third-Party Firm. Third-Party Firms are not permitted to condition their payment of such costs on any amount of sales of their products or services. Third-Party Firm reimbursement or participation in the sharing of any such costs must align to internal policies and policy limits which have been reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice provided. Certain Third-Party Firms periodically participate in internal training and education conferences (“Conferences”) for invited financial professionals, which may include Representatives and employees of MAA, the Bank, and Merrill. These financial professionals may include employees who cover product and home office support functions, which included employees of the CIO (“Non-Field Employees”). Conferences are organized on either a national or local level. Client and prospect events (e.g., seminars, trade shows, booth events) can also be held where Third-Party Firms participate (“Client Events”). Third-Party Firms reimburse Merrill for eligible costs associated with the Conferences and Client Events. Eligible reimbursable costs include venue and facilities (including food and beverages), certain speaker and continuing education costs for attending financial advisors and select employees facilitating the Conferences and/or Client Events. In addition, Third-Party Firms are permitted to pay for the cost of travel and accommodation for financial advisors and, on a limited basis, Non-Field Employees, except for employees of the CIO due diligence team. During 2025, Merrill was reimbursed by participating Third-Party Firms for certain expenses incurred in connection with a number of Conferences and Client Events in the amount of approximately $28.4 million. Certain Third-Party Firms periodically host or participate in educational meetings (“Manager Meetings”) that provide Representatives and Merrill and/or MAA financial professionals, including Non-Field Employees with the opportunity to interact with their investment and sales personnel and to receive information and education on market conditions and events, investment products and services and practice management guidance. Third-Party Firms that hold any such Manager Meetings pay for all eligible costs associated with such meetings, including the cost of travel and accommodation and for the attendees (not including any Representative or any employee of the CIO due diligence team). In 2025, the total expenditures made by participating Third-Party Firms relating to Manager Meetings was 21 MAA-MerrillSPS-09-2026 $2.5 million. Third-Party Firms also provide monetary support directly to charities or in connection with charitable events and causes that Merrill or its employees support or attend. The total contributions made by Third-Party Firms in support of charitable events and causes that we requested or initiated with the Third-Party Manager in 2025 was less than $300,000. The participation of, and payment of costs by, a Third-Party Firm for Conferences, Client Events, Manager Meetings and charitable events present conflicts of interest. They create incentives for Representatives and Merrill and/or MAA financial professionals to recommend products of participating Third-Party Firms. They give those participating in Conferences, client meetings and Manager Meetings with more opportunities to interact and build relationships with Third-Party Firms and their personnel which could lead them to recommend the products and services of these Third-Party Firms over others. There is also a conflict of interest for non-Field Employees to select products of the Third-Party Firm. These conflicts are addressed in a number of ways. There is no requirement that Third-Party Firms reimburse Merrill or the Bank for, or pay the costs of, such events in order for their investment products to be made available. Neither Merrill nor MAA incentivize Non-Field Employees to approve particular products of a Third-Party Firm. Third-Party Firms are not permitted to condition their payment on any amount of sales of their products or services. Third-Party Firm reimbursements for costs of meetings and events must align to applicable internal policies and policy limits and are subject to supervision and oversight that is reasonably designed to review the nature of the business interactions and level of expense reimbursement from affecting the nature of the advice provided. Representatives are subject to Bank supervision and oversight and do not have an incentive to recommend certain investment products over others because they do not receive additional compensation as a result of these types of arrangements or compensation. Representatives can attend Conferences and Manager Meetings described above and must abide by Bank policies and guidelines. Additionally, the Bank does not incentivize Representatives to recommend the products or services of a Third-Party Firm that makes contributions to charitable events or causes over those that do not. Personnel from Third-Party Firms will, from time to time, meet and work with financial professionals, including Representatives and Non-Field Employees, in one-on-one or in small group meetings, to provide information and support regarding their respective investment products. There are internal policies and procedures in place that limit Third-Party Firms from providing or paying for gifts and entertainment other than as permitted by and subject to the limits established under internal policies. In general, these financial professionals may accept nominal gifts and occasionally attend entertainment events, including business meals, subject to certain limits and conditions. Gifts or entertainment conditioned on achieving a sales target is not permitted. Permitting Third-Party Firm personnel access to Bank and Merrill financial professionals and providing gifts and entertainment presents a conflict of interest. It creates incentives for them to recommend investment products of those Third-Party Firms. Consistent with applicable laws, management and employees of BofA Corp. and its Affiliates are provided a broader level of access and exposure to Merrill, Representatives and other personnel through marketing events and distribution of marketing material and have greater access to client-related and other information. Such access and exposure is not available to other asset managers and enhances the ability of BofA Corp. Affiliates to distribute their investment products through the Bank, Merrill and MAA. In addition to monetary limits, the Bank and Merrill each have policies, procedures and supervisory controls that are reasonably designed to review the frequency and level of gifts and entertainment from affecting the nature of the advice provided. Third-Party Firms are not permitted to condition their gifts and entertainment on any amount of sales of their investment products and they are not required to take any such action. The policies, procedures and supervisory controls in place have been reasonably designed for regulatory requirements relating to such activities and the receipt of non-cash compensation from Third-Party Firms. Support Services Fees and Data Analytic Services Fees Received by Us from Certain Third-Party Firms Support Services and Fees paid to Merrill. As of January 1, 2027, it is anticipated that Merrill (and/or its MAA) will begin to receive fees (Support Fees) from certain Third-Party Firms that relate to the services provided to them. Support Fees are also commonly referred to as a type of “revenue sharing.” Support Fees will be paid to Merrill by certain Third-Party Firms that sponsor, manage, construct, advise or distribute investment products available in certain of our advisory programs or through brokerage relationships. These investment products include: (1) mutual funds; (2) ETFs that do not seek to track the performance of a specified market index (actively-managed ETFs); and (3) certain annuities. We will also receive Support Fees from Third-Party Firms or their Affiliates relating to assets invested in Strategies by Merrill’s clients and other separately managed account strategies made available in certain investment advisory programs. As a component of compensation Merrill receives for its efforts related to distribution of interests in alternative investment funds made available in certain other investment advisory programs and in brokerage, Merrill also currently receives revenue sharing payments as set forth in the relevant offering documents and subscription documents. Merrill will not receive Support Fees in connection with Accounts enrolled in the Program, including Program assets invested in Funds and Strategies. Support Fees will be paid to us by Third-Party Firms and their Affiliates out of their own resources. In the case of fund products, the Support Fees due to Merrill for the support services will not be paid directly from the funds’ assets. Merrill will retain all Support Fees, which will not be rebated or credited to client accounts. Due to applicable regulations, we will not charge or retain Support Fees for assets held in Retirement Accounts. 22 MAA-MerrillSPS-09-2026 Support Fee rates will be fully negotiable between the Third-Party Firm and us. Support Fee payments will not be a requirement for a product to be made available at Merrill. Nonetheless, whether a Third-Party Firm agrees to pay Support Fees and the amount of Support Fees the Third-Party Firm agrees to pay will be considered as a factor by Merrill in its decision to make products available to our clients. Because Support Fee rates are negotiated individually with Third-Party Firms, similarly situated products may generate different amounts of compensation to Merrill. The agreed-upon rates and the specific terms of our arrangements and payment amounts will vary among Third-Party Firms. Rates will also vary within the same product category of a single Third-Party Firm (e.g., the Support Fee rate for equity mutual funds may be higher than for fixed income mutual funds) and will sometimes vary for the same product made available in brokerage accounts. We will provide different support depending on the product type. The Support Fees we will receive in connection with products in its investment advisory programs could be based on purchases or the amount of client assets in a particular product as set forth below. A description of Support Fees by product and the fees that will apply to brokerage transactions and assets can be found in the Merrill Lynch Best Interest Disclosure Statement. In addition, a description of all products in its other investment advisory programs subject to Support Fees can be found in the Merrill Lynch Investment Advisory Program Brochure accessible at mymerrill.com/ADV/materials. The receipt of Support Fees will create conflicts of interest. Because we will receive Support Fees from some Third-Party Firms and not others, and because the amounts we receive will vary among Third-Party Firms and products, we will have a financial incentive to make available and recommend products from Third-Party Firms that pay us Support Fees, or that pay us more, over products from Third-Party Firms that do not pay us Support Fees or that pay us less. Whether a Third-Party Firm agrees to pay Support Fees, and the amount of Support Fees the Third-Party Firm agrees to pay, will be a factor in our decision to make products available to our clients. As a result, in certain circumstances, products that would otherwise meet our criteria for inclusion in the Program will not be made available if the applicable Third-Party Firm or its Affiliates do not agree to pay us a Support Fee, thereby limiting the available universe of products offered to its clients. Third-Party Firms that pay Support Fees may receive additional opportunities to engage with Merrill personnel, or otherwise maintain relationships with Merrill. As a result, Merrill personnel may be more familiar with products offered by those firms than comparable products offered by firms that do not pay Support Fees. Support Fees represent a source of additional revenue to Merrill that is separate from other compensation that we may receive in connection with client assets and transactions. In addition, the Support Fees received generally will exceed the value of the services we provide to Third-Party Firms and include a profit to Merrill. Because Support Fees are generally correlated with, and may increase, as a product’s management fee, expense ratio, or fee paid to a third-party manager for its separately managed account strategy increases, we have a financial incentive to make available, promote or recommend products with higher underlying fees over comparable lower- cost alternatives when doing so results in higher Support Fee payments to us. This incentive will sometimes result in clients being invested in products with higher costs, which will reduce net investment returns. Separately, a Third-Party Firm could seek to offset the Support Fees it pays us by maintaining or increasing the fees or costs associated with its products, which would indirectly increase a product’s costs or affect our opportunities to negotiate more favorable financial terms for client investments in the products of Third- Party Firms. We will address the conflicts of interest described in this section through disclosure of the nature of our Support Fee arrangements in this Brochure and through account and product disclosures and documentation provided to clients prior to or at the time of sale. The payment of Support Fees will not be a condition for a Third-Party Firm’s products to be made available at Merrill but will be a factor in the evaluation. While Support Fee payments will not be a requirement for a product to be made available at Merrill, Support Fee arrangements will be taken into account as part of the overall business evaluation process and can influence platform availability decisions. We select the products that are available and offered through the Program, other investment advisory programs we offer, and through a brokerage account primarily based on the CIO Review Process considering qualitative and quantitative evaluation of such factors as performance, risk management policies and procedures and consistency of the execution of their investment strategy. We determine the compensation paid to our financial advisors on the same basis for all Program assets without regard to the amount of Support Fees or other compensation we or our Affiliates will receive. Although our financial advisors do not receive any portion of, or credit for, the Support Fees paid to us, the conflicts associated with Merrill’s receipt of Support Fees remain. Our financial advisors are required to recommend investment securities and services that are suitable for, and in the best interest of, each client based upon the client’s investment objectives, preferences, risk tolerance, financial situation and needs and considering cost. We will adopt various policies and procedures reasonably designed to prevent the receipt of Support Fees and other business arrangements from affecting the nature of the advice we and our financial advisors provide. These measures help mitigate, but do not eliminate, the conflicts described above. Data Analytics and Fees paid to Merrill. As of January 1, 2027, Merrill will offer optional data analytics services (Data Analytics) to certain Third-Party Firms whose investment products and services are available on the Merrill platform. Our providing Data Analytics is intended to help Third-Party Firms streamline and tailor how they engage with our financial advisors. It includes information regarding mutual funds, money market funds, ETFs, alternative investment funds, separately managed account strategies, model portfolios, annuities, and insurance. Merrill reserves the right to include information regarding other products or services in the future. The information provided as part of the Data Analytics will not involve any account or client-specific information, including client personal data or individually identifiable client information. As it relates to the Program, Data Analytics does not include information about Representatives. 23 MAA-MerrillSPS-09-2026 Depending on the Data Analytics selected, Third-Party Firms will receive varying levels of information about individual financial advisors and their practices, such as investment product utilization, sales metrics and other analytical data. Fees for Data Analytics will range typically from $125,000 to $860,000 per year. Merrill will also offer additional Data Analytics related to passively-managed ETFs for fees that will range from $25,000 to $550,000 per year. In general, the more Data Analytics a Third-Party Firm selects, and the higher the fees it pays, the more extensive the information it will receive. Data Analytics are offered to all Third-Party Firms on Merrill’s platform and is not required for a Third-Party Firm’s products or services to be, or remain, available on the platform. The receipt of fees for Data Analytics from Third-Party Firms will create conflicts of interest. We will have a financial incentive to make available and recommend products from Third-Party Firms that pay fees for Data Analytics over those that do not. We will also have an incentive to favor Third-Party Firms that select Data Analytics with higher fees over those that select Data Analytics with lower fees. Third-Party Firms will obtain information that they may use to identify opportunities to market products and services, tailor sales and educational efforts, target particular financial advisor practices, and otherwise seek increased utilization of their products and services. This information could enable Third-Party Firms to engage more effectively with our financial advisors, which could lead our financial advisors to have greater familiarity with those firms’ products and services and could influence their recommendations. We will address these conflicts in a number of ways. Fees for Data Analytics are set according to a schedule that applies uniformly to all Third-Party Firms selecting the same offering and are not individually negotiated to favor or disadvantage any particular Third-Party Firm. Whether a Third-Party Firm pays us fees for Data Analytics does not impact our financial advisors’ compensation. It is also not a factor in determining whether a Third-Party Firm’s products or services are approved for availability in the Program, and it is not considered as part of the CIO Review Process. Offering of Investments or Programs Managed by Us or Our Affiliates MAA, Merrill and their Affiliates act in a variety of capacities to a wide range of clients. From time to time in the course of those duties, confidential information is acquired that cannot be divulged or acted upon for advisory or other clients. Similarly, MAA and Merrill may give advice or take action with regard to certain clients, including the Bank for the Program, which differs from that given or taken with regard to other clients. This includes the advice given or actions taken for certain securities, Funds or Strategies or Style Managers. In some instances, the actions taken by Affiliates for similar services and programs will conflict with the actions taken by MAA. This is due to, among other things, the differing nature of the Affiliate’s investment service and differing processes and criteria upon which actions are taken. MAA, Merrill and their Affiliates provide some or all of the same services offered in the Program through other financial firms, either with their Affiliates or with firms that are unaffiliated. Certain of these services have fee rates that differ from the Account Fees. Merrill or one of its Affiliates may have a position in or enter into “proprietary” transactions in securities purchased or sold for clients, including clients participating in the Program, and benefit from such securities positions or transactions. MAA and Merrill address these conflicts through disclosure in this Brochure. Moreover, the Representatives are required to recommend investment advisory programs, other investment programs, investment products and securities that are appropriate for each client based upon the client’s investment objectives, risk tolerance and financial situation and needs. In addition, MAA, Merrill and their Affiliates have established, as appropriate, a variety of restrictions, procedures and disclosures designed to address potential conflicts of interest – both those arising between and among Accounts as well as between Accounts and MAA’s and Merrill’s other business. For example, MAA and Merrill personnel are also subject to personal trading restrictions as detailed in their respective policies and procedures and Code of Ethics. These policies and procedures and the Code of Ethics require certain MAA personnel to pre-approve certain securities transactions, disclose their investment accounts, provide an annual holdings report, and provide a quarterly transaction report. Merrill and its Affiliates and related business divisions, offer their own managed products or wrap programs that are similar to this or other Bank programs. Advice and/or recommendations provided to accounts in these programs will be different from, or even conflict with, the advice and guidance provided in connection with the Program, including as to recommendations and review determinations. This is due to, among other things, the differing nature of Merrill’s and MAA’s investment advisory services and differing processes and criteria upon which determinations are made. In addition, other BofA Corp. Affiliates or divisions, including Merrill, offer their own managed products or wrap programs that are similar to the Program. In particular, the CIO also may provide advice and/or recommendations to these different Affiliates or divisions, including advice related to the recommendation of certain investment managers. Importantly, the advice and recommendations provided for the Program will be different from, or even conflict with, the advice and guidance provided to other Affiliates or programs. This is due to, among other things, the differing nature of the Affiliate’s investment advisory service and differing processes and criteria upon which determinations are made. For example, CIO may recommend a specific investment manager for inclusion in a Merrill program, but not the Program. In addition to providing advisory services to Program participants, Representatives also service other advisory and banking accounts for clients who do not participate in the Program, and offer and provide other services to clients who, in addition to participating in the Program, have other relationships or dealings with Merrill, MAA or their Affiliates. The Bank, MAA and their Affiliates also, from time to time, enter into specialized agreements to provide particular or unique services to certain clients, subject to negotiated fees. 24 MAA-MerrillSPS-09-2026 ITEM 12. BROKERAGE PRACTICES Transactions in Program Accounts All transactions in a Program Account, except as provided below, will be effected by or through Merrill or its Affiliates, acting as agent. In effecting transactions for a client’s Program Account, Merrill and its Affiliates will be acting exclusively as broker-dealer. If Merrill or its Affiliates effect the transaction through an Unaffiliated Trade Counterparty, we will take into account various factors, such as the nature and quantity of the securities involved, the markets involved, the reputation and perceived soundness of the firm, the firm’s clearance and settlement capabilities and other factors relevant to the selection of a broker-dealer for the execution of client securities transactions. The client should understand that the direction by the client and/or the Bank to use Merrill and its Affiliates to effect transactions in a Program Account may result in less advantageous execution, including greater spreads (the difference between the bid and the offer price) or less favorable net prices, than if an Unaffiliated Trade Counterparty were to execute the transaction. However, because clients generally are not paying for brokerage costs, any added expense typically will be absorbed by the Bank. The Bank pays an asset-based fee for these and other services provided by Merrill through the Program. In effecting transactions, Merrill or its Affiliates will be acting exclusively as a broker-dealer and trades will be handled by Merrill consistent with its best execution and other regulatory obligations. Even in meeting these obligations, it is possible that the client may be able to obtain better prices for transactions if such trades were executed with other broker-dealers or third parties, including having smaller spreads (the difference between the bid and the offer price) or at more favorable net prices. Merrill seeks to effect transactions correctly, promptly and in the best interests of clients. In the event an error occurs in its handling of client transactions, Merrill seeks to identify and correct any errors as promptly as possible without disadvantaging the client. In general, in instances where Merrill is responsible for effecting the transaction, Merrill may: (i) reimburse clients for any losses directly resulting from trade errors; (ii) credit to the client any profits directly resulting from such trade errors that are corrected after the settlement of the transaction; or (iii) retain any profits directly resulting from such trade errors that are corrected prior to the settlement of the transaction. In certain instances, Merrill’s corrective measure involves purchasing the securities from your Account at a price determined at the time of the correction that will determine the amount to reimburse clients for any resulting losses or to credit clients for resulting profits. If Merrill is subsequently unable to sell the securities from its error account until a later point in time due to regulatory restrictions or otherwise, Merrill will retain any profits if those securities are eventually sold at a higher price than the amount paid to correct the error. As discussed in the section “Agency-Cross and Other Cross Transactions”, there may be instances in which Merrill or its Affiliate (or a Discretionary Manager or its Affiliate, if applicable) will have the opportunity to engage in cross or agency-cross transactions, subject to applicable law. Merrill or its Affiliate or a Discretionary Manager or its affiliate, if applicable, would engage in such transactions only when the transaction is in the best interest of each party. MAA may, but is not required to, aggregate orders for the sale or purchase of securities for a client’s Account with orders for the same security for its other clients, proprietary accounts or the accounts of its employees and/or related persons, without a client’s prior authorization. In such cases, each account in the aggregated transaction will be charged or credited with the average price and, when applicable, its pro rata share of any fees. If a discretionary Strategy is selected, the Discretionary Manager has the authority to place orders for transactions with broker-dealers that it selects, including Unaffiliated Trade Counterparties, when consistent with their obligation to seek best price and execution. For certain Discretionary Managers, MAA provides administrative services to assist with the placement of orders at its direction. A Discretionary Manager may, but is not required to, aggregate orders for the sale or purchase of securities for the Strategy with orders of the same security for other clients in the same Strategy (either at Merrill or at other firms), for its own accounts or for the accounts of its employees and/or related persons. Certain Discretionary Managers that place orders for particular (but not all) transactions for their Strategies with Merrill and its Affiliates or with an Unaffiliated Trade Counterparty if the Discretionary Manager determines, after consultation with MAA, that: (1) they are able to aggregate a particular trade for Program clients in a block trade and (2) they expect such aggregation will be for the overall benefit of Program clients. A transaction that the Discretionary Manager has placed through an Unaffiliated Trade Counterparty for a particular Strategy is commonly referred to as a “step out” or “step out trade.” For certain Style Managers that are Discretionary Managers, we may provide administrative support to the Discretionary Managers to assist with the placement of orders at their direction. In selecting a firm to execute transactions and the markets in which the transactions will be executed, the Discretionary Manager is not obligated to solicit competitive bids for each transaction or seek the lowest available commission cost so long as it reasonably believes that the firm it selects can be expected to obtain a “best execution” market price on the particular step out trade. Each Discretionary Manager is responsible for ensuring that it complies with its own best execution obligations. Certain Discretionary Managers have historically executed all or a portion of their trades as “step outs.” Frequently, these trades have been for fixed income or other securities for which a markup or markdown is charged by the executing broker-dealer (generally referred to as “dealer spread”). The client will bear the cost of this dealer spread amount and the Account Fee does not cover this expense or cost. The Discretionary Manager may also execute step out transactions for certain equities and other securities for which the executing broker-dealer charges a brokerage commission. These trades have historically been for foreign securities for which a 25 MAA-MerrillSPS-09-2026 brokerage commission had been charged by the executing Unaffiliated Trade Counterparty. Under the Program, other than as noted below as to Foreign Ordinary Shares and American Depositary Receipts (“ADRs”), the client will not have to pay this Unaffiliated Trade Counterparty brokerage commission. The Style Manager Expense rates vary among Style Managers and it is possible that the Style Manager Expense rate for a Discretionary Manager is higher than that for other Style Managers with the same or similar Strategies. The client could be deemed to be indirectly bearing the cost of the step out trades by virtue of any such higher Style Manager Expense rate. Because the client will pay the same Style Manager Expense rate regardless of whether or not a Discretionary Manager has a step out trade, this creates a material conflict of interest, or the appearance of a material conflict of interest, between the Discretionary Manager and the client. The Discretionary Managers identified as trading through Unaffiliated Trade Counterparties, either on a regular or a limited basis, are listed in the document entitled “Style Manager Step Out Information Document” available at ml.com/SMA. Clients may also request a copy from their Representative. Information in this document is based solely on the historical information that has been provided by the Discretionary Managers and MAA makes no representation regarding the future trading practices of any Discretionary Manager for any Strategy. When Merrill through its Affiliate executes transactions in foreign ordinary securities outside the United States, it may use the services of foreign Unaffiliated Trade Counterparties. These foreign Unaffiliated Trade Counterparties may handle the client’s order as agent and assess a commission charge, or they may transact as principal and receive a dealer spread or mark-up/down. Additionally, to the extent a foreign currency conversion transaction is required to facilitate trade settlement, the foreign Unaffiliated Trade Counterparty (or its affiliate) effecting the currency conversion will be remunerated in the form of a dealer spread or mark-up/down. Although the remuneration is not disclosed in net price transactions, Merrill will undertake, at a client’s written request, to determine or ascertain from the counterparty this remuneration in a given transaction for the client’s Account. Foreign Unaffiliated Trade Counterparties also may charge commissions and/or dealer spreads when foreign issuers terminate an ADR facility, thereby necessitating conversion of ADRs to foreign ordinary share form. In such circumstances, the prices obtained for the post-ADR security may be lower than if the ADR remained intact. These commission charges and/or dealer spreads are in addition to the Account Fee. Additional information about execution expenses can be found in the Bank’s SPS Disclosure Statement. ITEM 13. REVIEW OF ACCOUNTS Program Account Reviews An important part of the Program relationship involves providing clients with the opportunity to engage in Account reviews periodically in which the client’s Representative reviews the client’s Account’s progress toward goals. Because these reviews provide the client with important and necessary information relating to the client’s Account, the client is strongly encouraged to take advantage of these opportunities to participate in these Account reviews with the client’s Representative. At least annually, the Bank will contact clients to request updated information and determine whether there have been any changes in a client’s financial situation and investment objectives, and whether the client wishes to impose any reasonable restrictions, or reasonably modify existing restrictions, on the management of the Account or reasonably modify existing restrictions. Additionally, on a quarterly basis, the Bank will notify clients in writing to contact the Bank if there have been any material changes in a client’s financial circumstances that might affect the manner in which the client’s assets should be invested. Clients should promptly inform the Bank in writing of any change in their financial circumstances that might affect the manner in which their assets should be invested. Any such information received that is deemed material or appropriate will be promptly forwarded by the Bank to MAA and, if applicable, any Discretionary Manager that may manage a portion of the client’s Account. If the changes provided are material in nature, a review of the client’s Account may be in order. Representatives will be reasonably available to clients for consultation. In addition, MAA and each Discretionary Manager have agreed to make one or more of their advisory or investment personnel reasonably available for consultation with clients or a joint consultation with their Representative regarding a Strategy, if requested by the client. Clients should contact their Representatives to arrange for a consultation with a Discretionary Manager or MAA. Client Reports Under the Program, clients will receive statements from the Bank of Account activity and current holdings on a quarterly or monthly basis, depending on client preference. Clients also may request periodic performance reviews with their Representatives, depending on a client’s relationship with the Bank. This review generally includes a presentation of the client’s Account performance, based on information reflected on the Bank’s and/or MAA’s records, supplemented by information that may be provided by the client, the Bank, Merrill, and/or Style Managers, and ongoing comparisons of Account performance with selected industry indices and/ or benchmarks. Account statements will be the definitive record of all activity in an Account. In the event of any discrepancy between the account statements and any performance reports received, the client account statements will control and prevail. MAA and its Affiliates may receive (and provide to clients) information about the performance of Style Managers and/or Strategies available through the Program that is not specific to the performance of any client Account. Performance results of the Style Managers are generally reported to MAA by third-party vendors or the Style Managers, on a standardized basis. While information collected by 26 MAA-MerrillSPS-09-2026 MAA and its Affiliates regarding Style Managers and/or Strategies is believed to be reliable and accurate, MAA, the Bank and their Affiliates will not necessarily independently review or verify any such information, or be obligated to do so, nor will MAA, the Bank and their Affiliates audit or verify that these results are calculated on a uniform or consistent basis. Clients should understand that: • Past performance does not guarantee future results. • Performance may reflect (primarily or solely) management of accounts outside of the Program and the performance of Accounts may vary from “composite” performance due to factors such as Account size, timing of investments, client investment objectives and reasonable restrictions, the Program’s brokerage practices, as described above, and MAA’s management of a client’s Accounts. • Client risk parameters or benchmark indices are provided for comparison purposes only and there is no guarantee that they will be met or exceeded. Trade Confirmations Clients may elect to receive periodic statements (at least quarterly) detailing their Account activity instead of trade-by-trade confirmations. Periodic statements will contain the same information that would be included in the trade-by-trade confirmations. The client’s initial direction regarding receipt of trade-by-trade confirmations will apply to all of the client’s Accounts, including any changes to and additional Style Managers selected by the client, until such direction is changed. The client’s election to receive periodic statements in lieu of trade-by-trade confirmations will not affect the calculation of or amount of the client’s Account Fee; is not a condition to entering into or continuing participation in the Program; and may be rescinded by the client at any time by written notice to the Bank for any of the client’s Accounts. The client may request that its Representative provide to the client, at no additional cost, an interim update and further details concerning any transaction effected between periodic statements. Clients also will have access to this information via online access at privatebank.bankofamerica.com/login. If the client elects to receive periodic statements in lieu of trade-by-trade confirmations, the client may later choose to receive, and the Bank or its Affiliates will provide to the client at no additional cost, any confirmations for transactions effected for up to a one-year period preceding the client’s last periodic statement and trade-by-trade confirmations for all subsequent transactions. Confirmations or periodic statements will be sent or made available to the client, MAA, or any Discretionary Manager, as applicable and in accordance with applicable law. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION MAA, Merrill and their Affiliates have business relationships with many investment managers, including those participating in the Program, separate and apart from the Program. For example, Style Managers may direct clients’ transactions to Merrill and receive research, execution, custodial, pricing and other services offered by Merrill in the normal course of business. Merrill, the Bank and its Representatives may receive compensation in connection with such transactions and other services. Clients are encouraged to speak with their Representatives to discuss any questions that they may have about existing or potential conflicts of interest relating to their selected Strategies, including any business relationships that the relevant Funds or Style Managers have with MAA, BofA Corp., Merrill or their Affiliates or Representatives. As discussed previously in the section “Relationships With Asset Managers, Sponsors and Style Managers,” Style Managers pay, or reimburse MAA or its Affiliates for, various costs relating to the Program and asset management generally. These conflicts are addressed through disclosure to clients in this Brochure and the Bank’s SPS Disclosure Statement. ITEM 15. CUSTODY Neither MAA nor Merrill maintains physical custody of client assets. Generally, the Bank or another Affiliate will maintain physical custody of securities for Program Accounts. Clients should receive periodic statements from the Bank or its Affiliates or, to the extent client assets are not custodied with the Bank or an Affiliate, other broker-dealer, bank or financial services firm that serves as qualified custodian. Clients should carefully review these statements. Clients who do not receive such account statements are encouraged to follow-up directly with their custodian and request such statements. To the extent a client receives additional reports from MAA or Merrill, they are urged to compare these reports to the account statements they receive from the qualified custodian. MAA’s and Merrill’s reports are generally preliminary and may vary from custodial statements based on accounting procedures, reporting dates, valuation methodologies and other factors. They are not intended to be a substitute for account statements provided by a qualified custodian and should not be used for official purposes. ITEM 16. INVESTMENT DISCRETION MAA generally has discretionary investment authority to implement one or more Strategies in a client’s Program Account based on the recommendations of the Strategies’ Style Managers. Generally, clients or their authorized representatives who choose to grant MAA discretion sign a Client Agreement with the Bank to that effect. MAA has entered into investment manager advisory agreements with a variety of Style Managers, which may or may not be Related Entities. A list of the Style Managers available through the Program appears in the Style Manager Expense Rate Supplement to the Bank’s SPS Disclosure Statement. In general, Style Managers provide advisory services through the Program by furnishing investment recommendations to MAA for one or more Strategies based on model portfolios in accordance with the applicable Strategy Profiles. 27 MAA-MerrillSPS-09-2026 MAA is responsible for implementing each Strategy based on the advice provided by a Style Manager, except when the Style Manager acts as a Discretionary Manager. MAA generally will implement a Style Manager’s recommendations for a Strategy without change, subject to any reasonable client-imposed restrictions, cash flow and other considerations. Certain of the Style Managers are Discretionary Managers that provide discretionary investment advisory services to clients that have selected the relevant portfolio. A Discretionary Manager makes and implements investment decisions for a client’s Program Account in accordance with the Discretionary Manager’s Strategy Profile. MAA does not implement investment decisions for any portion of a client’s assets that is managed by a Discretionary Manager. However, MAA is responsible for enforcing any client- imposed reasonable restrictions for a client’s Program Account. MAA’s discretionary authority may be limited by the terms of the Client Agreement, Reasonable Investment Restrictions imposed by a client, Bank instructions, and MAA’s obligation to comply with regulatory requirements. As discussed above, MAA’s authority also may be limited where a client’s Program Account is invested with a Discretionary Manager. MAA will communicate to the Bank its response to corporate actions, including reorganizations, with respect to securities held in the client’s Program Account. MAA will not advise clients or act on clients’ behalf regarding any legal matters, including bankruptcies and class action lawsuits. The Bank will advise or act for clients in the event of a class action involving securities held in the client’s Program Account. ITEM 17. VOTING CLIENT SECURITIES The Bank or clients may not delegate to MAA or Merrill, and neither MAA nor Merrill accept or assume from the Bank or clients, proxy voting authority for any securities in a Program Account. Pursuant to separate arrangements between the client and the Bank, unless the client has notified the Bank otherwise, the client authorizes the delegation, on its behalf, of proxy voting authority for securities in an Account to the Bank and a proxy voting service selected by and subject to oversight by the Bank. Additional information regarding the Bank’s proxy voting arrangement for the Program, the proxy voting service and/or the Bank’s proxy voting policies can be obtained by contacting the client’s Representative. ITEM 18. FINANCIAL INFORMATION Not applicable because (1) MAA and Merrill do not require or solicit the prepayment of more than $1,200 per client six or more months in advance; (2) there is no financial condition of which Merrill or MAA is aware that is reasonably likely to impair their ability to meet contractual commitments to clients; and (3) MAA and Merrill have not been the subject of a bankruptcy petition at any time during the past 10 years. ADDITIONAL INFORMATION Covered Entities under the Volcker Rule Certain entity clients that qualify as “family wealth management vehicles (“FWMV clients”) and certain entity clients that qualify as “customer facilitation vehicles” (“CFV clients”) may receive investment advisory services under this Program or other investment advisory programs where MAA and/or Merrill act as an investment adviser as well as lending services and engage, where permitted, in principal transactions. In doing so, they rely on the exception under the Volcker Rule implementing regulations that is available for FWMV clients and have provided FWMV clients with key disclosures that relate to qualifying for this exception in the Client Agreement. For certain entity clients that are deemed “covered fund” clients under the Volcker Rule, it is not permitted to offer both investment advisory services and the availability of margin, lending or other extensions of credit from the Bank, MAA, Merrill and any of their Affiliates or engage in certain principal transactions. Certain other transactions between the Bank or its Affiliates and the entity client will also be prohibited. GLOSSARY “Account Fee” means the IM&T Fee and the Style Manager Expense. “ADR” means American Depositary Receipt, which is a receipt for shares of a foreign company held by a U.S. financial institution that entitles the holder to rights and obligations of the underlying shares, including dividends and capital gains and losses. “Advisers Act” means the Investment Advisers Act of 1940, as amended. “Affiliate” means a company that is controlled by, in control of or under common control with another company. “Bank of America Workplace Benefits” means the group providing specialized retirement account services, which operates through the Bank and other subsidiaries of BofA Corp. “Bank of America Private Bank” means the fiduciary business of Bank of America, N.A., which operates through the Bank and other subsidiaries of BofA Corp. “BofA Corp.” means Bank of America Corporation, the parent company of the Bank, MLPF&S, MAA and other Affiliates. “BofA Global Research” means the business unit of BofAS and/or one or more of its Affiliates that produces research material for clients. “BofAS” means BofA Securities, Inc., an Affiliate of MAA. “Brochure” means this Form ADV, Part 2A (including any amendments or supplements) of Merrill and MAA relating to the advisory services they provide in connection with the Program, as updated from time to time. “CIO” means the Chief Investment Office, a business division consisting of Bank and Merrill employed personnel, which acts as a Related Entity for certain Related Strategies and which engages in the CIO Review Process for the review of Funds and investment strategies. 28 MAA-MerrillSPS-09-2026 “Code of Ethics” means Merrill’s and MAA’s Investment Adviser Code of Ethics. “Dealer spread costs” means mark-ups, mark-downs and/or dealer spread charges imposed by an Unaffiliated Trade Counterparty or a trade counterparty that is an Affiliate. “Discretionary Manager” means a Style Manager that has full discretion to effect transactions for an Account with Merrill and its Affiliates or an Unaffiliated Trade Counterparty and to determine which securities to buy, sell or hold in its Strategy. “ERISA” means the Employee Retirement Income Security Act of 1974, as amended. “ERISA Plan” means a plan subject to the fiduciary responsibility provisions of ERISA or any other entity deemed to hold assets of such a plan. “ETF” means a Registered Fund that is an exchange-traded fund. “Exchange Act” means the Securities Exchange Act of 1934, as amended. “Funds” means a registered and unregistered investment company, including a mutual fund, a money market fund, a closed-end fund, an ETF, an NTF, and any other pooled investment vehicle. “MAA” means Managed Account Advisors LLC. “Manager-Related Fund” means a Fund sponsored or advised by a Style Manager (including a Related Entity) or its Affiliates. “Merrill” or “MLPF&S” means Merrill Lynch, Pierce, Fenner & Smith Incorporated. “NTFs“ means mutual funds and ETFs registered with the SEC that are classified by us as Alternative Investments. “Program” means Select Portfolio Solutions, an investment service offered by the Bank. “Program Account” or “Account” means an account for investment of assets of the client through the Program. “Registered Fund” means any Fund that is registered under the Investment Company Act of 1940. “Related Entity” means an Affiliate of BofA Corp. or an entity in which BofA Corp. or an Affiliate has a material ownership interest. Related Entities include the Bank, MAA and Merrill. “Related Fund” means any Fund sponsored, managed, or advised by the Bank or a Related Entity. “Related Strategy” means any investment strategy sponsored, managed or constructed by the Bank, MAA, Merrill or a Related Entity. “Representative” means the client’s representative from Bank of America Private Bank or Bank of America Workplace Benefits. “Retirement Account” means an ERISA Plan, a U.S. tax-qualified plan of self-employed persons, a U.S. individual retirement account, or any other plan, arrangement or entity subject to Section 4975 of the U.S. Internal Revenue Code of 1986, as amended. “Rule 12b-1 fees” means fees paid for distribution of mutual funds pursuant to a plan made under Rule 12b-1 under the Investment Company Act of 1940. “SEC” means the Securities and Exchange Commission. “Securities Act” means the Securities Act of 1933, as amended. “SPS Disclosure Statement” means the disclosure statement of the Bank, including any supplements and as updated from time to time, for the Program. “SIPC” means Securities Investor Protection Corporation. “Strategy” means one or more investment styles or disciplines that may be selected for a client’s account, either individually or in combination with other Strategies, and that may include specific asset classes or asset types such as mutual funds, ETFs or other Funds, in each case as determined by the Bank or MAA from time to time. “Strategy Profile” means a written document that contains a description of a Strategy offered in the Program and may contain other information relating to the Strategy or Style Manager. “Style Manager” means an investment manager that constructs and/or manages its respective managed strategy portfolios in a Strategy which can be a third-party investment manager and the Bank, MAA, Merrill or another Related Entity. “Style Manager Expense” means the portion of the client’s Account Fee for the Style Manager’s services that is based on Program Assets allocated to the Style Manager’s Strategy. The Style Manager Expense rate varies depending on the Style Manager. “Third-Party Firms” means third-party investment managers, fund managers (including for alternative investments), product distributors and sponsors, insurance companies and other product providers. “Unaffiliated Trade Counterparty” means a bank, broker or dealer other than Merrill or a Merrill Affiliate. “Unrelated Money Market Fund” means a registered money market fund that is not managed by Merrill or a Related Entity. Unless otherwise noted, registered service marks and service marks are the property of Bank of America Corporation. © 2026 Merrill Lynch, Pierce, Fenner & Smith Incorporated Printed in the U.S.A. 29 MAA-MerrillSPS-09-2026