CAPITAL BANK AND TRUST COMPANY

CAPITAL BANK AND TRUST COMPANY 6455 Irvine Center Drive Irvine, California 92618 Phone: (949) 975-5000 capitalgroup.com Form ADV, Part 2A Date: September 26, 2025 This brochure provides information about the qualification and business practices of Capital Bank and Trust Company (“CB&T”). Throughout this brochure and related materials, CB&T refers to itself as a “registered investment adviser” or “being registered”. You should be aware that registration with the United States Securities and Exchange Commission (“SEC”) or a state securities authority does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at ADVPart2@capgroup.com. The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about CB&T also is available on the SEC’s website at www.adviserinfo.sec.gov.  ITEM 2: MATERIAL CHANGES There have been no material changes since the last update of CB&T’s Form ADV, Part 2A brochure dated July 1, 2025. 2  ITEM 3: TABLE OF CONTENTS Item Page 1 Cover Page……………………………………………………………..…..………..…...1 2 Material Changes…………………………………………………………..………..……2 3 Table of Contents………………………………………………………..…………..…....3 4 Advisory Business………………………………………………………..………..……..4 5 Fees and Compensation…………………………………………………………...….…..5 6 Performance-Based Fees and Side-by-Side Management…………………….…..….......6 7 Types of Clients……………………………………………………………….……....….7 8 Methods of Analysis, Investment Strategies and Risk of Loss…………………...….......8 9 Disciplinary Information……………………………………………………..……....….28 10 Other Financial Industry Activities and Affiliations…………………………..………...29 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading…32 12 Brokerage Practices……………………………………………………………………...34 13 Review of Accounts……………………………………………………………………..42 14 Client Referrals and Other Compensation…………………………………………….…43 15 Custody………………………………………………………………………………….44 16 Investment Discretion…………………………………………………………………...45 17 Voting Client Securities……. …………………………………………………………..46 18 Financial Information…………………………………………………………………...50 19 Requirements for State-Registered Advisers………………………………....…………51 3  ITEM 4: ADVISORY BUSINESS CB&T is a wholly-owned subsidiary of The Capital Group Companies, Inc. The Capital Group Companies form one of the most experienced families of investment management firms in the world, dating to 1931, and have always been privately held. CB&T was formed in July 2000 as a federal savings bank. CB&T’s primary businesses include: (i) providing directed trustee services and custodial services to employer-sponsored retirement plans and individual retirement accounts invested in registered investment companies (“Directed Trustee Services”); and (ii) providing investment management and related services to institutional clients (the “Institutional Client Services”). In this regard, CB&T offers both collective investment trusts and common trust funds (collectively, “Commingled Funds”), designed for retirement plans, foundations, endowments and other entities for which CB&T acts as investment manager and/or discretionary trustee and oversees their formation and maintenance. CB&T engages other service providers, including affiliates, to assist in administration and investment management of the Commingled Funds. It has retained Capital International, Inc. (“CIInc”) and Capital Research and Management Company (“CRMC” and, together with CIInc, the “Advisers”) to serve as investment advisers of the Commingled Funds. CB&T’s investment approach is based on rigorous fundamental research. CB&T’s offerings of equity, fixed-income, balanced, and other customized investment strategies are informed by the investment objectives and guidelines (including any specific investment restrictions and limitations) of its clients. The client’s guidelines typically describe the investment mandate and types of securities that are eligible for (or prohibited from) the account. For discretionary trustee services provided to Commingled Funds, the terms of the fund’s governing documents will apply. Please also refer to Items 8 (Methods of Analysis, Investment Strategies and Risk of Loss) and 16 (Investment Discretion) in this brochure for further information. As described above, CB&T’s only business is investment management and related services; it does not provide retail banking services nor does it engage in the brokerage or corporate finance businesses. As of June 30, 2025, CB&T managed approximately $139,294,600,000 in client assets (regulatory assets under management) on a discretionary basis. 4  ITEM 5: FEES AND COMPENSATION WITH RESPECT TO COMMINGLED FUNDS: The fees and expenses for each Commingled Fund, including fees paid to CB&T and its affiliates, as well as any brokerage and transaction costs, are described in each fund’s governing documents as well as each client’s agreement with CB&T or its affiliates. WITH RESPECT TO SALES AND MARKETING PROFESSIONALS: Sales and marketing professionals employed by CB&T or an affiliate may receive direct or indirect compensation related to the services CB&T provides. This presents a conflict of interest, as marketing and sales associates have an incentive to recommend services based upon the compensation they are provided by CB&T. 5  ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT CB&T charges asset-based fees for providing investment advisory services. However, in limited circumstances, certain of CB&T’s affiliates receive fees that are based on the performance of the account. Managing both types of accounts simultaneously creates a risk of conflicts for the portfolio manager to (i) allocate more attractive investment opportunities to accounts with performance-based fees and/or (ii) make investments for those accounts that are more speculative than for accounts that do not have performance-based fees. To mitigate these risks, CB&T and its affiliates have adopted allocation policies that are designed in part to address these potential conflicts of interest. See Item 12 (Brokerage Practices) of this Brochure for CB&T’s policy on allocating trades fairly, which is designed to allocate trades to clients in a fair and equitable manner over time, taking into consideration the interests of each client. Non-investment factors, such as fee arrangements, are not considered when allocating trades among clients. In addition, while CB&T and its affiliates provide individual investment advice and treatment to each fund and account, portfolio managers focus on particular investment mandates, using similar investment strategies in connection with the management of multiple portfolios, which helps minimize the potential for conflicts of interest. CB&T reviews accounts with similar objectives managed by CB&T and its affiliate at least annually. These reviews generally include, among other things, information related to investment results, including dispersion of results among accounts and reasons for such dispersion, if any, significant account guidelines and the investment structure of the portfolio. 6  ITEM 7: TYPES OF CLIENTS CB&T provides directed trustee services and custodial services to employer-sponsored retirement plans and individual retirement accounts invested in registered investment companies, but does not offer discretionary investment advisory services to these clients. With respect to Commingled Funds: CB&T serves as a discretionary trustee and/or investment manager for Commingled Funds generally designed for retirement plans, foundations and endowments. Investors in these funds generally sign an agreement with CB&T to serve as fiduciary. While there is no stated minimum account size, participants in the Commingled Funds who are not clients of Capital Group Private Client Services, Inc. (“CGPCS”), an affiliated investment adviser registered with the SEC, are subject to minimum account sizes to invest in the funds, as outlined in the respective Advisers’ Form ADV and the fund’s governing documents. 7  ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS METHODS OF ANALYSIS CB&T and the Advisers maintain an investment philosophy that is distinguished by four key beliefs and practices:  Fundamental research underlies all investment decisions: CB&T and the Advisers employ teams of experienced analysts who regularly gather in-depth, first-hand information on markets and companies around the globe.  Investment decisions are not made lightly: In addition to providing extensive research, investment professionals go to great lengths to determine the difference between the fundamental value of a company/security and its price in the marketplace.  A long-term approach: It’s part of the big-picture view investment professionals take of the companies in which they invest. This is reflected by the typically low turnover of portfolio holdings in the funds and accounts CB&T and the Advisers manage. In addition, investment professionals usually remain with us for many years and are compensated according to their investment results over time.  The Capital System: CB&T and the Advisers use a system of multiple portfolio managers in managing most separate account and fund assets. Under this approach, the portfolio of an account or fund is divided into segments managed by individual managers who decide how their respective segments will be invested. In addition, investment research analysts may make investment decisions with respect to a portion of the portfolio. Over time, this method has contributed to consistency of results and continuity of management.  The Advisers may consider environmental, social and governance (“ESG”) factors that, depending on the facts and circumstances, are material to the value of an issuer or instrument. ESG factors may include, but are not limited to, environmental-related events resulting from climate change or society’s response to environmental change, social conditions (e.g., labor relations, investment in human capital, accident prevention, changing customer behavior) or governance issues (e.g., board composition, significant breaches of international agreements, unsound business practices). Investment decisions are consistent with a portfolio’s objective(s), investment guidelines, restrictions, and are subject to oversight of the appropriate investment-related committees. The objective(s), policies and restrictions of any fund are set forth in the governing documents of the fund. INVESTMENT STRATEGIES The following are descriptions of the investment strategies offered by CB&T: 8  Equity strategies U.S. Core Equity– Seeks to provide long-term growth of capital. The fund will invest primarily in equity and equity-related securities of issuers in the U.S. The fund will focus on investments in high quality companies determined by the strength of their balance sheets, returns on capital or dividend sustainability, among other measures. The fund will also focus on investments in larger capitalization companies; however, investments are not limited to a particular capitalization size. International Equity — The fund seeks long-term growth of capital. The fund invests primarily in equity and equity-related securities: (1) of issuers from non-U.S. countries; or (2) that are primarily traded outside the U.S. The fund will focus on investments in larger capitalization companies; however, investments are not limited to a particular capitalization size. While the assets of the fund may be invested with geographical flexibility, the emphasis will be in securities of developed country issuers. Although the fund intends to concentrate its investments in such securities, the fund may invest in cash, cash equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates or managed by a third party) and government securities under certain economic conditions. The fund may also invest up to 10% of its assets in the securities of developing country issuers. Global Equity — The fund seeks to provide long-term growth of capital and income. The fund invests primarily in equity and equity-related securities of U.S. and non-U.S. issuers. The Fund will focus on investments in larger capitalization companies; however, investments are not limited to a particular capitalization size. While the assets of the Fund may be invested with geographical flexibility, the emphasis will be in securities of developed country issuers. Although the Fund intends to concentrate its investments in such securities, the Fund may invest in cash, cash equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates or managed by a third party) and government securities under certain economic conditions. The Fund may also invest up to 10% of its assets in the securities of developing country issuers. International All Countries Equity — The fund seeks to provide long-term growth of capital. The fund invests primarily in equity and equity-related securities: (1) of issuers from all countries, excluding the U.S.; or (2) that are primarily traded outside the U.S. The fund may invest with geographical flexibility across developed and developing countries (subject to a limit of 50% of its assets in the securities of developing country issuers). Although the fund intends to concentrate its investments in such securities, the fund may invest in cash, cash equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates or managed by a third party) and government securities under certain economic conditions. Emerging Markets Equity – The investment objective of the strategy is to provide long-term capital growth. Under normal market conditions, the fund will invest at least 90% of its net assets in equity and equity-related securities of developing country issuers. Securities of developing country issuers are defined as those from issuers in developing countries. In determining whether a country is a developing country, the fund considers, among other things, whether the country is generally considered to be a developing country by the international financial community. The fund may invest in cash and cash equivalents (including shares of money market or similar funds 9  managed by the investment adviser or its affiliates or managed by a third party). The fund may invest up to 10% of its net assets in the securities of issuers that are not in developing countries that are expected to have economic exposure to developing countries (through assets, revenues or profits) of at least 75%. The fund may also invest up to: (1) 25% of its assets in a single industry; and (2) 5% of its assets in a single issuer and 10% of the voting securities of a single issuer. Emerging Markets Restricted Equity – The fund seeks to provide long-term capital growth. The fund will invest at least 90% of its net assets in equity and equity-related securities of developing country issuers. Securities of developing country issuers are defined as those from issuers in developing countries. In determining whether a country is a developing country, the fund considers, among other things, whether the country is generally considered to be a developing country by the international financial community. The fund may invest in cash and cash equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates or managed by a third party). The fund may invest up to 10% of its net assets in the securities of issuers that are not in developing countries that are expected to have economic exposure to developing countries (through assets, revenues or profits) of at least 75%. The fund may also invest up to: (1) 25% of its assets in a single industry; and (2) 5% of its assets in a single issuer and 10% of the voting securities of a single issuer. The fund may not invest in securities of issuers that generate 10% or more of their revenues from the following products and/or services: (a) Alcohol, (b) Tobacco or recreational cannabis, (c) Gambling, (d) Adult entertainment, including pornography, (e) Weapons, including civilian firearms, (f) Military defense and weapons, or (g) for profit prison operators. These limits will be monitored using a third -party market research vendor on environmental, social and governance issues. An exception to the 10% threshold will apply to restaurants and other food retailers of alcoholic beverages and firearms retailers. For such businesses, a 25% revenue threshold will apply. Capital Group AMCAP – The fund seeks to provide long-term growth of capital. Invests primarily in common stocks of U.S. companies that have solid long-term growth records and the potential for good future growth. The fund may invest in common stocks and other securities outside the United States to a limited extent. Capital Group American Mutual - The fund strives for the balanced accomplishment of three objectives: current income, growth of capital and conservation of principal. The fund seeks to invest primarily in common stocks of companies that are likely to participate in the growth of the American economy and whose dividends appear to be sustainable. The fund invests primarily in the United States and Canada. Capital Group EUPAC - The fund’s investment objective is to provide long-term growth of capital. The fund invests primarily in common stocks of issuers in Europe and the Pacific Basin that are believed to have the potential for growth. The fund may invest a portion of its assets in common stocks and other securities of companies in emerging markets. Capital Group Fundamental Investors - The fund’s investment objective is to achieve long-term growth of capital and income. The fund seeks to invest primarily in common stocks of companies that appear to offer superior opportunities for capital growth and most of which have 10  a history of paying dividends. In addition, the fund may invest significantly outside the United States. Capital Group Growth Fund of America - The fund’s investment objective is to provide growth of capital. The fund invests primarily in common stocks and seeks to invest in companies that appear to offer superior opportunities for growth of capital. The fund invests primarily in common stocks of large and mid-capitalization issuers. The fund may invest outside the United States. Capital Group Investment Company of America - The fund’s investment objectives are to achieve long-term growth of capital and income. The fund invests primarily in common stocks, most of which have a history of paying dividends. The fund may invest to a limited extent outside the United States. Capital Group International Growth and Income - The fund’s investment objective is to provide long-term growth of capital while providing current income. The fund invests primarily in stocks of larger, well-established companies domiciled outside the United States, including in emerging markets and developing countries that the investment adviser believes have the potential for growth and/or to pay dividends. These investments will be primarily in issuers whose securities are listed primarily on exchanges outside the United States and in cash and cash equivalents and securities held as collateral issued by U.S. issuers. Capital Group New Economy - The fund’s primary investment objective is to provide long-term growth of capital. Current income is a secondary consideration. The fund seeks to achieve its objectives by investing in securities of companies that can benefit from innovation, exploit new technologies or provide products and services that meet the demands of an evolving global economy. The fund may invest a significant portion of its assets in issuers based outside the United States, including those based in developing countries. Capital Group World Growth and Income - The fund’s investment objective is to provide long- term growth of capital while providing current income. The fund invests primarily in common stocks of well-established companies located around the world, many of which have the potential to pay dividends. The fund invests, on a global basis, in common stocks that are denominated in U.S. dollars or other currencies. Under normal market circumstances the fund will invest a significant portion of its assets outside the United States, including in developing countries. Capital Group Washington Mutual Investors - The fund’s investment objective is to produce income and to provide an opportunity for growth of principal consistent with sound common stock investing. The fund invests primarily in common stocks of established companies that are listed on, or meet the financial listing requirements of, the New York Stock Exchange and have a strong record of earnings and dividends. The fund strives to accomplish its objective through fundamental research, careful selection and broad diversification. In the selection of common stocks and other securities for investment, current and potential yield as well as the potential for long-term capital appreciation are considered. The fund seeks an above-average yield in relation to the S&P 500 Index (a broad, unmanaged index). The fund strives to maintain a fully invested, diversified portfolio, consisting primarily of high-quality common stocks. 11  Capital Group New Perspective - The fund’s investment objective is to provide long-term growth of capital. The fund seeks to take advantage of investment opportunities generated by changes in international trade patterns and economic and political relationships by investing in common stocks of companies located around the world. In pursuing its primary investment objective, the fund invests primarily in common stocks that are believed to have the potential for growth. In pursuing its secondary objective, the fund invests in common stocks of companies with the potential to pay dividends in the future. Capital Group New World - The fund’s investment objective is long-term capital appreciation. The fund invests primarily in common stocks of companies with significant exposure to developing countries. For purposes of this investment strategy, the fund may invest in equity securities of any company, regardless of where it is domiciled, if the fund determines that a significant portion of the company’s assets or revenues (generally 20% or more) is attributable to developing countries. Fixed-Income strategies Long Duration Government — Seeks to maximize risk adjusted returns over the long term. The strategy will invest in the following types of fixed-income securities, denominated in U.S. dollars, generally with a remaining maturity of 8 years or longer: (1) Generally, at least 80% of the strategy’s assets will be invested in securities that are issued, guaranteed or sponsored by the U.S. government, including securities issued by federal agencies and instrumentalities that are not backed by the full faith and credit of the U.S. government; and (2) Up to 20% of the fund’s or account’s assets may be invested in securities issued by foreign governments, their agencies and instrumentalities, and multilateral and supranational institutions. Investments will be made in the foregoing types of securities that have minimum credit ratings of AA- or better or Aa3 or better by a nationally recognized statistical rating organization, or if the security is unrated, those that are deemed to be of equivalent investment quality. Such investments may be represented by derivative instruments. The strategy may also hold cash and cash equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates or managed by a third party). Long Duration Credit — Seeks to maximize risk adjusted returns over the long term. The strategy may invest in fixed-income securities denominated in U.S. dollars, generally with a remaining maturity of eight years or greater. The strategy will invest primarily in securities of corporate, sovereign, supranational, local authority and non-U.S. agency issuers rated Baa3 or better or BBB- or better by a nationally recognized statistical rating organization, or unrated securities which are deemed to be of equivalent investment quality. Such investments may be represented by derivative instruments. The strategy may also invest in other fixed-income securities with the same minimum ratings or investment quality as above, and cash or cash equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates or managed by a third party). U.S. High-Yield - The fund’s primary investment objective is to provide a high level of current income. Its secondary investment objective is capital appreciation. The fund invests primarily in 12  higher yielding and generally lower quality debt securities (rated Ba1 / BB+ or below by Nationally Recognized Statistical Rating Organizations or unrated but determined to be of equivalent quality), including corporate loan obligations. The fund may also invest a portion of its assets in securities tied economically to countries outside the United States. The fund may invest in derivative instruments including forward contracts, futures contracts, swaps and options to, among other things, provide liquidity, obtain exposure not otherwise available, manage risk, manage foreign currency exposure, manage duration and yield curve exposure, and/or seek to increase returns and implement investment strategies in a more efficient manner. In addition, derivative instruments may be used to meet all or a portion of the investment concentrations noted above. Core Plus Total Return - Seeks to provide maximum total return consistent with preservation of capital. The strategy will invest primarily in bonds and other debt securities, which may be represented by derivatives. The strategy may invest in a broad range of debt securities, including corporate bonds and debt and mortgage-backed securities issued by government-sponsored entities and federal agencies and instrumentalities that are not backed by the full faith and credit of the U.S. government. Emerging Markets Debt — The fund seeks to provide, over the long-term, a high level of total return, of which a large component is current income. The fund will invest primarily in fixed- income securities of sovereign and corporate issuers: (1) in developing countries; (2) in countries rated Ba1 or lower or BB+ or lower by a nationally recognized statistical rating organization; or (3) in countries that are on an International Monetary Fund (“IMF”) program, have outstanding liabilities to the IMF, or have exited an IMF program no more than 5 years earlier. Such investments may be represented by derivative instruments. The fund may also invest in cash or cash equivalents (including shares of money market or similar funds managed by the investment adviser or its affiliates or managed by a third party). Capital Group U.S. Inflation Linked – The fund’s investment objective is to provide inflation protection and income consistent with investment in inflation-linked securities. The fund seeks to provide inflation protection and income by investing primarily in inflation-linked securities. Normally, the fund invests primarily in inflation-linked bonds issued by U.S. and non-U.S. governments, their agencies or instrumentalities, and corporations. Capital Group U.S. Intermediate-Term Fixed Income – The fund’s investment objective is to provide current income consistent with the maturity and quality standards described in the offering documents and preservation of capital. The fund invests primarily in bonds (bonds include any debt instrument and money market instrument). The fund maintains a portfolio of bonds, other debt securities and money market instruments having a dollar-weighted average effective maturity of no less than three years and no greater than five years under normal market conditions. Capital Group U.S. Core Fixed Income – The fund’s investment objective is to provide as high a level of current income as is consistent with the preservation of capital. The fund seeks to maximize the portfolio’s level of current income and preserve capital by investing primarily in bonds. Normally the fund invests primarily in bonds and other debt securities. The fund invests a majority of its assets in debt securities rated A3 or better or A- or better by Nationally 13  Recognized Statistical Ratings Organizations, or in debt securities that are unrated but determined to be of equivalent quality, including U.S. government securities, money market instruments or cash. The fund primarily invests in debt securities denominated in U.S. dollars. Capital Group Global Fixed Income – The fund’s investment objective is to provide, over the long term, a high level of total return consistent with prudent investment management. Total return comprises the income generated by the fund and the changes in the market value of the fund’s investments. Under normal market circumstances, the fund invests primarily in bonds and other debt securities. The fund invests primarily in debt securities, including asset-backed and mortgage-backed securities and securities of governmental, supranational and corporate issuers denominated in various currencies, including U.S. dollars. Capital Group U.S. Mortgage - The fund’s investment objective is to provide current income and preservation of capital. Normally the fund is invested primarily in mortgage-related securities, including securities collateralized by mortgage loans and contracts for future delivery of such securities (such as to be announced contracts and mortgage dollar rolls). Capital Group U.S. Government - The fund’s investment objective is to provide a high level of current income consistent with prudent investment risk and preservation of capital. Normally the fund invests primarily in securities that are guaranteed or sponsored by the U.S. government, its agencies and instrumentalities, including bonds and other debt securities denominated in U.S. dollars. The fund may also invest in mortgage-backed securities issued by federal agencies and instrumentalities that are not backed by the full faith and credit of the U.S. government. Capital Group Multi-Sector Fixed Income - The fund’s investment objective is to provide a high level of current income. Its secondary investment objective is capital appreciation. The fund invests primarily in bonds and other debt instruments, which may be represented by derivatives. In seeking to achieve a high level of current income, the fund invests in a broad range of debt securities across the credit spectrum. Normally, the fund will invest its assets across four primary sectors: high-yield corporate debt, investment grade corporate debt, debt instruments of emerging market issuers and securitized debt. The proportion of securities held by the fund within each of these credit sectors will vary with market conditions and the investment adviser’s assessment of their relative attractiveness as investment opportunities. The fund may opportunistically invest in other sectors, including U.S. government debt, municipal debt and non-corporate credit, in response to market conditions. The fund will normally seek to limit its foreign currency exposure. Balanced and total opportunity strategies Capital Group American Balanced - The investment objectives of the fund are: (1) conservation of capital, (2) current income and (3) long-term growth of capital and income. The fund uses a balanced approach to invest in a broad range of securities, including common stocks and investment-grade bonds (rated Baa3 or better or BBB- or better by Nationally Recognized Statistical Rating Organizations or unrated but determined to be of equivalent quality). The fund also invests in securities issued and guaranteed by the U.S. government and by federal agencies and instrumentalities. In addition, the fund may invest a portion of its assets in common stocks, 14  most of which have a history of paying dividends, bonds and other securities outside the United States. Though the fund will invest in both equity and debt securities, the fund will normally invest more heavily in common stocks and other equity securities than in fixed income securities. Although the fund focuses on investments in medium to larger capitalization companies, the fund’s investments are not limited to a particular capitalization size. Target Date Retirement Series – Depending on the proximity to its target date, which we define as the year that corresponds roughly to the year in which the investor expects to retire, the fund will seek to achieve the following objectives to varying degrees: growth, income and conservation of capital. The fund will increasingly emphasize income and conservation of capital by investing a greater portion of its assets in fixed income, equity-income and balanced funds as it approaches and passes its target date. In this way, the fund seeks to balance total return and stability over time. The fund will attempt to achieve its investment objectives by investing in a mix of proprietary pooled investment vehicles, which may include mutual funds and/or collective investment trusts, in different combinations and weightings. Target Date Retirement Blend Series – Depending on the proximity to its target date, which we define as the year that corresponds roughly to the year in which the investor expects to retire, the fund will seek to achieve the following objectives to varying degrees: growth, income and conservation of capital. The fund will increasingly emphasize income and conservation of capital by investing a greater portion of its assets in fixed income, equity-income and balanced funds as it approaches and passes its target date. In this way, the fund seeks to balance total return and stability over time. The fund will attempt to achieve its investment objectives by investing in a wide range of proprietary active and third-party-offered passive pooled investment vehicles, which may include collective investment trusts, mutual funds and/or ETFs, in different combinations and weightings. INVESTMENT RISKS Investing in securities involves risk of loss that funds and clients should be prepared to bear. Each account and fund is subject to certain risks associated with the investment strategy employed by CB&T and in accordance with the fund or account’s policies and restrictions. These risks may include, but are not limited to, certain of the risks set forth below.  Management — CB&T actively manages client’s investments. Consequently, the funds are subject to the risk that the methods and analyses including models, tools and data employed by CB&T in this process which may not produce the desired results. This could cause a fund to lose value or their investment results to lag relevant benchmarks or other funds with similar objectives.  Market conditions — The prices of, and income generated by, the common stocks and other securities held by the funds may decline – sometimes rapidly or unpredictably – due to various factors, including events or conditions affecting the general economy or particular industries or companies; overall market changes; local, regional or global political, social or economic instability; governmental, governmental agency or central bank responses to 15  economic conditions; levels of public debt and deficits; changes in inflation rates; and currency exchange rate, interest rate and commodity price fluctuations. Economies and financial markets throughout the world are highly interconnected. Economic, financial or political events, trading and tariff arrangements, wars, terrorism, cybersecurity events, natural disasters, public health emergencies (such as the spread of infectious disease), bank failures and other circumstances in one country or region, including actions taken by governmental or quasi-governmental authorities in response to any of the foregoing, could have impacts on global economies or markets. As a result, whether or not the fund invests in securities of issuers located in or with significant exposure to the countries affected, the value and liquidity of the fund’s investments may be negatively affected by developments in other countries and regions.  Investing in stocks — Investing in stocks may involve larger price swings and greater potential for loss than other types of investments. As a result, the value of the funds may be subject to sharp declines in value. Income provided by an underlying fund may be reduced by changes in the dividend policies of, and the capital resources available at, the companies in which the underlying fund invests. These risks may be even greater in the case of smaller capitalization stocks.  Investing in growth-oriented stocks — Growth-oriented common stocks and other equity- type securities (such as preferred stocks, convertible preferred stocks and convertible bonds) may involve larger price swings and greater potential for loss than other types of investments. These risks may be even greater in the case of smaller capitalization stocks.  Investing in income-oriented stocks — The value of the securities and income provided by the funds may be reduced by changes in the dividend policies of, and the capital resources available for dividend payments at, the companies in which a fund invests.  Issuer risks — The prices of, and the income generated by, securities held by the fund may decline in response to various factors directly related to the issuers of such securities, including reduced demand for an issuer’s goods or services, poor management performance, major litigation, investigations or other controversies related to the issuer, changes in the issuer’s financial condition or credit rating, changes in government regulations affecting the issuer or its competitive environment and strategic initiatives such as mergers, acquisitions or dispositions and the market response to any such initiatives. An individual security may also be affected by factors relating to the industry or sector of the issuer or the securities markets as a whole, and conversely an industry or sector of the securities markets may be affected by a change in financial condition or other event affecting a single issuer. The fund invests in issuers based on its level of investment conviction. At times, the fund may invest more significantly in a single issuer, which could increase the risk of loss arising from the factors described above.  Currency – The prices of, and the income generated by, most debt securities held by a fund may also be affected by changes in relative currency values. If the U.S. dollar appreciates 16  against foreign currencies, the value in U.S. dollars of the fund’s securities denominated in such currencies would generally fall and vice versa.  Currency transactions – In addition to the risks generally associated with investing in derivative instruments, the use of forward currency contracts involves the risk that currency movements will not be accurately predicted by the investment adviser, which could result in losses to the fund. While entering into forward currency contracts could minimize the risk of loss due to a decline in the value of the hedged currency, it could also limit any potential gain that may result from an increase in the value of the currency. Additionally, the investment adviser may use forward currency contracts to increase exposure to a certain currency or to shift exposure to currency fluctuations from one country to another. Forward currency contracts may expose the fund to potential gains and losses in excess of the initial amount invested. The fund may also enter into currency transactions to provide for the purchase or sale of a currency needed to purchase a security denominated in such currency. In addition, the fund may enter into forward currency contracts to protect against changes in currency exchange rates, to increase exposure to a particular foreign currency, to shift exposure to currency fluctuations from one currency to another or to seek to increase returns. A forward currency contract is an agreement to purchase or sell a specific currency at a future date at a fixed price.  Investing in small companies — Investing in smaller companies may pose additional risks. For example, it is often more difficult to value or dispose of small company stocks and more difficult to obtain information about smaller companies than about larger companies. Furthermore, smaller companies often have limited product lines, operating histories, markets and/or financial resources, may be dependent on one or a few key persons for management, and can be more susceptible to losses. Moreover, the prices of their stocks may be more volatile than stocks of larger, more established companies, particularly during times of market turmoil.  Investing outside the United States — Securities of issuers domiciled outside the United States or with significant operations or revenues outside the United States, and securities tied economically to countries outside the United States, may lose value because of adverse political, social, economic or market developments (including social instability, regional conflicts, terrorism and war) in the countries or regions in which the issuers are domiciled, operate or generate revenue or to which the securities are tied economically. These securities may also lose value due to changes in foreign currency exchange rates against the U.S. dollar and/or currencies of other countries. Issuers of these securities may be more susceptible to actions of foreign governments, such as nationalization, currency blockage or the imposition of price controls, sanctions or punitive taxes, each of which could adversely impact the value of these securities. Securities markets in certain countries may be more volatile and/or less liquid than those in the United States. Investments outside the United States may also be subject to different regulatory, legal, accounting, auditing, financial reporting and recordkeeping requirements, and may be more difficult to value, than those in the United States. In addition, the value of investments outside the United States may be reduced by foreign taxes, including foreign withholding taxes on interest and dividends. Further, there 17  may be increased risks of delayed settlement of securities purchased or sold by the fund, which could impact the liquidity of the fund’s portfolio. These risks of investing outside the United States may be heightened in connection with investments in emerging market.  Investing in emerging markets — Investing in emerging markets may involve risks in addition to and greater than those generally associated with investing in the securities markets of developed countries. For instance, emerging market countries tend to have less developed political, economic and legal systems than those in developed countries. Accordingly, the governments of these countries may be less stable and more likely to intervene in the market economy, for example, by imposing capital controls, nationalizing a company or industry, placing restrictions on foreign ownership and on withdrawing sale proceeds of securities from the country, and/or imposing punitive taxes that could adversely affect the prices of securities. Information regarding issuers in emerging markets may be limited, incomplete or inaccurate, and such issuers may not be subject to regulatory, accounting, auditing, and financial reporting and recordkeeping standards comparable to those to which issuers in more developed markets are subject. The fund’s rights with respect to its investments in emerging markets, if any, will generally be governed by local law, which may make it difficult or impossible for the fund to pursue legal remedies or to obtain and enforce judgments in local courts. In addition, the economies of these countries may be dependent on relatively few industries, may have limited access to capital and may be more susceptible to changes in local and global trade conditions and downturns in the world economy. Securities markets in these countries can also be relatively small and have substantially lower trading volumes. As a result, securities issued in these countries may be more volatile and less liquid, more vulnerable to market manipulation, and more difficult to value, than securities issued in countries with more developed economies and/or markets. Less certainty with respect to security valuations may lead to additional challenges and risks in calculating the fund’s net asset value. Additionally, emerging markets are more likely to experience problems with the clearing and settling of trades and the holding of securities by banks, agents and depositories that are less established than those in developed countries.  Investing in developing countries — Investing in countries with developing economies and/or markets may involve risks in addition to and greater than those generally associated with investing in developed countries. For instance, developing countries tend to have less developed political, economic and legal systems than those in developed countries. Accordingly, the governments of these countries may be less stable and more likely to intervene in the market economy, for example, by imposing capital controls, nationalizing a company or industry, placing restrictions on foreign ownership and on withdrawing sale proceeds of securities from the country, and/or imposing punitive taxes that could adversely affect the prices of securities. Information regarding issuers in developing countries may be limited, incomplete or inaccurate, and such issuers may not be subject to regulatory, accounting, auditing, and financial reporting and recordkeeping standards comparable to those to which issuers in developed countries are subject. The fund’s rights with respect to its investments in developing countries, if any, will generally be governed by local law, which may make it difficult or impossible for the fund to pursue legal remedies or to obtain and enforce judgments in local courts. In addition, the economies of these countries may be dependent on relatively few industries, may have limited access to capital and may be 18  more susceptible to changes in local and global trade conditions and downturns in the world economy. Securities markets in these countries can also be relatively small and have substantially lower trading volumes. As a result, securities issued in these countries may be more volatile and less liquid, more vulnerable to market manipulation, and more difficult to value, than securities issued in countries with more developed economies and/or markets. Less certainty with respect to security valuations may lead to additional challenges and risks in calculating the fund’s net asset value. Additionally, developing countries are more likely to experience problems with the clearing and settling of trades and the holding of securities by banks, agents and depositories that are less established than those in developed countries.  Exposure to country, region, industry or sector — Subject to the investment limitations, the fund may have significant exposure to a particular country, region, industry or sector. Such exposure may cause the fund to be more impacted by risks relating to and developments affecting the country, region, industry or sector, and thus its net asset value may be more volatile, than a fund without such levels of exposure. For example, if the fund has significant exposure in a particular country, then social, economic, regulatory or other issues that negatively affect that country may have a greater impact on the fund than on a fund that is more geographically diversified.  Investing in debt instruments — The prices of, and the income generated by, bonds and other debt securities held by the fund may be affected by factors such as the interest rates, maturities and credit quality of these securities. Rising interest rates will generally cause the prices of bonds and other debt securities to fall. Also, when interest rates rise, issuers of debt securities which may be prepaid at any time, such as mortgage- or other asset-backed securities, are less likely to refinance existing debt securities, causing the average life of such securities to extend. A general change in interest rates may cause investors to sell debt securities on a large scale, which could also adversely affect the price and liquidity of debt securities and could also result in increased redemptions from the fund. Falling interest rates may cause an issuer to redeem, call or refinance a debt security before its stated maturity, which may result in the fund having to reinvest the proceeds in lower yielding securities. Longer maturity debt securities generally have greater sensitivity to changes in interest rates and may be subject to greater price fluctuations than shorter maturity debt securities. Bonds and other debt securities are also subject to credit risk, which is the possibility that the credit strength of an issuer or guarantor will weaken or be perceived to be weaker, and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. Changes in actual or perceived creditworthiness may occur quickly. A downgrade or default affecting any of the fund’s securities could cause the value of the fund’s shares to decrease. Lower quality debt securities generally have higher rates of interest and may be subject to greater price fluctuations than higher quality debt securities. Credit risk is gauged, in part, by the credit ratings of the debt securities in which the fund invests. However, ratings are only the opinions of the rating agencies issuing them and are not guarantees as to credit quality or an evaluation of market risk. The fund’s investment adviser and its affiliates rely on their own credit analysts to research issuers and issues in assessing various credit and default risks. 19   Investing in lower rated debt instruments — Lower rated bonds and other lower rated debt securities, rated Ba1/BB+ or below by Nationally Recognized Statistical Rating Organizations, generally have higher rates of interest and involve greater risk of default or price declines due to changes in the issuer’s creditworthiness than those of higher quality debt securities. The market prices of these securities may fluctuate more than the prices of higher quality debt securities and may decline significantly in periods of general economic difficulty. These risks may be increased with respect to investments in junk bonds.  Investing in depository receipts – Depositary receipts are securities that evidence ownership interests in, and represent the right to receive, a security or a pool of securities that have been deposited with a bank or trust depository. Such securities may be less liquid or may trade at a lower price than the underlying securities of the issuer. Additionally, receipt of corporate information about the underlying issuer and proxy disclosure may not be timely and there may not be a correlation between such information and the market value of the depositary receipts.  Investing in securities backed by the U.S. government — U.S. government securities are subject to market risk, interest rate risk and credit risk. Securities backed by the U.S. Treasury or the full faith and credit of the U.S. government are guaranteed only as to the timely payment of interest and principal when held to maturity. Accordingly, the current market values for these securities will fluctuate with changes in interest rates and the credit rating of the U.S. government. Notwithstanding that these securities are backed by the full faith and credit of the U.S. government, circumstances could arise that would prevent or delay the payment of interest or principal on these securities, which could adversely affect their value and cause the fund to suffer losses. Such an event could lead to significant disruptions in U.S. and global markets. Securities issued by U.S. government-sponsored entities and federal agencies and instrumentalities that are not backed by the full faith and credit of the U.S. government are neither issued nor guaranteed by the U.S. government.  Interest rate risk — The values and liquidity of the securities held by a fund may be affected by changing interest rates. For example, the values of these securities may decline when interest rates rise and increase when interest rates fall. Longer maturity debt securities generally have greater sensitivity to changes in interest rates and may be subject to greater price fluctuations than shorter maturity debt securities. The fund may invest in variable and floating rate securities. When the fund holds variable or floating rate securities, a decrease in market interest rates will adversely affect the income received from such securities and the net asset value of the fund’s shares. Although the values of such securities are generally less sensitive to interest rate changes than those of other debt securities, the value of variable and floating rate securities may decline if their interest rates do not rise as quickly, or as much, as market interest rates. Conversely, floating rate securities will not generally increase in value if interest rates decline. During periods of extremely low short-term interest rates, the fund may not be able to maintain a positive yield or total return and, in relatively low interest rate environments, there are heightened risks associated with rising interest rates.  Investing in future delivery contracts — A fund or account may enter into transactions involving future delivery contracts, such as to-be-announced (TBA) contracts and mortgage dollar rolls. These contracts involve the purchase or sale of mortgage backed securities for 20  settlement at a future date and predetermined price. When the fund enters into a TBA commitment for the sale of mortgage-backed securities (which may be referred to as having a short position in such TBA securities), the fund may or may not hold the types of mortgage- backed securities required to be delivered. The fund may choose to roll these transactions in lieu of settling them.  When the fund rolls the purchase of these types of future delivery transactions, the fund or account simultaneously sells the mortgage backed securities for delivery in the current month and repurchases substantially similar securities for delivery at a future date at a predetermined price. When the fund or account rolls the sale of these transactions rather than settling them, the fund or account simultaneously purchases the mortgage backed securities for delivery in the current month and sells substantially similar securities for delivery at a future date at a predetermined price. Such roll transactions can increase the turnover rate of the fund or account and may increase the risk that prices may move unfavorably between the original and new contracts, potentially resulting in losses or reduced returns for the fund or account.  Investing in mortgage-related and other asset backed securities —Mortgage-related securities, such as mortgage-backed securities, and other asset-backed securities, include debt obligations that represent interests in pools of mortgages or other income-bearing assets, such as consumer loans or receivables. Such securities often involve risks that are different from or more acute than the risks associated with investing in other types of debt securities. Mortgage-backed and other asset-backed securities are subject to changes in the payment patterns of borrowers of the underlying debt, potentially increasing the volatility of the securities and a fund’s net asset value. When interest rates fall, borrowers are more likely to refinance or prepay their debt before its stated maturity. This may result in the fund having to reinvest the proceeds in lower yielding securities, effectively reducing the fund’s income. Conversely, if interest rates rise and borrowers repay their debt more slowly than expected, the time in which the mortgage-backed and other asset-backed securities are paid off could be extended, reducing the fund’s cash available for reinvestment in higher yielding securities. Mortgage-backed securities are also subject to the risk that underlying borrowers will be unable to meet their obligations and the value of property that secures the mortgages may decline in value and be insufficient, upon foreclosure, to repay the associated loans. Investments in asset-backed securities are subject to similar risks.  Investing in derivatives — The use of derivatives involves a variety of risks, which may be different from, or greater than, the risks associated with investing in traditional securities, such as stocks and bonds. Changes in the value of a derivative may not correlate perfectly with, and may be more sensitive to market events than, the underlying asset, rate or index, and a derivative instrument may cause a fund to lose significantly more than its initial investment. Derivatives may be difficult to value, difficult for the fund to buy or sell at an opportune time or price and difficult to terminate or otherwise offset. The fund’s use of derivatives may result in losses to the fund, and investing in derivatives may reduce the fund’s returns and increase the fund’s price volatility. The fund’s counterparty to a derivative 21  transaction (including, if applicable, the fund’s clearing broker, the derivatives exchange or the clearinghouse) may be unable or unwilling to honor its financial obligations in respect of the transaction. In certain cases, the fund may be hindered or delayed in exercising remedies against or closing out derivative instruments with a counterparty, which may result in additional losses. Derivatives are also subject to operational risk (such as documentation issues, settlement issues and systems failures) and legal risk (such as insufficient documentation, insufficient capacity or authority of a counterparty, and issues with the legality or enforceability of a contract).  Investing in swaps — Swaps, including interest rate swaps and credit default swap indices, or CDSIs, are subject to many of the risks generally associated with investing in derivative instruments. Additionally, although swaps require no initial investment or only a small initial investment in the form of a deposit of initial margin, the amount of a potential loss on a swap could greatly exceed the initial amount invested. The use of swaps involves the risk that the investment adviser will not accurately predict anticipated changes in interest rates or other economic factors, which may result in losses to a fund. If the fund enters into a bilaterally negotiated swap, the counterparty may fail to perform in accordance with the terms of the swap . If a counterparty defaults on its obligations under a swap , the fund may lose any amount it expected to receive from the counterparty, potentially including amounts in excess of the fund’s initial investment. Certain swaps are subject to mandatory central clearing or may be eligible for voluntary central clearing. Although clearing interposes a central clearinghouse as the ultimate counterparty to each participant’s swap, central clearing will not eliminate (but may decrease) counterparty risk relative to uncleared bilateral swaps. Some swaps, such as CDSIs, may be dependent on both the individual credit of the fund’s counterparty and on the credit of one or more issuers of any underlying assets. If the fund does not correctly evaluate the creditworthiness of its counterparty and, where applicable, of issuers of any underlying reference assets, the fund’s investment in a swap may result in losses to the fund.  Investing in futures contracts — In addition to the risks generally associated with investing in derivative instruments, futures contracts are subject to the creditworthiness of the clearing organizations, exchanges and futures commission merchants with which a fund transacts. Additionally, although futures require only a small initial investment in the form of a deposit of initial margin, the amount of a potential loss on a futures contract could greatly exceed the initial amount invested. While futures contracts are generally liquid instruments, under certain market conditions futures may be deemed to be illiquid. For example, the fund may be temporarily prohibited from closing out its position in a futures contract if intraday price change limits or limits on trading volume imposed by the applicable futures exchange are triggered. If the fund is unable to close out a position on a futures contract, the fund would remain subject to the risk of adverse price movements until the fund is able to close out the futures position. The ability of the fund to successfully utilize futures contracts may depend in part upon the ability of the fund’s investment adviser to accurately forecast interest rates and other economic factors and to assess and predict the impact of such economic factors on the futures in which the fund invests. If the investment adviser incorrectly forecasts economic developments or incorrectly predicts the impact of such developments on the futures in which it invests, the fund could suffer losses. 22   Investing in options – Options on currencies, securities and other instruments (referred to as the “underlying instruments”) are subject to additional risks aside from those generally associated with investing in derivatives instruments. For example, there may be significant differences between the underlying instruments and options markets that could result in an imperfect correlation between these markets, which could cause a given transaction not to achieve its objectives. When a put or call option on a particular underlying instrument is purchased to hedge against price movements in a related underlying instrument, for example, the price to close out the put or call option may move more or less than the price of the related underlying instrument. Options prices can diverge from the prices of their underlying instruments for a number of reasons. Options prices are affected by such factors as current and anticipated short-term interest rates, changes in the volatility of the underlying instrument, and the time remaining until expiration of the contract, which may not affect security prices in the same way. Imperfect correlation may also result from differing levels of demand in the options markets and the markets for the underlying instruments, from structural differences in how options and underlying instruments are traded, or from imposition of daily price fluctuation limits or trading halts. The fund may purchase or sell options contracts with a greater or lesser value than the underlying instruments it wishes to hedge or intends to purchase in order to attempt to compensate for differences in volatility between the contract and the underlying instruments, although this may not be successful. If price changes in the fund’s options positions are less correlated with its other investments, the positions may fail to produce anticipated gains or result in losses that are not offset by gains in other investments. There is no assurance that a liquid market will exist for any particular options contract at any particular time.  Hedging – There may be imperfect or even negative correlation between the prices of the options and futures contracts in which a fund invests and the prices of the underlying securities or indexes which the fund seeks to hedge. For example, options and futures contracts may not provide an effective hedge because changes in options and futures contract prices may not track those of the underlying securities or indexes they are intended to hedge. In addition, there are significant differences between the securities market, on the one hand, and the options and futures markets, on the other, that could result in an imperfect correlation between the markets, causing a given hedge not to achieve its objectives. The degree of imperfection of correlation depends on circumstances such as variations in speculative market demand for options and futures, including technical influences in options and futures trading, and differences between the financial instruments being hedged and the instruments underlying the standard contracts available for trading. A decision as to whether, when and how to hedge involves the exercise of skill and judgment, and even a well-conceived hedge may be unsuccessful to some degree because of market behavior or unexpected interest rate trends. In addition, the fund’s investment in exchange-traded options and futures and their resulting costs could limit the fund’s gains in rising markets relative to those of the underlying fund, or to those of unhedged funds in general.  Lending of portfolio securities – Securities lending involves risks, including the risk that the loaned securities may not be returned in a timely manner or at all, which would interfere with the fund’s ability to vote proxies or settle transactions, and/or the risk of a counterparty 23  default. Additionally, a fund may lose money from the reinvestment of collateral received on loaned securities in investments that decline in value, default or do not perform as expected.  Liquidity risk – Certain fund holdings may be or may become difficult or impossible to sell, particularly during times of market turmoil. Liquidity may be impacted by the lack of an active market for a holding, legal or contractual restrictions on resale, or the reduced number and capacity of market participants to make a market in such holding. Market prices for less liquid or illiquid holdings may be volatile or difficult to determine, and reduced liquidity may have an adverse impact on the market price of such holdings. . Additionally, the sale of less liquid or illiquid holdings may involve substantial delays (including delays in settlement) and additional costs and the fund may be unable to sell such holdings when necessary to meet its liquidity needs, or to try to limit losses, or may be forced to sell at a loss.  Asset allocation — The fund’s percentage allocation to equity securities, debt securities and money market instruments could cause the fund or account to underperform relative to relevant benchmarks and other funds with similar investment objectives. The fund may also hold cash or cash equivalents, including commercial paper and short-term securities issued by the U.S. government, its agencies and instrumentalities. The percentage of the fund invested in such holdings varies and depends on various factors, including market conditions and purchases and redemptions of fund shares. The investment adviser may determine that it is appropriate to invest a substantial portion of the fund’s assets in such instruments in response to certain circumstances, such as periods of market turmoil. For temporary defensive purposes, the fund may invest without limitation in such instruments. A larger percentage of such holdings could moderate the fund’s investment results in a period of rising market prices. Alternatively, a larger percentage of such holdings could reduce the magnitude of the fund’s loss in a period of falling market prices and provide liquidity to make additional investments or to meet redemptions.  Cybersecurity risks — With the increased use of technologies such as the Internet to conduct business, the fund has become potentially more susceptible to operational and information security risks through breaches in cybersecurity. In general, a breach in cybersecurity can result from either a deliberate attack or an unintentional event. Cybersecurity breaches may involve, among other things, “ransomware” attacks, injection of computer viruses or malicious software code, or the use of vulnerabilities in code to gain unauthorized access to the fund’s digital information systems, networks or devices that are used directly or indirectly by the fund or its service providers through “hacking” or other means. Cybersecurity risks also include the risk of losses of service resulting from external attacks that do not require unauthorized access to the fund’s systems, networks or devices. For example, denial-of- service attacks on the investment adviser’s or an affiliate’s website could effectively render the fund’s network services unavailable to fund shareholders and other intended end-users. Any such cybersecurity breaches or losses of service may, among other things, cause the fund to lose proprietary information, suffer data corruption or lose operational capacity, which or may result in the misappropriation, unauthorized release or other misuse of the fund’s assets or sensitive information (including shareholder personal information or other confidential information),the inability of fund shareholders to transact business, or the 24  destruction of the fund’s physical infrastructure, equipment or operating systems. These, in turn, could cause the fund to violate applicable privacy and other laws and incur or suffer regulatory penalties, reputational damage, additional costs (including compliance costs) associated with corrective measures and/or financial loss. While the fund and its investment adviser have established business continuity plans and risk management systems designed to prevent or reduce the impact of cybersecurity attacks, there are inherent limitations in such plans and systems due in part to the ever-changing nature of technology and cybersecurity attack tactics, and there is a possibility that certain risks have not been adequately identified or prepared for. In addition, cybersecurity failures by or breaches of the fund’s third-party service providers (including, but not limited to, the fund’s investment adviser, transfer agent, custodian, administrators and other financial intermediaries) may disrupt the business operations of the service providers and of the fund, potentially resulting in financial losses, the inability of fund shareholders to transact business with the fund and of the fund to process transactions, the inability of the fund to calculate its net asset value, violations of applicable privacy and other laws, rules and regulations, regulatory fines, penalties, reputational damage, reimbursement or other compensatory costs and/or additional compliance costs associated with implementation of any corrective measures. The fund and its shareholders could be negatively impacted as a result of any such cybersecurity breaches, and there can be no assurance that the fund will not suffer losses relating to cybersecurity attacks or other informational security breaches affecting the fund’s third-party service providers in the future, particularly as the fund cannot control any cybersecurity plans or systems implemented by such service providers. Cybersecurity risks may also impact issuers of securities in which the fund invests, which may cause the fund’s investments in such issuers to lose value.  Operational Events – To the extent that a strategy relies on proprietary and third party data analysis and systems to support investment decision making, there is a risk or software or other technology malfunctions or programming inaccuracies that may impair the performance of these systems. System impairment may negatively impact performance.  Loss of investment — An investor may lose money by investing in an account or fund. The likelihood of loss may be greater if the investor invests for a shorter period of time.  Investments are not guaranteed — Investments in accounts and funds are not bank deposits and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other governmental agency, entity or person.  Long-Term Perspective – Investors in the account or fund should have a long-term perspective and be able to tolerate potentially sharp declines in value.  Past investment results are not predictive of future investment results. 25  For Target Date fund investments, additional risks include:  Allocation risk — Investments in the fund are subject to risks related to the investment adviser’s allocation choices. The selection of the underlying funds and the allocation of the fund’s assets could cause the fund to lose value or its results to lag relevant benchmarks or other funds with similar objectives. The fund may invest in an underlying fixed-income fund that is a non-diversified investment company under the Investment Company Act of 1940. To the extent that the fund invests a larger percentage of its assets in securities of one or more issuers, poor performance by these securities could have a greater adverse impact on the fund’s investment results.  Proprietary funds – The fund invests only in underlying funds offered and/or managed by the trustee or its affiliates, including the investment adviser. The fund does not intend to invest in unaffiliated funds. The fund’s fees will not vary based on the allocation to underlying funds. The investment results of the fund may differ if it invested in non-proprietary funds.  Underlying fund risks — Because the fund’s investments consist of underlying funds, the fund’s risks are directly related to the risks of the underlying funds. For this reason, it is important to understand the risks associated with investing in the underlying funds, as described below. Through the underlying funds in which it invests, the fund will, over time, have significant exposure to a range of different security types, including growth-oriented and dividend- paying common stocks and a variety of fixed income investments. Through its underlying fund investments, the fund will typically have exposure to issuers outside the United States, including issuers domiciled in emerging markets. The fund will also have exposure to issuers with a broad range of market capitalizations, including smaller capitalization issuers. Each fund will invest in some, but not all, of the underlying funds for which principal risks are listed below. Accordingly, not all of the principal risks listed below necessarily apply to each fund’s underlying funds. Each fund's risks will vary based on the combination and weightings of the underlying funds held. For example, risks related to investing in stocks and investing outside the U.S. will be higher for funds that are further from their target date. Those risks will decline and risks associated with investing in fixed income securities will rise as a fund gets closer to its target date. Clients should also refer to account guidelines as well as to each account’s or fund’s governing documents or other disclosure documents for further information specific to their account or fund investment. CB&T occasionally, as needed for account servicing, discloses nonpublic personal information about your account such as name, account information, portfolio holdings or other relevant details to unaffiliated third parties. If information is provided to a third party, such third party is 26  required to protect the confidentiality and security of this information and use it only for its intended purpose. If a third party delivers client securities or funds to the investment adviser in connection with, among other things, a securities law related lawsuit or regulatory order (e.g., proceeds from a class action settlement or Fair Fund account), corporate action, tax refund or reclaim, such securities or funds will be forwarded to the client or the client’s custodian. In certain circumstances, however, if the intended recipient cannot be readily identified, they may be returned to sender, escheated or donated as deemed appropriate by the investment adviser. 27  ITEM 9: DISCIPLINARY INFORMATION Neither CB&T nor its management persons have been the subject of legal or regulatory findings, or are the subject of any pending criminal proceedings that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. From time to time, CB&T or its management persons may be subject to regulatory examinations, investigations, litigation or inquiries that arise in the ordinary course of our business. In the event we become aware of any regulatory matter or litigation that we believe would be material to an evaluation of our advisory business, we notify all clients or prospects effected by those events, subject to applicable law and regulation. 28  ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS CB&T has the following arrangements that are material to its advisory business with certain affiliated entities. Some of CB&T’s directors and executive officers and employees are also directors, officers or employees of one or more affiliates. Broker-dealer Capital Client Group, Inc. (“CCG”) is a registered broker-dealer and a member of the Financial Industry Regulatory Authority and Municipal Securities Rulemaking Board. CCG acts as the principal underwriter and distributor of mutual funds, including investment companies advised and administered by CB&T’s affiliates, and provides related services. In addition, certain of CB&T’s management persons or other employees are registered representatives of CCG. Capital Client Group, Inc. is also registered as an insurance agency or producer in certain states. Capital Client Group, Inc. is also an investment adviser which provides investment advisory related services in connection with various wrap-fee programs sponsored by unaffiliated broker-dealers or other financial institutions, where CB&T’s affiliates can be retained as an investment manager. Registered Investment Companies Capital International, Inc. (“CIInc”) and Capital Research and Management Company (“CRMC”) serve as investment advisers for investment companies registered under the Investment Company Act of 1940. CIInc and CRMC receive advisory and other fees and expenses from each fund based upon the value of the fund’s assets; those fees are described in each fund’s governing documents. Commodity Pool Operator CRMC, an affiliated investment adviser, is registered as a commodity pool operator and a member of the National Futures Association. Unregistered Collective Investment Funds CB&T serves as the discretionary trustee to privately-offered commingled funds that are exempt from registration. CIInc and CRMC serve as investment advisers to CB&T for these Commingled Funds. CB&T, CRMC, and CIInc all receive compensation in connection with their services to the Commingled Funds. Fees are described in each fund’s governing documents. Other Investment Advisers Because our funds, accounts, and our personnel are located around the world, we conduct business through a number of affiliated entities licensed to offer services in various jurisdictions and to perform particular business functions. Though legally distinct, our affiliates function as a unified, global business. We believe that our globally integrated model helps us to serve our 29  clients’ needs better. We often engage our affiliates and their personnel to assist in managing client mandates. For example, our affiliated personnel provide research, portfolio management or trading services to certain client accounts. Certain portfolio managers employed by the following affiliated investment advisers, under the supervision and review of CB&T or its affiliates, determine the securities to be purchased and sold for certain clients of CB&T: CGPCS is an affiliated investment adviser registered with the U.S. Securities and Exchange Commission with which CB&T shares supervised persons. CRMC is an affiliated investment adviser registered with the U.S. Securities and Exchange Commission with which CB&T shares supervised persons. Capital Research Company is an affiliated registered investment adviser and indirectly provides investment advisory research to CB&T. This includes managing assets, subject to the supervision and control of CB&T, or its other advisory affiliates. CIInc is an affiliated investment adviser registered with the U.S. Securities and Exchange Commission as well as with the Hong Kong Securities and Futures Commission, the Financial Services Commission of South Korea and the Australian Securities and Investment Commission as it also conducts investment advisory and asset management services in those regions. Capital International K.K. (“CIKK”) is based in Japan and has been authorized by the Financial Services Agency to provide investment advisory and asset management services. Capital International K.K. provides research information and services to CB&T. Capital Group Investment Management Pte. Ltd. (“CGIMPL”) is based in Singapore and has been authorized by the Monetary Authority of Singapore to provide investment advisory and asset management services. Capital International Sarl (“CISA”) is based in Switzerland and has been authorized by the Financial Markets Supervisory Authority to provide investment advisory services. Capital International Limited (“CIL”) is based in the U.K has been authorized by the U.K. Financial Conduct Authority to provide investment advisory and asset management services. Capital Group UK Management Company (“CGUKMC”) is authorized by the U.K. Financial Conduct Authority as a U.K. management company. CGUKMC serves as a management company only and does not undertake other financially regulated activities, nor does it undertake any activities outside of the U.K. 30  Capital International Management Company Sarl (“CIMC”) is based in Luxembourg and has been authorized by the Luxembourg financial regulator and other financial regulators in the European Union to provide investment advisory or asset management services in Luxembourg and European Union countries. None of CIKK, CGIMPL, CISA, CIL nor CIMC are registered as an investment adviser under the Investment Advisers Act of 1940, as amended (the “Advisers Act”) and each is deemed to be a “Participating Affiliate” of CB&T and its affiliates, as this term has been used by the SEC’s Division of Investment Management in various no-action letters granting relief from the Advisers Act’s registration requirements for certain affiliates of registered investment advisers. 31  ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING CB&T and its affiliated companies have adopted a Code of Ethics for its associates (“Code of Ethics”) that requires all associates: (1) act with integrity, competence and in an ethical manner; (2) comply with applicable U.S. federal securities laws, as well as all other applicable laws, rules and regulations; and (3) promptly report violations of the Code of Ethics. All associates are required to certify at least annually that they have read and understand the Code. A copy of the Code of Ethics is available to clients and prospective clients upon request and on americanfunds.com. The Code of Ethics includes:  Protection of Non-Public Information: Policies and procedures designed to prevent and detect the misuse of material non-public information by associates. These procedures require all associates who believe they may be in possession of material non-public information regarding an issuer to notify the Legal Department, which will determine the appropriate actions to be taken.  Personal Investing: Policies related to personal investing by our associates. The policies ban excessive trading of any Capital-managed investment vehicles worldwide, including the American Funds. Associates generally may not participate in the acquisitions of securities in initial public offerings. Additional restrictions apply to associates with access to non-public information relating to current or imminent fund/client transactions, investment recommendations or fund portfolio holdings (Covered Associates). Covered Associates generally may not affect securities transactions for their own account when any investment advisory account is transacting in the issuer in question. All such Covered Associates must report their securities transactions on a quarterly basis and disclose their holdings annually. Covered Associates must pre-clear certain personal security transactions and special review of private placements is required. Additional restrictions and reporting apply to Investment Access Persons, including blackout periods on personal investing and a ban on short-term trading.  Gifts and Entertainment: Policy prohibiting associates from accepting and extending gifts or entertainment that are excessive, repetitive or extravagant, if such gifts or entertainment involve a third party’s business relationship (or prospective business relationship) with Capital. Procedures include quarterly reporting of gifts or entertainment received or extended, a dollar limit on gifts that can be accepted from any one source during a calendar year, and preclearance of entertainment beyond a certain dollar limit.  Political Contributions: Policy governing political contributions and/or other activities that directly support officials, candidates, or organizations that may be in a position to influence decisions to award business to investment management firms. Specific rules exist for political contributions and activities within the U.S. and restricted 32  associates are required to seek preclearance and approval for political contributions to state and local government officials (or candidates for those positions), federal candidate campaigns and affiliated committees, and political organizations, such as Political Action Committees (PACs). Participation or Interest in Client Transactions CB&T's employees may also purchase shares in certain Commingled Funds and other pooled funds advised by CB&T or an affiliate of CB&T. Such purchases take place either through their CGPCS account or through retirement plans sponsored by The Capital Group Companies, Inc., the parent company of CB&T. All such transactions are conducted at net asset value and in accordance with the purchase and redemption provisions as described in either the prospectus or offering memorandum of the fund. 33  ITEM 12: BROKERAGE PRACTICES Selecting Broker-Dealers Portfolio Transactions CB&T and its affiliates place orders with broker-dealers for clients’ portfolio transactions. Purchases and sales of equity securities on a securities exchange or an over-the-counter market are effected through broker-dealers who receive commissions for their services. Purchases and sales of fixed-income securities and currency foreign exchange transactions are generally made with an issuer or a primary market-maker acting as principal with no stated brokerage commission. Prices for fixed-income securities in secondary trades usually include undisclosed compensation to the market-maker reflecting the spread between the bid and ask prices for the securities. The prices for equity and fixed-income securities purchased in primary market transactions, such as initial public offerings, new fixed-income issues, secondary offerings and private placements, may include underwriting fees. Best Execution In selecting broker-dealers, CB&T and its affiliates strive to obtain “best execution” (the most favorable total price reasonably attainable under the circumstances) for its clients’ portfolio transactions, taking into account a variety of factors. These factors include the size and type of transaction, the nature and character of the markets for the security to be purchased or sold, the cost, quality, likely speed and reliability of execution and settlement, the broker-dealer’s or execution venue’s ability to offer liquidity and anonymity and the tradeoff between market impact and opportunity costs. CB&T considers these factors, which involve qualitative judgment, when selecting broker-dealers and execution venues for its clients’ portfolio transactions. CB&T views best execution as a process that should be evaluated over time as part of an overall relationship with particular broker-dealer firms. In this regard, CB&T does not consider itself as having an obligation to obtain the lowest commission rate available for a portfolio transaction to the exclusion of price, service and qualitative considerations. Brokerage commissions are only a small part of total execution costs and other factors, such as market impact and speed of execution, contribute significantly to overall transaction costs. Oversight The Capital Group Companies Equity Trading Oversight and Best Execution Committee and the Capital Group Companies Fixed-Income Best Execution Committee provide oversight to CB&T’s policies, procedures and practices relating to best execution. CB&T obtains third-party analysis of trading execution quality. These analyses compare execution results with various benchmarks which provide quantitative data that is one of many data points that is evaluated to ensure that CB&T is meeting its best execution obligation. The Market and Transaction Research group performs in-depth analysis on equity trade execution data and reviews the findings with the Global Equity Trading Manager to enhance the ability to measure and interpret trading costs and their effects on portfolio performance. The 34  Equity Trading Oversight and Best Execution Committee meets periodically to review such trade execution analysis and evaluate the overall quality of execution and trades. The Equity Trading Oversight and Best Execution Committee also reviews equity trading policies and approves changes as appropriate. Fixed-income analysis of trade execution data and trading costs is performed in coordination with the traders and reviewed by the Fixed Income Trading Management team to enhance the ability to measure and interpret trading costs and their effects on portfolio performance. The Fixed-Income Best Execution Committee meets periodically to review fixed-income trading practices and overall quality of execution for fixed-income and foreign exchange trades. The Fixed-Income Best Execution Committee also reviews fixed- income trading policies and approves changes as appropriate. The Capital Group Companies Investment Group provides oversight of Capital Group’s research management program. It is responsible for (a) overseeing the quality of the research and data acquired by CB&T and its affiliates to inform future procurement processes, decisions and payment levels and (b) approving an annual research budget. Commission Rates CB&T and its affiliates negotiate commission rates with brokers based on what they believe is reasonably necessary to obtain best execution. CB&T and its affiliates do not consider the appropriate commission to necessarily be the lowest available commission, but attempt to maximize the overall benefits received by their clients for their commissions. Commission rates vary based on the nature of the transaction, the market in which the security is traded and the venue chosen for trading, among other factors. CB&T and its affiliates seek, on an ongoing basis, to determine what the reasonable levels of commission rates for execution services are in the marketplace, taking various considerations into account, including the extent to which a broker-dealer has put its own capital at risk, historical commission rates and, commission rates that other institutional investors are paying. Brokerage and Investment Research Services CB&T and its affiliates execute portfolio transactions with broker-dealers who provide certain brokerage and/or investment research services to CB&T and its affiliates but only when in CB&T’s and its affiliates’ judgment the broker-dealer is capable of providing best execution for that transaction. CB&T and its affiliates make decisions for procurement of research separately and distinctly from decisions on the choice of brokerage and execution services. The receipt of these research services permits CB&T and each affiliate to supplement its own research and analysis and makes available the views of, and information from, individuals and the research staffs of other firms. These services include, among other things, reports and other communications with respect to individual companies, industries, countries and regions, economic, political and legal developments, as well as scheduling meetings with corporate executives and seminars and conferences related to relevant subject matters. This information may be provided in the form of written reports, telephone contacts and meetings with securities analysts. 35  CB&T and its affiliates bear the cost of all third-party investment research services for all client accounts they advise. However, in order to compensate certain U.S. broker-dealers for research consumed, and valued, by their investment professionals, CB&T and its affiliates operate a limited commission sharing arrangement with commissions on equity trades for registered investment companies managed by CB&T or its affiliates. CB&T and its affiliates voluntarily reimburse such registered investment companies for all amounts collected into the commission sharing arrangement. In order to operate the commission sharing arrangement, CB&T and its affiliates may cause such registered investment companies to pay commissions in excess of what other broker-dealers might have charged for certain portfolio transactions in recognition of brokerage and/or investment research services. In this regard, CB&T and its affiliates have adopted a brokerage allocation procedure consistent with the requirements of Section 28(e) of the U.S. Securities Exchange Act of 1934. Section 28(e) permits an investment adviser to cause an account to pay a higher commission to a broker-dealer to compensate the broker-dealer or another service provider for certain brokerage and/or investment research services provided to CB&T and its affiliates, if CB&T and each affiliate makes a good faith determination that such commissions are reasonable in relation to the value of the services provided to CB&T and its affiliates in terms of that particular transaction or CB&T’s or its affiliates overall responsibility to their clients. Certain brokerage and/or investment research services may not necessarily benefit all accounts paying commissions to a broker-dealer, therefore, CB&T and its affiliates assess the reasonableness of commissions in light of the total brokerage and investment research services provided to CB&T and its affiliates. Further, research services may be used by all investment associates of CB&T and its affiliates regardless of whether they advise accounts with trading activity that generates eligible commissions. In accordance with its internal brokerage allocation procedure, CB&T and its affiliates periodically assess the brokerage and investment research services provided by each broker-dealer and each other service provider from whom they receive such services. As part of ongoing relationships, CB&T and its affiliates routinely meet with firms to discuss the level and quality of the brokerage and research services provided, as well as the value and cost of such services. In valuing the brokerage and investment research services CB&T and its affiliates receive from broker-dealers and other research providers in connection with their good faith determination of reasonableness, CB&T and its affiliates take various factors into consideration, including the quantity, quality and usefulness of the services to CB&T and its affiliates. Based in this information and applying their judgment, CB&T and its affiliates set an annual research budget. Research analysts and portfolio managers periodically participate in a research poll to determine the usefulness and value of the research provided by individual broker-dealers and research providers. Based on the results of this research poll, CB&T and its affiliates may, through commission sharing arrangements with certain broker-dealers, direct a portion of commissions paid to a broker-dealer by registered investment companies managed by CB&T or its affiliates to be used to compensate the broker-dealer and/or other research providers for research services they provide. 36  While CB&T and its affiliates may negotiate commission rates and enter into commission sharing arrangements with certain broker-dealers with the expectation that such broker-dealers will be providing brokerage and research services, none of CB&T, any of its affiliates or any of their clients incurs any obligation to any broker-dealer to pay for research by generating trading commissions. CB&T and its affiliates negotiate prices for certain research that may be paid through commission sharing arrangements or by themselves with cash. Cross Trades As part of its authority to invest client assets on a discretionary basis, CB&T places cross-trades between client accounts managed by CB&T and its affiliates from time to time. CB&T recognizes that a potential conflict of interest may exist when placing trades between client accounts. To address such potential conflicts, CB&T maintains cross-trade policies and procedures and places a cross-trade under those limited circumstances when such a trade: (a) is in the best interest of all participating clients and (b) is not prohibited by the participating clients’ investment management agreement or applicable law. Exchange or alternative trading system ownership An affiliate of CB&T currently maintains a minority ownership interest in IEX Group and an indirect, minority ownership interest in alternative trading systems Luminex Trading and Analytics and LeveL ATS (through a non-controlling interest in their common parent holding company). CB&T, or brokers with whom it places orders, may place orders on these or other exchanges or alternative trading systems in which it, or one of its affiliates, has an ownership interest, provided such ownership interest is less than five percent of the total ownership interests in the entity. CB&T is subject to the same best execution obligations when trading on any such exchange or alternative trading system. Sale of Fund Shares Not Considered CB&T may place orders for a client’s portfolio transactions with broker-dealers who have sold shares in the funds managed by CB&T or its affiliated companies; however, it does not consider whether a broker-dealer has sold shares of the funds managed by CB&T or its affiliated companies when placing any such orders for a client’s portfolio transactions. Client Referrals CB&T does not consider client referrals from a broker-dealer or third party in selecting or recommending broker-dealers. Directed Brokerage In some instances, CB&T or its affiliates will accept a client’s instructions to direct a portion of the account’s brokerage commissions to a particular broker or group of brokers so long as the direction is consistent with CB&T’s policy of seeking best execution. CB&T’s ability to meet client direction requests will depend on the broker(s) selected by the client and the securities and 37  markets in which the account invests, among other factors. Furthermore, CB&T and its affiliates will only accept requests to direct brokerage from clients who are subject to ERISA only if the client’s direction program complies with ERISA. Occasionally, clients direct CB&T to place all or a portion of their account’s annual brokerage costs to one or several broker-dealers and do not require that directed trades be subject to CB&T’s policy of seeking best execution. In these cases, CB&T may be limited in negotiating commissions with broker-dealers to whom it directs trades and such accounts may therefore pay higher commissions than those that do not direct brokerage in this way. Further, such trades are not aggregated with trades for CB&T’s other clients and funds, and may be executed subsequent to trades for other CB&T accounts and funds. CB&T believes clients are best served when it has the full authority to determine the broker and negotiate commissions for securities transactions. With directed brokerage arrangements of this type, CB&T cannot assure clients that they will be able to obtain best execution. Aggregation and Allocation of Portfolio Transactions Frequently, CB&T will place orders to purchase or sell the same security for a number of clients of CB&T and its affiliates that are advised by the same investment division. CB&T has determined that it is fair and equitable to participating funds and accounts to aggregate orders and allocate executions within each investment division in accordance with this policy. CB&T believes that placing aggregated or “block” trades is consistent with its duty to seek best execution. Further, a client’s trades are aggregated with those of other clients only if it is consistent with the terms of the client’s investment advisory agreement. CB&T may not aggregate certain trades only when it believes that doing so will not have a material impact on the price or quality of other transactions. This policy is designed to allocate trades of the same security to clients in a fair and equitable manner over time, taking into consideration the interests of each fund and account. Non- investment factors, such as fee arrangements, are not considered in selecting clients or allocating trades. Equity Securities Within each equity investment division, if orders to purchase or sell the same security are open for more than one fund or account, executed trades are generally allocated pro rata to the funds and accounts based on the authorized order size for each fund and account at the time the trade is executed. Allocated amounts will be rounded to reflect the Advisers’ and market practices for lot sizes. All funds and accounts receive shares at the average price and pay a pro rata portion of all transaction costs. In addition, restrictions in client accounts, such as broker selection requirements, may require that a client’s order be traded separately. Client accounts that are traded separately from the aggregate order may receive a less favorable execution price than the accounts that are part of the aggregate order. 38  Certain clients have requested CB&T to direct a portion of their trades to a particular broker- dealer, subject to the CB&T’s duty to seek best execution. If the trader believes that best execution would not be harmed by directing the client’s trade to the requested broker-dealer, then the trade for that client may be removed from the block to place the trade with the requested broker-dealer. Additional equity authorizations. If an additional order to purchase or sell a security is placed after the trader has begun to work the initial orders, the Equity Trading Platform allocates executed trades to participating accounts based on the initial orders and then begins a new allocation process based on the remaining open orders and the new orders. Under certain circumstances, traders are given discretion to include orders they receive after the trader has started to work an initial order with the initial aggregated order for allocation purposes. This may occur for example when an analyst has issued a recommendation in the morning and not all managers have had the opportunity to hear the recommendation before the start of trading or an order for the same security is subject to additional compliance approvals. The traders have discretion to allocate on this basis when to do so will be fair and equitable to all participating client accounts. Special instructions. In certain circumstances, parts of an aggregated order may be subject to special portfolio manager instructions, such as a price limit, or other factors that do not apply to the entire aggregated order. This may result in an allocation other than pro rata to all accounts in the aggregated order. For example, trades executed above a price limit (in the case of purchases) or below the limit (in the case of sales) would be allocated on a pro rata basis only to orders that were not subject to the price limit. Occasionally when there is a relatively small remaining open order and a very large new order is placed, trading may complete the small order before proceeding with the larger new order, rather than aggregating the orders. Program and list trades. CB&T and its affiliates serve as investment adviser for certain accounts that are designed to be substantially similar to another account. This type of account will often generate a large number of relatively small trades when it is rebalanced to its reference fund due to differing cash flows or when the account is initially started up. CB&T may not aggregate program trades or electronic list trades executed as part of this process. Non-aggregated trades performed for these accounts will be allocated entirely to that account. This is done only when CB&T believes doing so will not have a material impact on the price or quality of other transactions. Minimum allocation size. Often, a single aggregated order is executed in a series of smaller transactions over a period of time. In those circumstances, some clients, particularly those that represent a small portion of an aggregated order, may incur significant trade ticket, custody and related fees due to multiple allocations. CB&T may observe a minimum transaction size per client account and allocate trades in a manner that seeks to reduce the transaction costs that clients may incur as a result of small allocations. These minimums may vary by client account in an effort to treat all clients fairly and equitably. 39  Initial Public Offerings Orders for initial public offerings of equity securities (“IPOs”) are allocated in the same manner as described above. The trading department aggregates authorized orders it receives for IPOs and places a block trade with the underwriting syndicate. If the resulting allocation we receive from the underwriting syndicate is not sufficient to fill all orders, each equity investment division generally allocates the transaction on a pro rata basis based on each account’s authorized order size, unless the relevant investment committee approves another allocation. In certain circumstances orders are placed based on approximate fund or account asset size; however, no fund or account will be allocated more than its indication. Allocations may be subject to CB&T’s and its affiliates market practices for lot sizes. If the allocation places some client accounts below the minimum lot size, then the trading department will exclude those accounts in the allocation process and allocate the remaining shares to other clients on a pro rata basis. Fixed-Income Securities In allocating trades to accounts, portfolio managers and analysts review client guidelines and consider a variety of other factors including: the other securities held in the account’s portfolio; the appropriateness of the security for the fund’s objective; the industry/sector, issue/issuer holdings, portfolio analytic data; the size of the account; the size of the confirmed, executed transaction; the invested position of the account; and the marketability of the security. Once a fixed-income trade has been executed and participating client accounts are identified, all accounts receive the same purchase price when participating in a block trade. All fixed-income trades are reviewed a final time after allocation and execution by the Fixed Income Compliance team against the compliance guidelines of the accounts. New Fixed-Income Issues Funds and accounts are selected to participate in new issuance of fixed-income securities in the same manner as described above. Orders are aggregated for new issues and a block order is placed with the lead arrangers or bookrunners. If the resulting allocation received from the arrangers is not sufficient to fill all orders, the trade is generally allocated on a pro rata basis based on each account’s authorized order size, unless the relevant investment committee approves another allocation methodology. Consideration may be given to the factors listed above. Allocations may be subject to CB&T’s and market practices for lot sizes. If the allocation places some client accounts below the minimum lot size, those accounts may not receive an allocation. 40  Forward Currency Exchange Transactions CB&T generally executes foreign currency transactions for funds or accounts over which it has investment discretion directly through broker-dealers; however, a fund's or account’s custodian may be used to execute certain foreign exchange transactions. These include transactions in markets with legal restrictions or operational risks that make executing directly in those markets impractical. Identification and Resolution of Trade Errors CB&T maintains policies and procedures that address the identification and remediation of trade errors. These policies and procedures are designed to address the resolution of errors and to provide appropriate oversight and review of such errors. To the extent a trade error occurs, CB&T seeks to identify and resolve such error in a manner that is fair to its clients as promptly as possible. When determining the loss associated with an error, CB&T will typically net gains and losses arising from a single error or a series, unless prohibited by applicable law or a specific agreement with the client. CB&T will address and resolve errors on a case-by-case basis, in its discretion, based on each error’s facts and circumstances. CB&T attempts to resolve similar trade errors in a consistent manner, although we may elect to compensate a client for a loss in certain circumstances where we believe it is not a compensable trade error. 41  ITEM 13: REVIEW OF ACCOUNTS Compliance teams monitor funds and accounts on an ongoing basis and perform periodic reviews. This monitoring and review is conducted to verify that funds and accounts are in compliance with their objectives and guidelines. In addition, certain portfolio data for funds and accounts is periodically reviewed by investment professionals, including portfolio managers. The Commingled Funds are reviewed at least annually by a Committee of the CB&T Board or its designee. The review generally includes, among other things, information related to investment results, significant fund guidelines, and the investment structure of the portfolio. In addition, compliance teams of the investment advisers to CB&T also conduct regular reviews to verify that overall positions are appropriately aligned relative to the funds’ objectives. Investors in pooled investment vehicles are provided periodic portfolio statements and such other reports as they are specifically requested from time to time. 42  ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION CB&T may compensate affiliates for client referrals, client relations and marketing services. CB&T’s affiliates may from time to time compensate eligible third parties for client referrals pursuant to a written solicitation agreement. At the time of solicitation, CB&T’s affiliates provide – either directly or through the solicitor – written disclosure to referred clients regarding the fee arrangement and any material conflicts of interest on the part of the solicitor with respect to their recommendation of CB&T’s affiliate resulting from the fee arrangement. Some of CB&T’s clients and prospective clients retain investment consultants to evaluate and recommend investment advisers and their services. CB&T may provide investment management services to these consultants or their affiliates. CB&T is not affiliated with an investment consultant business and has never paid to gain favor from consultants in terms of future or continuing new business opportunities. Many consultants offer valuable services to investment managers, and CB&T and its affiliates regularly subscribe to various consultant services to gain access to their index and peer data and occasionally participate in their conferences and training programs. In addition, from time to time, CB&T and its affiliates co-sponsor with other managers or consultants, industry events such as conferences. Also, CB&T and its affiliates purchase other products or services from certain consultants such as data feed transmission, electronic services and related software. 43  ITEM 15: CUSTODY Not applicable. 44  ITEM 16: INVESTMENT DISCRETION CB&T maintains Commingled Funds pursuant to their governing declarations of trust and engages other service providers, including affiliates, to assist in the administration and investment management of these funds. CB&T has retained the Advisers to each serve as investment adviser for the Commingled Funds. CB&T can also act as fiduciary with respect to a particular client’s assets transferred to CB&T for investment in the Commingled Funds, as directed by the client pursuant to an agreement. However, CB&T does not generally exercise discretion with regard to a particular client’s decision to invest in one or more Commingled Funds. 45  ITEM 17: VOTING CLIENT SECURITIES Capital Bank and Trust Company (the “Adviser”) accepts proxy voting authority from its clients and follows its Proxy Voting Procedures and Principles (the “Principles”), which are summarized below. If the Adviser has voting authority for a client account, it generally does not provide the client the option to direct a proxy vote with respect to a particular solicitation. Some clients reserve the right to vote proxies and do not give the Adviser the authority to vote on their behalf. In those cases, clients should contact their custodian about receiving proxies. The Adviser would not expect to discuss particular solicitations with clients for whom it does not have proxy voting authority. This summary of the Adviser’s Principles is qualified by the full policy. The Principles provide an important framework for analysis and decision-making by the Adviser. However, they are not exhaustive and do not address all potential issues. The Principles provide a certain amount of flexibility so that all relevant facts and circumstances can be considered in connection with every vote. As a result, each proxy received is voted on a case-by-case basis considering the specific circumstances of each proposal. The voting process reflects the Adviser’s understanding of the company’s business, its management and its relationship with shareholders over time. In all cases, long-term value creation the investment objectives and policies of the funds and accounts managed by the Adviser or its affiliates remain the focus. Voting Procedures The Adviser seeks to vote all U.S. proxies. Proxies for companies outside the U.S. also are voted where, there is sufficient time and information available, taking into account distinct market practices, regulations and laws, and types of proposals presented in each country. Where there is insufficient proxy and meeting agenda information available, the Adviser will generally vote against such proposals in the interest of encouraging improved disclosure for investors. The Adviser may not exercise its voting authority if voting would impose costs on clients, including opportunity costs. For example, certain regulators have granted investment limit relief to the Adviser and its affiliates, conditioned upon limiting voting power to specific voting ceilings. To comply with these voting ceilings, the Adviser will scale back its votes across all funds and accounts it manages on a pro rata basis based on assets. In addition, certain countries impose restrictions on the ability of shareholders to sell shares during the proxy solicitation period. The Adviser may choose, due to liquidity issues, not to expose the funds and accounts it manages to such restrictions and may not vote some (or all) shares. Finally, the Adviser may determine not to recall securities on loan to exercise its voting rights when it determines that the cost of doing so would exceed the benefits to clients or that the vote would not have a material impact on the investment. Proxies with respect to securities on loan through client-directed lending programs are not available to vote and therefore are not voted After a proxy statement is received, the Adviser’s stewardship and engagement team prepares a summary of the proposals contained in the proxy statement. Investment analysts are generally responsible for making voting recommendations for their investment division on significant 46  votes that relate to companies in their coverage areas. Analysts also have the opportunity to review initial recommendations made by the Adviser’s stewardship and engagement team. Depending on the vote recommendation, a second opinion may be made by a proxy coordinator (an investment professional with experience in corporate governance and proxy voting matters) within the appropriate investment division, based on knowledge of the Principles and familiarity with proxy-related issues. Each of the Adviser’s equity investment divisions has its own proxy voting committee, which is made up of investment professionals within each division. Each division’s proxy voting committee retains final authority for voting decisions made by such division. In cases where a fund or account is co-managed and a security is held by more than one of the Adviser’s equity investment divisions, the divisions may develop different voting recommendations for individual ballot proposals. If this occurs, and if permitted by local market conventions, the position will generally be voted proportionally by divisional holding, according to their respective decisions. Otherwise, the outcome will be determined by the equity investment division or divisions with the larger position in the security as of the record date for the shareholder meeting. In addition to its proprietary proxy voting, governance and executive compensation research, the Adviser may utilize research provided by third-party advisory firms on a case-by-case basis. It does not, as a policy, follow the voting recommendations provided by these firms. It periodically assesses the information provided by the advisory firms and reports to the applicable governance committees that provide oversight of the application of the Principles. Conflicts of Interest From time to time, the Adviser may vote proxies issued by, or on proposals sponsored or publicly supported by, (a) a client with substantial assets managed by the Adviser or its affiliates, (b) an entity with a significant business relationship with The Capital Group Companies, Inc. or its affiliates, or (c) a company with a director of a U.S. mutual fund or ETF on its board that is managed by the Adviser or its affiliates (each referred to as an “Interested Party”). Other persons or entities may also be deemed an Interested Party if facts or circumstances appear to give rise to a potential conflict. The Adviser has developed procedures to identify and address instances where a vote could appear to be influenced by such a relationship. Each equity investment division of the Adviser has a Special Review Committee (“SRC”) of senior investment professionals and legal and compliance professionals with oversight of potentially conflicted matters. If a potential conflict is identified according to the procedure above, the SRC will take appropriate steps to address the conflict of interest. These steps may include, engaging an independent, third-party to review the proxy and using the Principles to provide an independent voting recommendation to the Adviser for vote execution. The Adviser will generally follow the third party’s recommendation, except when it believes the recommendation is inconsistent with the Adviser’s fiduciary duty to its clients. Occasionally, it may not be feasible to engage the third party to review the matter due to compressed timeframes or other operational issues. In this case, 47  the SRC will take appropriate steps to address the conflict of interest, including reviewing the proxy after being provided with a summary of any relevant communications with the Interested Party, information on the organization’s relationship with the Interested Party and any other pertinent information. Proxy Voting Principles The below sets forth at a high level the general positions of the Adviser on various types of proposals. A copy of the full Principles is available upon request, free of charge, by visiting the Capital Group website (capitalgroup.com). Director matters — The election of a company’s slate of nominees for director generally is supported. Votes may be withheld for some or all of the nominees if this is determined to be in the best interest of shareholders or if, in the opinion of the Adviser, such nominee has not fulfilled his or her fiduciary duty. In making this determination, the Adviser considers, among other things, a nominee’s potential conflicts of interest, track record (whether in the current board seat or in previous executive or director roles) with respect to shareholder protection and value creation as well as their capacity for full engagement on board matters. The Adviser generally supports a breadth of experience and perspectives among board members, and the separation of the chairman and CEO positions. Governance provisions — Proposals to declassify a board (elect all directors annually) generally are typically supported based on the belief that this increases the directors’ sense of accountability to shareholders. Proposals for cumulative voting generally are supported in order to promote management and board accountability and an opportunity for leadership change. Proposals designed to make director elections more meaningful, either by requiring a majority vote or by requiring any director receiving more withhold votes than affirmative votes to tender his or her resignation, generally are supported. Shareholder rights — Proposals to repeal an existing poison pill generally are supported. (There may be certain circumstances, however, when a proxy voting committee or an investment division of the Adviser believes that a company needs to maintain anti-takeover protection). Proposals to eliminate the right of shareholders to act by written consent or to take away a shareholder’s right to call a special meeting typically are not supported. Compensation and benefit plans —Equity incentive plans are complicated, and many factors are considered in evaluating a plan. Each plan is evaluated based on protecting shareholder interests and a knowledge of the company and its management. Considerations include the pricing (or repricing) of options awarded under the plan and the impact of dilution on existing shareholders from past and future equity awards. Compensation packages should be structured to attract, motivate and retain existing employees and qualified directors; in addition, they should be aligned with the long-term success of the company and the enhancement of shareholder value. Routine matters — The ratification of auditors, procedural matters relating to the annual meeting and changes to company name are examples of items considered routine. Such items generally are voted in favor of management’s recommendations unless circumstances indicate 48  otherwise. Shareholder proposals on environmental and social issues — The Adviser believes environmental and social issues present investment risks and opportunities that can shape a company’s long-term financial sustainability. Shareholder proposals, including those relating to social and environmental issues, are evaluated in terms of their materiality to the company and its ability to generate long-term value in light of the company’s business model specific operating context. The Adviser generally supports transparency and standardized disclosure, particularly that which leverages existing regulatory reporting or industry best practices. With respect to environmental matters, this includes disclosures aligned with industry standards and reporting on sustainability issues that are material to investment analysis. With respect to social matters, the Adviser encourages companies to disclose the composition of the workforce in a regionally appropriate manner. The Adviser supports relevant reporting and disclosure that is consistent with broadly applicable standards Proxy Voting for Fund of Funds and Other Pooled Vehicles In cases where the underlying fund of an investing fund managed by the Adviser, including a fund of funds, holds a proxy vote, such vote is reviewed based on the procedures described above for potentially conflicted matters. 49  ITEM 18: FINANCIAL INFORMATION CB&T does not require or solicit pre-payment of investment advisory fees in advance. CB&T is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments. 50  ITEM 19: REQUIREMENTS FOR STATE-REGISTERED ADVISERS CB&T is not registered with any state securities authority. 51