J.P. Morgan Securities LLC

B. Administrative Proceedings Before Regulatory Authorities and Self-Regulatory Authorities .......................................................... 11 ITEM 10 — OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ............................................................................. 12 A. Broker-Dealer Registrations ....................................................... 12 B. Futures/Commodities-Related Registrations .............................. 12 C. Material Relationships with Related Persons and Potential FORM ADV PART 2A FIRM BROCHURE J.P. MORGAN SECURITIES DEFINED CONTRIBUTION PLAN CONSULTING SERVICES PROGRAM J.P. Morgan Securities LLC April 15, 2026 Conflicts of Interest .................................................................... 12 ITEM 11 — CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ............................... 13 A. Code of Ethics ............................................................................. 13 B. Securities in Which JPMS or a Related Person Has a Material Financial Interest ........................................................................ 13 C. When JPMS or a Related Person Invests in the Same Securities 270 Park Avenue New York, NY 10017 (800) 392-5749 That It Recommends ..................................................................... 14 SEC File No. 801-3702 jpmorgan.com/adv D. When JPMS or a Related Person Buys/Sells Securities for Itself at or About the Same Time It Recommends the Same Securities to/for Clients................................................................................. 14 ITEM 12 — BROKERAGE PRACTICES .................................................. 14 ITEM 13 — REVIEW OF ACCOUNTS ..................................................... 14 ITEM 14 — CLIENT REFERRALS AND OTHER COMPENSATION .......... 15 A. Economic Benefits for Providing Services to Clients ..................... 15 B. Compensation to Non-Supervised Persons for Client Referrals .... 15 ITEM 15 — CUSTODY .......................................................................... 15 ITEM 16 — INVESTMENT DISCRETION ............................................... 15 ITEM 17 — VOTING CLIENT SECURITIES ............................................ 15 ITEM 18 — FINANCIAL INFORMATION ............................................... 15 This investment advisory brochure (Brochure) provides information about the qualifications and business practices of J.P. Morgan Securities LLC (JPMS or the Firm) and the Defined Contribution (DC) Plan Consulting Services Program (the Program). Notwithstanding the reference to Defined Contribution plans, this Program is also available to eligible Non-Qualified Deferred Compensation plans. If you have any questions about the contents of this Brochure, contact us at (800) 392-5749. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. ITEM 4 — ADVISORY BUSINESS A. Description of Advisory Firm Additional information about JPMS is also available on the SEC’s website at adviserinfo.sec.gov. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. ITEM 2 — MATERIAL CHANGES This section describes the material and other changes to this Brochure since the last amendment dated March 27, 2026. Item 4, 5 and 7 have been updated to reflect that Plans structured as a multiple employer retirement plan (MEP) or pooled employer retirement plan (PEP) can receive Program services. ITEM 3 — TABLE OF CONTENTS JPMS is a wholly owned subsidiary of JPMorgan Chase & Co. (JPMC), a publicly held financial services holding company. JPMC and its affiliates (together, J.P. Morgan) are engaged in a large number of financial businesses worldwide, including banking, asset management, securities brokerage, and investment advisory services. JPMS is registered as a broker-dealer and investment adviser with the SEC and is a member of the investment Financial Industry Regulatory Authority (FINRA). JPMS’ advisory services include sponsoring a variety of advisory programs, including wrap fee programs, and providing certain consulting services to defined contribution plan sponsors. JPMS offers investment advisory services through several separate sales channels. ITEM 4 — ADVISORY BUSINESS ............................................................ 1 A. Description of Advisory Firm......................................................... 1 B. Description of Advisory Services ................................................... 2 C. Availability of Customized Services ............................................... 5 D. Wrap Fee Program ........................................................................ 5 E. Assets Under Management ........................................................... 5 ITEM 5 — FEES AND COMPENSATION .................................................. 5 A. JPMS Compensation and Fees ....................................................... 5 B. Billing of Fees ............................................................................... 5 C. Other Fees and Expenses .............................................................. 5 D. Advance Payment of Fee............................................................... 5 Financial Advisors Compensation ................................................. 5 E. ITEM 6 — PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................................................. 6 ITEM 7 — TYPES OF CLIENTS ................................................................ 6 ITEM 8 — METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS ............................................................................... 6 A. Methods of Analysis and Investment Strategies ............................. 6 B. Material, Significant, or Unusual Risks Associated with Certain This Brochure provides information about JPMS and the Program that is made available through a JPMS Private Client Advisor or a Wealth Advisor (collectively, Financial Advisors and each, a Financial Advisor), each a representative of JPMS. Information about other investment advisory services that JPMS provides is contained in separate brochures, which can be obtained from your Financial Advisor or at the SEC’s website at adviserinfo.sec.gov. separate website, JPMS also maintains a chase.com/managed-account-disclosures for clients of Private Client Advisors, and jpmorgan.com/adv for Wealth Advisor clients. These sites contain the Brochure for the Program, wrap fee programs brochures, and other important disclosures, including advisory brochures for J.P. Morgan Private Investments Inc. (JPMPI). For purposes of this Brochure, “Plan” refers to the defined contribution plan (DC Plan, which may be structured as a single employer retirement plan, a MEP or a PEP) or the non-qualified deferred compensation plan (NQDC Plan, and collectively with DC Plans, Plans), and “Client” refers to the DC Plan sponsor or employer establishing the NQDC Plan, as named in the Client Agreement (as defined below). For DC Plans, the Client may act, as applicable, as the Plan sponsor and/or named fiduciary of a single employer retirement plan or MEP or as the pooled plan provider of a PEP. Investments in the Program............................................................ 7 C. Risks Associated with Particular Types of Securities .................... 11 ITEM 9 — DISCIPLINARY INFORMATION ........................................... 11 A. Criminal or Civil Proceedings ....................................................... 11 INVESTMENT AND INSURANCE PRODUCTS ARE: • NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, JPMORGAN CHASE BANK, N.A. OR ANY OF ITS AFFILIATES • SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED 33817_COL 04-15-2026 Page 1 of 15  1. Plan Advisor Services Investing in securities involves risk of loss that Clients should be prepared to bear. The investment performance and success of any particular investment cannot be predicted or guaranteed, and the value of a Client’s investments will fluctuate due to market conditions and other factors. Investments are subject to various risks, including, but not limited to market, liquidity, currency, economic and political risks, and will not necessarily be profitable. Past performance of investments is not indicative of future performance. B. Description of Advisory Services When providing DC Plan Advisor Services, JPMS will acknowledge in the applicable Client Agreement its status as a “fiduciary” under Section 3(21)(A)(ii) of ERISA for any “investment advice” (as defined by ERISA) JPMS provides under the Client Agreement. For both ERISA and NQDC Plans, the Client retains and exercises final decision-making authority and responsibility for all matters concerning the Plan as well as implementation of any investment advice resulting from the Plan Advisor Services provided pursuant to the Client Agreement. Neither JPMS nor its Wealth Advisors will (1) manage or exercise any investment discretion or control over the Plan’s assets; (2) be responsible or liable, to the extent permitted by law, for the performance of any investment option recommended by JPMS or a Wealth Advisor and selected by the Client, a Plan fiduciary, or a Plan official; or (3) be responsible or liable for any decisions made with respect to a Plan where such decisions differ from a specific recommendation made by JPMS or a Wealth Advisor to the Client or where the recommendation is based on information about the Plan or its participants that is either incorrect or has not been updated by the Client. Plan Advisor Services include: Within the Program, JPMS offers two types of investment advisory offerings: (1) non-discretionary advisory services (Plan Advisor Services), whereby JPMS provides investment advice with respect to Plans, which include DC Plan Advisor Services and NQDC Plan Advisor Services; and (2) discretionary investment management services (Plan Manager Services), which include DC Plan Manager Services, NQDC Plan Manager Services, and “Custom Plan Manager Services,” which in turn includes Custom 3(38) DC Plan Manager Services and Custom NQDC Plan Manager Services. Only DC Plan Manager Services and Custom 3(38) DC Plan Manager Services are available for MEPs or PEPs. When providing Plan Advisor Services or Plan Manager Services to DC Plans subject to Title I of the Employee Retirement Income Security Act of 1974, as amended (ERISA) (ERISA Plans), JPMS will act as a “fiduciary” (as defined in Section 3(21)(A) of ERISA) to such ERISA Plans and, when providing Plan Manager Services to ERISA Plans, as an “investment manager” (as defined in Section 3(38) of ERISA) to such ERISA Plans. • Plan Investment Menu Design. Wealth Advisors and/or JPMS make recommendations related to the initial or existing Plan investment menu design, including structure, asset classes, investment style and investment expenses, based on information provided by the Plan sponsor about the Plan’s investment objectives, guidelines, and restrictions or similar information. Wealth Advisors also assist the Client in the ongoing review of the Plan investment menu design to determine whether it continues to meet the needs of the Plan and its participants. • The terms Plan Advisor Services and Plan Manager Services shall be understood to include services provided by JPMS to both ERISA Plans and NQDC Plans, which are not intended to be qualified under Section 401(a) of the Internal Revenue Code of 1986, as amended, nor generally subject to ERISA (other than certain minimal reporting and disclosure requirements and certain provisions regarding enforcement and preemption). The terms DC Plan Advisor Services and DC Plan Manager Services shall also be understood to include such services provided by JPMS to ERISA Plans. Plan Manager Services and Plan Advisor Services are available through Wealth Advisors. Plan Manager Services are also offered through Private Client Advisors. JPMS also offers additional services to Clients (collectively, Plan-Related Services). These include (1) searches for recordkeeping platform providers (each, a Recordkeeper); (2) coordination of and/or delivery of education services; (3) a review of Recordkeeper features, services and non- investment related fees; (4) for ERISA Plans, plan fee benchmarking reporting; and (5) for Custom 3(38) DC Plan Manager, Custom NQDC Plan Manager, NQDC Plan Advisor and DC Plan Advisor Services plans generally over $25 million, monitoring on investment criteria. JPMS does not act as an investment adviser or a fiduciary in providing Plan-Related Services. Plan Advisor Services, Plan Manager Services, and Plan-Related Services (collectively, Plan Services) are described in more detail below. Investment Searches. Wealth Advisors and/or JPMS recommend certain investment options for inclusion in the Plan’s investment menu based on information provided by the Client about the Plan’s investment objectives, guidelines, and restrictions or similar information. Wealth Advisors and/or JPMS only recommend investment options that JPMS and its affiliates, including JPMPI (specifically, the manager solutions due diligence group in the J.P. Morgan Wealth Management division), or a third-party vendor retained by JPMS have reviewed and are available on the Plan Recordkeeper’s platform. Wealth Advisors and/or JPMS do not recommend or otherwise provide advice on investment options issued, sponsored, or advised by J.P. Morgan or any of its affiliates (Affiliated Products) (as discussed in more detail in Item 4.B Affiliated Funds). If Affiliated Products exist in the Plan’s investment menu when receiving Plan Advisor Services, the Client agrees that (1) neither JPMS nor its affiliates acts in a fiduciary capacity under ERISA or any other state or federal law with respect to the Client’s decision to maintain Affiliated Products and does not recommend or otherwise provide advice about the Affiliated Products and (2) the terms of the Client Agreement does not cover Affiliated Products. When receiving Plan Advisor services, the determination as to the appropriate investment share class or investment tier for inclusion in the Plan is solely the Client’s responsibility. The Client is not obligated to implement the non-discretionary investment advice provided by the Wealth Advisor and/or JPMS. • Periodic Review of Plan Investment Options Performance. Clients receive a review of the performance of Plan investment options. Refer to “Methods of Analysis, Investment Strategies, and Risk of Loss” in Item 8 for information on the due diligence process utilized. 2. Plan Manager Services The specific Plan Services being provided are agreed to by the Client and JPMS in the J.P. Morgan Securities Defined Contribution Plan Consulting Services Program Client Agreement (the Client Agreement). JPMS provides Plan Services only for the Plan specifically referenced in the Client Agreement and not for any other clients, assets, accounts or employers participating in the Plan (Participating Employers), unless otherwise separately agreed to by JPMS in writing. JPMS’ relationship with Clients becomes effective as detailed in the applicable Client Agreement. Any preliminary discussions that take place between the Client and/or any Participating Employer and JPMS before the Client Agreement is effective are not intended, and should not be relied upon, as investment or other fiduciary advice. With respect to ERISA Plans, JPMS acknowledges in the applicable Client Agreement its status as a “fiduciary” under Section 3(21)(A)(i) of ERISA, and the Client appoints and JPMS accepts appointment as an investment manager under Section 3(38) of ERISA for the DC Plan Manager Services JPMS provides under the Client Agreement. 33817_COL 04-15-2026 Page 2 of 15  Services are limited. For Custom, flexibility is available within defined parameters set by JPMS. Eligible Wealth Advisors can provide qualifying Clients flexibility within Plan Manager Services (Custom Plan Manager Services, also referred to as “Custom”). This flexibility includes Recordkeeper availability, Plan investment menu design, and optional investment monitoring criteria. Periodic Review of Plan Investment Options Performance. Clients receive a review of the performance of Plan investment options. Refer to “Methods of Analysis, Investment Strategies, and Risk of Loss” in Item 8 for information on the due diligence process utilized. 3. Plan-Related Services For both ERISA and NQDC Plans, JPMS is not (1) responsible or liable, to the extent permitted by law, for the performance of any investment option selected by JPMS; nor (2) responsible or liable for any decisions made with respect to a Plan based on information about the Plan, its participants or Participating Employers that is either incorrect or has not been updated by the Client. Clients enrolled in the Program can choose to receive certain non-fiduciary Plan-Related Services described in more detail below. Plan Investment Menu Design. JPMS has discretion for the Plan investment menu design, including structure, asset classes, investment style, and investment expenses. JPMS determines the mutual funds and exchange traded funds (Funds) to be used to construct plan investment menus as well as performs ongoing reviews and monitoring of the Funds and investment menus using due diligence produced by the manager solutions team of JPMPI or any of its affiliates. • Searches for Recordkeepers. This service involves evaluating the Plan’s current Recordkeeper, applying criteria to select Recordkeepers, coordinating the solicitation of quotes from Recordkeepers, issuing requests for proposals (RFPs) on behalf of Clients, and evaluating RFPs received from prospective Recordkeepers. Searches may be customized based on the needs of the Plan as identified by the Plan sponsor. Clients receiving Plan Manager Services are limited to certain Recordkeepers, as discussed in Item 4.B Recordkeeper Restrictions. Selection of the recordkeeper and underlying funding platform is the responsibility of the Client. Under Custom, JPMS has discretion over the Plan investment menu design, and the available investment options will be those reviewed by the manager solutions team of JPMPI or any of its affiliates or by a third-party vendor retained by JPMS. The manager solutions team of JPMPI or any of its affiliates and the third-party vendor retained by JPMS provide ongoing reviews and monitoring of the Funds but do not recommend the specific Funds or allocations to be used to construct plan investment menus. Rather, custom investment options and menus are selected by the Client’s Wealth Advisor consistent with JPMS’ investment menu structure guidelines regarding number of investment options and asset class requirements. share • Coordination and/or Delivery of Education Services. Financial Advisors provide Plan sponsors, and Plan participants with educational services. Financial Advisors can review the Plan’s current education program and suggest strategies for improving education. Financial Advisors can provide ERISA Plan sponsors with general education around Investment Policy Statements (IPS) and Qualified Default Investment Alternatives (QDIA), work with the Plan’s Recordkeeper to implement education program changes and deliver materials to Plan sponsors and participants. Financial Advisors can also provide investment education, including seminars, educational newsletters, and other materials reviewed and approved by JPMS. Upon a Client’s request and as appropriate for a particular Plan, Financial Advisors may provide employee education seminars to cover subjects that include investing, saving for retirement, and retirement and distribution planning, as well as other subjects that JPMS makes available. JPMS intends for all of its communication to Plan sponsors and participants, including education and employee education seminars, to be investment education under applicable U.S. Department of Labor regulations or other guidance. Neither JPMS nor its Financial Advisors provide Plan participants with individual investment advice. • Review of Recordkeeper Features, Services, and Fees. JPMS assists Clients with conducting and/or coordinating a review of the Recordkeeper features, services, and various fees and expenses. JPMS assists with and/or facilitates the delivery of information necessary for the Client to review and analyze Recordkeeping features, services, and fees. In performing these reviews and providing reports, JPMS relies on information provided by the Client and the Plan’s Recordkeeper, custodian and/or other third parties from whom JPMS receives Plan and investment-level data (each, a Data Provider). JPMS cannot guarantee the accuracy of information provided by the Client or Data Provider. • Plan Fee Benchmarking Reporting. For ERISA Plans, JPMS makes available to Clients the delivery of plan fee benchmarking information for the Client to review and analyze their plan’s fees. Fee Benchmarking reports provided by JPMS will rely on information provided by the Client and the Plan’s Recordkeeper, custodian and/or other third parties from whom JPMS receives benchmarking services. JPMS cannot guarantee the accuracy of information provided by these sources and does not verify such information. • Investment Monitoring Criteria (Custom and Plan Advisor Services only). JPMS makes available to Clients monitoring on investment criteria. Monitoring is done through a third-party vendor retained by JPMS. Investment monitoring criteria is limited to those metrics that are made available by the third-party vendor. Client shall be Investment Selection, Review, and Replacement. JPMS has discretion over the search for, and the selection, review, and replacement of, investment options on the Plan’s investment menu. JPMS generally uses the lowest cost share class available on the Recordkeeper’s platform for the investment options selected (generally, shares with zero revenue or institutional classes or equivalents). Financial Advisors’ compensation is not affected by the share class selected. By appointing JPMS as Investment Manager, Clients acknowledge, represent and warrant that JPM will be the only investment manager for the Plan with discretion over the search for and the selection, review and replacement of investment options on the Plan’s investment menu for the duration of the Agreement. Clients authorize JPMS to take any and all actions necessary to implement changes to the Plan’s investment menu, including directing the Plan’s Recordkeeper to implement such changes. Clients are required to execute any forms required by the Recordkeeper to authorize JPMS, as Investment Manager, to direct the Recordkeeper with respect to the changes to the investment menu so that the Plan’s Recordkeeper are required to implement such changes. JPMS will only select investment options that JPMS and its affiliates (including the manager solutions team of JPMPI or any of its affiliates) or a third-party vendor retained by JPMS have reviewed and that are available on the Plan Recordkeeper’s platform. JPMS will not select or use, or otherwise provide any advice on, Affiliated Products (as discussed in more detail in Item 4.B Affiliated Products), even where Affiliated Products are available on the Plan Recordkeeper’s platform. If the Plan’s investment menu includes Affiliated Products, JPMS will direct the sale, redemption, or replacement of the Affiliated Products within a reasonable time. JPMS does not assume any fiduciary duty or other obligations for Affiliated Products during the time they are part of the investment menu or while being sold, redeemed, or replaced. When providing Plan Manager Services, JPMS chooses a menu of investment options that are broadly appropriate for inclusion within participant- directed retirement plans or as notional investment options for NQDC Plans. The structure of the menu and the individual investment options selected by JPMS applies to all Clients receiving Plan Manager Services based upon the specific Recordkeeper platform and is not customized for any Plan, except for Custom. Based on certain Recordkeeper constraints, the universe of Recordkeepers available to Clients receiving Plan Manager 33817_COL 04-15-2026 Page 3 of 15  responsible for selection and review of investment monitoring criteria for the Plan. No assurance has been or can be given that the investment objectives reflected in your investment criteria will be achieved. JPMS will rely on information provided by the Client and the Plan’s Recordkeeper, custodian and/or other third parties and cannot guarantee the accuracy of information provided by these sources and does not verify such information. 4. Limitations on Plan Services custom funds; investment options that JPMS, its affiliates (including the manager solutions team of JPMPI or any of its affiliates) or a third-party vendor retained by JPMS have not reviewed; and any other assets JPMS designates as Excluded Assets. With respect to ERISA Plans, JPMS will not advise on whether Clients should offer or continue to offer employer securities, within the meaning of Section 407 of ERISA, as an investment option under the Plan. JPMS may designate assets as Excluded Assets without notice to the Client. JPMS will neither provide advice with respect to Excluded Assets nor include Excluded Assets in the calculation of the Fee (as defined in Item 5). Plan Services are subject to certain limitations, including: • Legal, Accounting, and Tax Advice. JPMS and its affiliates do not provide legal, accounting, or tax advice and will not be responsible for ensuring that a Plan’s IPS or any other Plan documents comply with ERISA, state, or local law or any other regulations or requirements applicable to the Plan. The Client is responsible for those matters and should consult with their legal, accounting, or tax professional(s) about them. • Universe of Investment Options. JPMS and/or the Wealth Advisor will only recommend or select investment options that JPMS and its affiliates (specifically the manager solutions team of JPMPI or any of its affiliates) or the third-party vendor retained by JPMS (to provide investment analysis and due diligence for certain investment options not reviewed by the manager solutions team of JPMPI or any of its affiliates) have approved and that are available on the Plan Recordkeeper’s platform. JPMS does not review every investment option available, or every asset class or investment category, nor every investment option that can be made available on the Recordkeeper’s platform. • Plan Actuarial, Administrative, and Recordkeeping Services. JPMS and its affiliates do not provide actuarial, administrative, or recordkeeping services to Plans in the Program (including, but not limited to, prospectus delivery and participant notices). • • Participant Communications. JPMS and its affiliates do not provide notices to participants and/or Participating Employers. Participants and/or Participating Employers can access the prospectus for a particular Fund via either the Fund family website or the recordkeeper’s website. • Investment Policy Statements. For Clients receiving Plan Advisor or Custom Services, upon Client request, JPMS will provide Clients with a sample of an investment policy statement. Clients are encouraged to consult with their legal or tax professional(s) prior to adopting and/or approving any investment policy statement(s). JPMS does not assume any obligation to comply with, accept or update a Client’s investment policy statement(s). For Clients receiving Plan Manager Services, upon Client request, JPMS will provide Clients with a “Program–Level Investment Policy Statement” that describes the investment process JPMS adheres to when providing Plan Manager Services. • Retirement Income Options. JPMS does not select or review “retirement income” products, including, but not limited to, managed payout funds, systematic withdrawal programs, and insurance-based annuity options. Information Provided by Clients. JPMS will rely on information provided by Clients without further verification. Clients are responsible for notifying JPMS promptly, in writing, of any changes to the information that the Client previously provided to JPMS and for providing JPMS with additional information as JPMS may request from time to time. Clients must notify JPMS promptly of any material changes in the Plan’s financial condition, risk tolerance, needs, or objectives. JPMS has no liability for a Client’s failure to provide JPMS with accurate or complete information or to inform JPMS promptly of any change in information previously provided. the Client requests otherwise, • Third-Party Information. JPMS relies on third-party information, including publicly available information and information received from Data Providers, in providing the Plan Services. While JPMS believes the information is accurate, JPMS does not independently verify or guarantee the accuracy of the information. • Recordkeeper Restrictions. For Plan Manager Services, Clients are limited to selecting a Recordkeeper with whom JPMS makes Plan Manager Services available. For Plan Advisor Services and Custom, unless JPMS only presents Recordkeeping providers who have been evaluated by JPMS. If requested by Clients, JPMS in its discretion can present Recordkeeping providers not evaluated by JPMS. Ultimate decision as to Recordkeeper selection rests with the Plan sponsor. 5. Termination • Broker of Record. Neither JPMS nor any Financial Advisor may be listed as broker of record for any of the investment options the Client or JPMS selects for the Plan’s investment menu for purposes of receiving Rule 12b-1 fees or other compensation directly from the Plan’s investment options. The Client agreement may be terminated at will by either party. Termination will be effective upon the later of: receipt of written notice of termination or removal of JPMS as advisor record by the Recordkeeper. Termination of the Client agreement will not affect the liabilities or obligations of the parties under the Client agreement that arise prior to termination. Upon termination, JPMS has no further obligation to provide investment advice or other Plan Services to the Client or any Plan fiduciary about the Plan’s assets. 6. Financial Advisors • Affiliated Products. JPMS will not recommend, select, use, or otherwise provide advice on Affiliated Products. Recommending, selecting, using or otherwise providing advice on Affiliated Products raises a conflict of interest because J.P. Morgan and its affiliates, including JPMS, receives more total revenue when a Client’s account is invested in Affiliated Products than when it is invested in unaffiliated third-party products. JPMS will include information on Affiliated Products in periodic investment reports, which the Client agrees is not investment advice or a fiduciary act of JPMS. As described below, JPMS will exclude the value of the Plan’s investments in Affiliated Products when calculating the Fee (as defined in Item 5). Financial Advisors who provide Plan Services are registered representatives and investment adviser representatives. Financial Advisors who provide Plan Services receive training on the Program, Program guidelines and policies, and other information essential to advising Program clients. Wealth Advisors may also complete third-party specialized training, such as the Accredited Investment Fiduciary® (AIF®). Upon completion of the training, Wealth Advisors are required to pass an assessment that demonstrates proficiency. The timeframe to meet these requirements may be extended under certain circumstances, including for newly hired Wealth Advisors. JPMS is not bound by the standards of conduct • Excluded Assets. Excluded Assets include, but are not limited to, Affiliated Products; employer securities; in-Plan retirement income options; self-directed brokerage accounts; participant loan balances; 33817_COL 04-15-2026 Page 4 of 15  of any professional organizations of which its Financial Advisors are members or entities that have authorized Financial Advisors to use designations or certifications. C. Availability of Customized Services based on the net market value of the Plan’s assets (less any Excluded Assets) on the last day of the relevant billing period. JPMS will rely on the value of the Plan’s assets provided by the Data Provider when calculating the Fee. Upon request, JPMS will provide an annual statement that details the amount of Fees the Client has paid to JPMS. Refer to Item 4.B. above for details on how JPMS advisory services can be tailored to the individual needs of Clients. The Fee applicable to the delivery of Plan Services will not be tied to or adjusted for any other services or investment programs the Client or any Participating Employer may be invested in with JPMS or its affiliates. D. Wrap Fee Program JPMS is the sponsor of several wrap fee programs; however, the Program is not a wrap fee program. In a wrap fee program, clients pay JPMS a single fee based on the assets they have invested with them. The fee covers investment advisory services and other account-related services, such as trade execution, clearing and settlement services, reporting, and custody services as well as financial planning, when applicable. E. Assets Under Management As of December 31, 2025, JPMS managed $358,295,849,690 on a discretionary basis and $71,398,641,352 on a non-discretionary basis. In its discretion, JPMS may negotiate the amount and calculation of the Fee, based on a number of factors, including (1) the type and size of the Plan; (2) the number and types of Plan Services selected; (3) the scope of the engagement; (4) the complexity of the Plan Services to be provided and any preferences stated by Plan fiduciaries; (5) the nature and amount of investment options involved; and (6) the frequency with which certain Plan Services are provided (e.g., on-site participant education meetings). The Fee charged to a Client may be higher or lower than (1) the Fee charged to other Clients for similar Plan Services and (2) the cost of similar services offered through other financial firms. The Fee to be charged to each Client is specified in the Client Agreement. ITEM 5 — FEES AND COMPENSATION C. Other Fees and Expenses JPMS Compensation and Fees A. Clients in the Program pay either a flat dollar fee or an asset-based fee calculated as a percentage of Plan assets (not including Excluded Assets) for which JPMS provides Plan Services (the Fee). For all new Clients in the Program on or after April 1, 2025, the minimum annual Fee is $5,000. The Fee does not cover transaction-based charges; commissions or other charges the Plan, Plan participants or Participating Employers may incur in implementing any investment advice that JPMS provides; certain costs or charges that may be imposed by JPMS or third parties, including account maintenance fees, recordkeeping fees, trust fees, plan administration fees, or custody fees imposed by other financial institutions; any other services, accounts, or products that JPMS provides to the Client apart from, or in addition to, the Plan Services as agreed upon in the Client Agreement; costs relating to trading in foreign securities; mutual fund redemption fees; or any other fees or expenses incurred by the Client. The maximum asset-based Fee that may be charged to Clients in the Program, expressed as an annual rate, is 1.00% for Plans with assets equal to or above $1,000,000 (not including Excluded Assets). For Plans with assets below $1,000,000 (not including Excluded Assets), the maximum Fee that may be charged to Clients is $10,000. The agreed-upon asset- based Fee must be a fixed percentage. JPMS may recommend that the Client include investment options as part of the Plan’s investment menu that have various internal fees and expenses, which are paid by such Funds but ultimately are borne by the Client as Fund shareholder. These internal fees and expenses are in addition to the Fee JPMS receives from the Client, and the Client is not entitled to any refund of the Funds’ internal fees and expenses ultimately borne by the Client or other offset against the Fee. U.S. Department of Labor regulations under Section 408(b)(2) of ERISA require JPMS to provide specified information regarding the Plan Services provided in the Program to ERISA Plans and the compensation that JPMS and its affiliates expect to receive in connection with those Plan Services. For purposes of meeting this requirement, the information in this Brochure is intended to be read in conjunction with the Client Agreement, as it may be amended or supplemented from time to time. JPMS and its affiliates may provide other services to the Client outside of the Program. Under such circumstances, the Client should also refer to the fee disclosures that the Client may receive from JPMS or its affiliates regarding those other services, including the JPMS 408(b)(2) disclosure, which is available upon request. B. Billing of Fees The Fee and the specific Plan Services are agreed upon in the Client Agreement. JPMS invoices Clients or the Plan’s Recordkeeper/custodian for the Plan Services provided or receives payment directly from the Recordkeeper/custodian, as agreed to in the Client Agreement. Although JPMS neither provides investment advice nor charges the Fee on Plan assets invested in Affiliated Products, JPMS and its affiliates receive other compensation from affiliated Funds included by the Plan in its investment menu. This other compensation may be attributable to investment management fees paid by certain Funds to affiliates of JPMS acting as the Funds’ portfolio managers; distribution fees paid by certain Funds to JPMS and its affiliates pursuant to Rule 12b-1 under the Investment Company Act of 1940, as amended; and non-Rule 12b-1 compensation (including revenue sharing, shareholder servicing fees and licensing fees for the use by a Fund of a JPMorgan index) from certain Funds, to the extent permitted by applicable law. JPMS will not accept 12b- 1 fees, transaction-based compensation, finder’s fees, or other revenue directly from the unaffiliated investment options offered by the Plan. Each Client should review the applicable prospectuses for Funds in the Plan’s investment menu for additional information about the internal fees and expenses ultimately borne by investors in the Funds. D. Advance Payment of Fee Fees are not paid in advance. Refer to Item 5.B. above. E. Financial Advisors Compensation JPMS typically pays a portion of the Fee it receives from each Client in the Program to the Financial Advisor for that Client. Certain Financial Advisors who do not receive compensation based an annual revenue production receive an annual salary and bonus payment, whereas other Financial Advisors receive a portion of the Fee paid to JPMS. For those Financial Fees are payable in arrears, no less frequently than on a calendar quarter basis, unless otherwise agreed to by JPMS. The Fee for the first billing period is prorated from either the date on which the Client Agreement becomes effective or as otherwise determined by JPMS. The Fee due for the billing period in which the Client Agreement is terminated will be prorated up until termination date or as otherwise determined by JPMS. For Clients that pay a flat dollar Fee, the Fee is billed in equal installments (generally no less frequently than quarterly) for the initial billing period, and for the billing period in which the Client Agreement is terminated, the Fee is prorated if applicable. For Clients that pay an asset-based Fee, the rate used for calculating the amount due is approximately one-fourth of the applicable annual rate based on the number of days in the quarter (or, if billed monthly, the rate used each month is approximately one-twelfth of the applicable annual rate based on the number of days in the month) and 33817_COL 04-15-2026 Page 5 of 15  Advisors that receive a portion of the Fee, the exact portion of the fee paid to the Financial Advisor varies among Financial Advisors and can also depend upon the overall revenue production of each Financial Advisor but is most commonly within a range from 22% to 50%. The type of compensation paid to IARs does not result in a change to a Client’s Fee schedule. ITEM 6 — PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT apply all factors equally to each Fund in the search universe. The manager solutions team of JPMPI or any of its affiliates will begin the search process by defining an applicable universe of Funds for a desired asset class. The manager solutions team of JPMPI or any of its affiliates utilizes both quantitative and qualitative assessments during its initial review process. The manager solutions team of JPMPI or any of its affiliates then recommends particular Funds to an internal governance forum, which is responsible for approving or rejecting them. The manager solutions team of JPMPI or any of its affiliates is also responsible for monitoring and re- evaluating approved Funds as part of its ongoing review process. Neither JPMS nor any of its supervised persons currently accepts performance-based fees in connection with the Program. ITEM 7 — TYPES OF CLIENTS JPMS makes the Program available to the sponsors of participant-directed including single employer defined contribution retirement plans, retirement plans, MEPs and PEPs, and employers establishing NQDC Plans. There is no minimum asset requirement for participation in the Program. For ERISA Plans, Clients, and (if applicable) not the Participating Employers in the Plan, must have the power and authority to designate and effectuate investment alternatives under the terms of the Plan and, as applicable, be a “named fiduciary” (as defined in Section 402(a) of ERISA) of the Plan. With respect to a PEP, the Client represents and warrants that they are the pooled plan provider of the PEP within the meaning of Section 3(44) of ERISA and Section 413(e) of the Code. Where the Client is the pooled plan provider of the Plan, the Client represents and warrants that it has duly registered with the U.S. Department of Labor and that such registration was and remains timely and accurate. For all Plans, Clients must have the power and authority to enter into contractual arrangements with third parties on behalf of the Plan. For MEPs and PEPs, the Client must have authority to engage JPMS on behalf of the Plan and, if applicable, Participating Employers. The Client will be responsible for obtaining any Participating Employer consents required to enter into and perform under the Client Agreement (including with respect to onboarding new Participating Employers) and for maintaining such consents for the term of the Client Agreement and thereafter as required by applicable law. Centralized Due Diligence. The manager solutions team of JPMPI or any of its affiliates provides two types of research on Funds and investment strategies (collectively, Researched Products) on an ongoing basis. For certain investment advisory programs, the manager solutions team of JPMPI or any of its affiliates utilizes a qualitative analysis of the Researched Products by reviewing the organization, investment process, investment philosophy, and performance of the Researched Products on an ongoing basis (the Qualitative Research Process). Additionally, the manager solutions team of JPMPI or any of its affiliates uses an internally developed quantitative screening process to evaluate the Researched Products that do not go through the Qualitative Research Process by reviewing the organization, investment process, service, and performance of the Researched Products on an ongoing basis (the Systematic Research Process). Researched Products may be removed from an investment advisory program if it is determined that they do not meet the criteria set forth in the Systematic Research Process. However, in the event a Researched Product does not pass the Systematic Research Process, the manager solutions team of JPMPI or any of its affiliates can review the Research Product and apply the Qualitative Research Process to determine if the Researched Product is eligible. Additionally, if a Researched Product does not meet the criteria of the Qualitative Research Process, it is removed from investment advisory programs that utilize the Systematic Research Process. The DC Consulting Program utilizes the Systematic Research Process. As part of the due diligence process, the manager solutions team of JPMPI or any of its affiliates applies an ESG eligibility framework that establishes minimum criteria for determining the universe of Funds and strategies to be considered for inclusion in ESG strategies. ITEM 8 — METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS A. Methods of Analysis and Investment Strategies Initial Fund and Investment Strategy Review and Approval. The internal governance forum approves or rejects new Funds to be made available for recommendation in the Program. There can be Funds that are not available in the Program but that are available in programs advised by JPMPI or its affiliates. The manager solutions and operational due diligence teams of JPMPI or any of its affiliates provide a formal presentation on prospective managed strategies to the governance forum for review. The internal governance forum is expected to consider factors in its review and approval process including, but are not limited to: (a) an analysis of the manager’s overall investment opportunity, (b) investment thesis, (c) track record, (d) performance, (e) terms of the vehicle, (f) reputational risk, (g) potential for conflicts of interest, and (h) regulatory issues. Set forth below is a general description of the primary methods of analysis that JPMS utilizes for the Program. In connection with investments in a Fund, the description is qualified in its entirety by the information included in the applicable Fund’s prospectus or other relevant offering documentation and/or the applicable investment adviser’s Form ADV disclosure brochures. JPMS and the manager solutions team of JPMPI or any of its affiliates are not responsible for the performance of any Fund, or its compliance with its prospectus, disclosures, laws or regulations, or other matters within the Fund’s control. Each Fund’s adviser is solely responsible for the management of the Fund. JPMS and the manager solutions team of JPMPI or any of its affiliates cannot ensure that a given Fund’s investment objective will be attained. Plan Manager Investment Menu Construction. From the pool of strategies, JPMS selects one or more Funds in each asset class. Under Custom, JPMS also has discretion over the Plan investment menu design, but your Wealth Advisor will have flexibility to construct Plan investment menus within certain guidelines. The available investment options will be those that have been reviewed by the manager solutions team of JPMPI or any of its affiliates or a third-party vendor retained by JPMS. is Implementation. investment decisions JPMS to responsible the Recordkeeper for for Investment Menu communicating implementation for each Client receiving Plan Manager Services. Research Process. JPMS uses research from the manager solutions team of JPMPI or any of its affiliates to research, select and monitor Funds. The manager solutions team of JPMPI or any of its affiliates is comprised of employees of JPMorgan Chase Bank, N.A. (JPMCB) and other affiliates. Specialists on the manager solutions team of JPMPI or any of its affiliates are supervised persons of JPMPI. The manager solutions team of JPMPI or any of its affiliates conducts due diligence of the Funds that are available for use in the Program. The manager solutions team of JPMPI or any of its affiliates is responsible for researching and selecting Funds as well as for subjecting them to a review process. The due diligence process is designed to subject Funds to the same process; however, the manager solutions team of JPMPI or any of its affiliates applies its discretion and is not required to Ongoing Review of Funds and Investment Strategies Approved for Use within Plan Manager Services. Another internal governance forum is responsible for the ongoing monitoring and oversight of Funds and investment strategies as approved and available for inclusion in the Program. From time to time, this internal governance forum may change 33817_COL 04-15-2026 Page 6 of 15  making the final selection of investment options, ensuring required communication of those changes to Plan participants occurs, and for implementing those changes on the Recordkeeper investment platform. Plan Manager Services. The method(s) of analysis used for purposes of providing Plan Manager Services are described above. JPMS is responsible for the ongoing review of Plan investment options utilizing Researched Products that have been approved using the above-described investment analysis and due diligence process of the manager solutions team of JPMPI or any of its affiliates. The Financial Advisor is not involved in selecting the investment options for the Plan. The Client is responsible for the required communication of investment menu changes to Plan participants. the status of a Fund, including terminating them as part of its ongoing monitoring and oversight responsibilities. JPMS may, for investment menu construction reasons, remove a Fund or investment strategy from the menu. If JPMS removes a Fund or investment strategy from the Plan Manager Services investment menus, another Fund or investment strategy that is approved for use in the Program may be added as a replacement. When evaluating a replacement Fund or investment strategy, JPMS is expected to consider the same factors described above. JPMS determines the number of Funds in an asset class and the overall design of the Plan Manager Services investment menus. Periodically, JPMS reviews the investment menus and will make a new Fund available to the investment menus in order to fill a gap in the Funds available or if a Fund is terminated and no Fund available is an appropriate replacement. Custom Plan Manager Services. In providing Custom Plan Manager Services, Wealth Advisors only recommend investment options that have been reviewed by the manager solutions team of JPMPI or any of its affiliates or a third-party vendor retained by JPMS. The method(s) of analysis used for purposes of providing Custom Plan Manager Services may vary from Wealth Advisor to Wealth Advisor and depend on the individual practice and investing philosophy of the Wealth Advisor and Client needs. JPMS will continue to have discretion over the Plan investment menu design, and your Wealth Advisor will have flexibility to construct Plan investment menus within certain guidelines determined by JPMS. The available investment options will be those that have been reviewed by the manager solutions team of JPMPI or any of its affiliates or a third-party vendor retained by JPMS. The Client is responsible for the required communication of investment menu changes to Plan participants. JPMS retains a third-party vendor to provide investment analysis and due diligence services for certain investment options not reviewed by the manager solutions team of JPMPI or any of its affiliates. JPMS, the manager solutions team of JPMPI or any of its affiliates, and/or a third-party vendor may consider multiple quantitative, qualitative, and operational due diligence factors to assist JPMS in providing investment advice or management to Plan Clients, including, but not limited to, firm resources and investment experience, firm and strategy operations, portfolio management team, investment process and philosophy, historical risk and return characteristics, and investment management fees and expenses. A third-party vendor may use different factors or assign different weightings as part of their own due diligence process. The process employed by a third- party vendor for the review of existing Plan investments may not include the same operational due diligence included within the due diligence process utilized by the manager solutions team of JPMPI or any of its affiliates. JPMS may also consider published materials, RFPs and requests for information, and third-party information that JPMS believes to be reliable. JPMS does not guarantee or verify this information, including past performance. JPMS may recommend or select certain Funds that have no prior performance in a particular share class, in which case JPMS may evaluate past performance achieved in other share classes of the same strategy. Risk of Loss. The particular investment options recommended or selected by Wealth Advisors or JPMS, respectively, entail varying degrees of risk. Clients are urged to consult with their Wealth Advisor to discuss the risks associated with the particular investment options recommended or selected. There is no assurance that recommended or selected investment options will be successful or that Plan participants will not suffer losses. Neither JPMS nor its affiliates are responsible for the performance of any investment option or for any investment option’s compliance with its prospectus, disclosures, laws or regulations, or other matters within the investment option’s control. The description of the method of analysis above is qualified in its entirety by the information included in the applicable investment option’s prospectus or other relevant offering documentation. Each investment option’s manager is solely responsible for the management of the investment option. Neither JPMS nor its affiliates can ensure that a given investment option’s investment objective will be attained. With respect to the Plan Advisor Services provided by Wealth Advisors, Clients are not obligated to implement any investment advice, suggestions, or recommendations that Wealth Advisors provide in the Program. Clients are solely responsible for determining if, and how, the investment advice provided should be implemented or otherwise followed. Clients should carefully consider all relevant factors, including an investment option’s prospectus or other disclosures, in making these decisions. Under Custom Plan Manager Services, JPMS will continue to have discretion over the Plan investment menu design, and the available investment options will be those that have been reviewed by the manager solutions team of JPMPI or any of its affiliates or a third-party vendor retained by JPMS. The manager solutions team of JPMPI or any of its affiliates provides ongoing reviews and monitoring of the Funds but does not recommend the specific Funds or allocations to be used to construct plan investment menus. Rather, Custom investment options and menus are recommended by Client’s Wealth Advisor consistent with JPMS’ investment menu structure guidelines regarding number of investment options and asset class requirements. Additionally, optional investment monitoring criteria will be applied for ongoing review of a Client’s Custom Plan investment menu if provided by the Client and agreed to by JPMS. A Fund change can be prompted by a status change from the manager solutions team of JPMPI or any of its affiliates, a third-party vendor retained by JPMS, a client’s investment monitoring criteria or a decision by the Wealth Advisor. JPMS is responsible for communicating investment decisions to the Recordkeeper for implementation for each Client receiving Custom Plan Manager Services. Investing in securities involves risk of loss that Clients should be prepared to bear. The investment performance and success of any particular investment cannot be predicted or guaranteed, and the value of a particular investment option will fluctuate due to market conditions and other factors. Past performance of investments is not indicative of future performance. Clients receive no written or oral guarantees regarding performance. Any projections, analyses, or other information regarding various investment outcomes are hypothetical in nature, do not reflect actual investment results, and are not guarantees of future investment results. B. Material, Significant, or Unusual Risks Associated with Certain Investments in the Program Set forth below are some of the material risk factors that are often associated with the investment options recommended or selected by Financial Advisors or JPMS, respectively. The information included below Plan Advisor Services. In providing Plan Advisor Services, Wealth Advisors only recommend investment options that have been approved by JPMS, the manager solutions team of JPMPI or any of its affiliates or a third-party vendor retained by JPMS. However, the method(s) of analysis used for purposes of providing Plan Advisor Services may vary from Wealth Advisor to Wealth Advisor and depends on the individual practice and investing philosophy of the Wealth Advisor and Client needs. Additionally, optional investment monitoring criteria will be applied for ongoing review of a Client’s Plan investment menu if provided by the Client and agreed to by JPMS for plans generally above $25 million. The Client is responsible for 33817_COL 04-15-2026 Page 7 of 15  relationships, programs and policies of governments, and national and international political and economic events and policies. does not identify every potential risk associated with each investment option. The strategies followed by a particular investment option may be speculative and involve significant risk. Clients are urged to ask their Financial Advisor or JPMS questions regarding risk factors applicable to a particular investment option, read all risk disclosures specific to particular investment options, and determine whether a particular investment option is suitable for the Plan. Refer to the prospectus or offering document for each investment option. Risks Associated with the Use of Artificial Intelligence (AI) Tools. J.P. Morgan relies on programs and systems that utilize AI, machine learning, probabilistic modeling, and other data science technologies (AI Tools). AI Tools are highly complex and may be flawed, hallucinate, reflect biases included in the data on which such tools are trained, be of poor quality, lack transparency, infringe on the intellectual property rights of others, or be otherwise harmful. J.P. Morgan typically incorporates human oversight, including through the standards and policies that define the governance framework, to reduce the risk of acting on potentially defective outputs. AI Tools present Data Sources Risks and Cybersecurity Risks (as described below). The U.S. and global legal and regulatory environment relating to the use of AI Tools is uncertain and rapidly evolving, and could require changes in JPMPI’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Furthermore, J.P. Morgan uses AI Tools developed by third parties, and J.P. Morgan may have limited visibility over the accuracy and completeness of such AI Tools. Data Source Risk. Although J.P. Morgan obtains data, including alternative data, and information from third-party sources that it considers to be reliable, J.P. Morgan does not warrant or guarantee the availability, accuracy, timeliness, and/or completeness of any data or information provided by these sources. J.P. Morgan has controls for certain data that, among other things, consider the representations of such third parties with regard to the provision of data in compliance with applicable laws. J.P. Morgan does not make any express or implied warranties of any kind with respect to such third-party data. J.P. Morgan shall not have any liability for any errors or omissions in connection with any data obtained from third- party sources. General Market Risk. Economies and financial markets throughout the world are becoming increasingly interconnected, which increases the likelihood that events or conditions in one country or region will adversely impact markets or issuers in other countries or regions. Securities in any one strategy may under perform in comparison to general financial markets, a particular financial market or other asset classes, due to a number of factors, including inflation (or expectations for inflation), deflation (or expectations for deflation), interest rates, global demand for particular products or resources, market instability, debt crises, and downgrades, U.S. government debt ceiling negotiations, embargoes, tariffs, sanctions, and other trade barriers, supply chain disruptions, regulatory events, other governmental trade or market control programs, and related geopolitical events. The U.S. and other governments may renegotiate their global trade relationships and impose or threaten to impose significant import tariffs. The implementation of tariffs, trade restrictions, currency controls, or similar measures (including retaliatory actions) could result in price volatility and overall declines in U.S. and global investment markets. In addition, the value of a strategy's investments may be negatively affected by the occurrence of global events such as war, terrorism, environmental disasters, natural disasters or events, country instability, and infectious disease epidemics or pandemics, or the threat or potential of one or more such factors and occurrences. J.P. Morgan often uses data feeds from a number of sources. If such data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool utilizing the data will be unable to properly function or their operation may be adversely impacted. The tools’ ability to use the data may also be adversely impacted by any change in the format of data delivered or acquired by the tool. The timeliness and quality of a third party’s data may be compromised for a variety of reasons, some of which are outside of the control of J.P. Morgan and the third-party data provider. A tool’s ability to process data may also be adversely affected if J.P. Morgan experiences any disruptions to its computing resources or network connections, including disruption of cloud-based computing resources. The effects of a global event to public health and business and market conditions may have a significant negative impact on the performance of the separately managed accounts and J.P. Morgan Affiliated Products investments; increase separately managed account and fund volatility; exacerbate preexisting political, social and economic risks to separately managed accounts and J.P. Morgan Affiliated Products; and negatively impact broad segments of businesses and populations. In addition, governments, their regulatory agencies or self-regulatory organizations, have taken or may take actions in response to a global event that affect the instruments in which a separately managed account or J.P. Morgan Affiliated Products invests, or the issuers of such instruments, in ways that could have a significant negative impact on such account’s or fund’s investment performance. The ultimate impact of any global event and the extent to which the associated conditions and governmental responses impact a separately managed account or J.P. Morgan Affiliated Products will also depend on future developments, which are highly uncertain, difficult to accurately predict, and subject to frequent changes. Valuation Risk. The net asset value of a portfolio as of a particular date may be materially greater than or less than its net asset value that would be determined if a portfolio’s investments were to be liquidated as of such date. For example, if a portfolio was required to sell a certain asset or all or a substantial portion of its assets on a particular date, the actual price that a portfolio would realize upon the disposition of such asset or assets could be materially less than the value of such asset or assets as reflected in the net asset value of a portfolio. Volatile market conditions could also cause reduced liquidity in the market for certain assets, which could result in liquidation values that are materially less than the values of such assets as reflected in the net asset value of a portfolio. Volatility Risk. The prices of a portfolio’s investments can be highly volatile. Price movements of assets are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, developments or trends in any particular industry, the financial condition of the issuers of such assets, changing supply and demand Cybersecurity Risk. As the use of technology has become more prevalent in the course of business, J.P. Morgan has become more susceptible to operational and financial risks associated with cybersecurity, including: theft, loss, misuse, fraud, improper release, corruption and destruction of, or unauthorized access to, confidential, personal, or highly restricted data relating to J.P. Morgan and its clients; and compromises or failures to systems, networks, devices and applications, including, but not limited to, AI Tools and cloud-based computing resources relating to the operations of J.P. Morgan and its service providers. Cybersecurity risks may result in financial losses to J.P. Morgan and its clients; the inability of J.P. Morgan to transact business with its clients; delays or mistakes in materials provided to clients; the inability to process transactions with clients or other parties; violations of privacy and other laws; regulatory fines, penalties, and reputational damage; and compliance and remediation costs, legal fees and other expenses. J.P. Morgan’s service providers (including any sub- advisers, administrator, transfer agent, and custodian or their agents), financial intermediaries, companies in which client accounts and funds invest, and parties with which J.P. Morgan engages in portfolio or other transactions also may be adversely impacted by cybersecurity risks in their own businesses, which could result in losses to J.P. Morgan or its clients. While measures have been developed that are designed to reduce the risks associated with cybersecurity, there is no guarantee that those measures will be effective, particularly since J.P. Morgan does not directly control the 33817_COL 04-15-2026 Page 8 of 15  practices and the Advisor’s assessment of such practices can change over time. its service providers, financial cybersecurity defenses or plans of intermediaries, and companies in which they invest or with which they do business. Use of AI Tools may lead to increased risks of cyberattacks or data breaches and the ability to launch more automated, targeted and coordinated attacks due to the vulnerability of AI technology to cybersecurity threats. The ESG or sustainable solutions offered by J.P. Morgan meet our internally developed criteria for inclusion in the ESG strategies available to clients, which, where applicable, take into account ESG or sustainable investing regulations. As part of the due diligence process, the manager solutions team of JPMPI or its affiliates applies an eligibility framework that establishes a sustainable investing minimum criteria for determining the universe of funds and strategies offered to our clients. Strategies that satisfy the sustainable investing ESG eligibility criteria also are subject to the same due diligence and performance review process as all other strategies. Accordingly, these strategies can be selected by J.P. Morgan, in its discretion and as appropriate, for inclusion in any client portfolio. Intellectual Property and Technology Risks Involved in International Operations. There can be risks to technology and intellectual property that can result from conducting business outside the United States. This is particularly true in jurisdictions that do not have comparable levels of protection of corporate proprietary information and assets such as intellectual property, trademarks, trade secrets, know-how, and customer information and records. As a result, JPMS and its funds can be more susceptible to potential theft or compromise of data, technology and intellectual property from a myriad of sources, including direct cyber intrusions or more indirect routes, such as companies being required to compromise protections or yield rights to technology, data or intellectual property in order to conduct business in a foreign jurisdiction. Risks That Apply Primarily to ESG/Sustainable Investing Strategies The evolving nature of sustainable finance regulations and the development of jurisdiction-specific legislation setting out the regulatory criteria for a “sustainable investment” or “ESG” investment mean that there is likely to be a degree of divergence as to the regulatory meaning of such terms. This is already the case in the European Union where, for example, under the Sustainable Finance Disclosure Regulation (EU) (2019/2088) (SFDR), certain criteria must be satisfied in order for a product to be classified as a “sustainable investment.” Any references to “sustainable investing” or “ESG” in this material are intended as references to our internally developed criteria only and not to any jurisdiction-specific regulatory definition. Category Restrictions and Exclusions Risks Restrictions and exclusions can affect the investment manager’s ability to make investments or take advantage of opportunities that may be available to Clients that do not choose similar restrictions and, as a result, investment performance could suffer. In order to implement category restrictions, JPMS and JPMPI may rely on information about a company, industry classification, industry grouping and/or issuer screening provided by J. P. Morgan, an affiliate, or a third party. Category restrictions aim to screen companies that engage in certain behaviors or with revenue derived from a restricted category; however, they do not exclude all companies with any tie or revenue derived from such restricted category. To the extent a client desires to invest in strategies that incorporate environmental, social, and governance (ESG) considerations or sustainable investing, those strategies can include additional risks. ESG or sustainable investing strategies (together, ESG Strategies), including mutual funds and ETFs, can limit the types and number of investment opportunities and, as a result, could underperform other strategies that do not have an ESG or sustainable focus. ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while others may apply screens in order to exclude particular sectors or industries from a portfolio. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries that share common characteristics and can be subject to similar business risks and regulatory burdens. Because investing on the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized by or determinations made by J.P. Morgan, or an investment manager selected by J.P. Morgan, will align with the beliefs or values of the client. Additionally, other investment managers can have a different approach to ESG or sustainable investing and can offer ESG Strategies that differ from the ESG Strategies offered by J.P. Morgan with respect to the same theme or topic. When evaluating investments, an investment manager is dependent upon information and data that might be incomplete, inaccurate, or unavailable, which could cause the manager to incorrectly assess an investment’s ESG or sustainable attributes. In making investment decisions, J.P. Morgan will use data and information, including, but not limited to, industry classifications, industry grouping, ratings, scores, and issuer screening provided by third-party Data Providers or by a J.P. Morgan affiliated service provider. J.P. Morgan does not review, guarantee, or validate any third-party data, ratings, screenings, or processes. Such data and information will not have been validated by J.P. Morgan and can therefore be incomplete or erroneous. Third-party managers may apply category restrictions differently than J.P. Morgan or its affiliates and use different data, Data Providers, and methodologies; therefore, the selection of restricted securities and the number of restricted securities may differ in the same category. Category restrictions require assumptions, opinions, and the subjective judgement of a Data Provider that might not reflect J.P. Morgan’s views or values and/or the views or values of the client. Furthermore, use of a particular data source from an organization does not mean that J.P. Morgan endorses all the activities of that organization. Additionally, Data Providers will have conflicts of interest when receiving compensation from or providing services to companies that use or obtain their ratings. J.P. Morgan does not review, guarantee, or validate any third-party data, ratings, screenings, or processes. Moreover, issuer screenings and processes to implement category restrictions are not absolute and may change at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations, and estimations, which could result in the portfolio holding investments in companies that derive revenue from the restricted category. If there is a change in the screening methodology or processes used to implement category restrictions, it could lead to trading in the account, which could trigger a taxable event. Any faith-based restrictions will exclude multiple categories selected by a third-party provider based generally on the values and norms of such groups; however, such restrictions will not completely represent or fully align with the client’s values or religious beliefs. ESG and sustainable investing are not uniformly defined concepts and scores or ratings may vary across third-party Data Providers that use similar or different screens based on their process for evaluating ESG characteristics. Investments identified by J.P. Morgan as demonstrating positive ESG characteristics might not be the same investments identified by other investment managers in the market that use similar ESG screens or methodologies. In addition, investments identified as demonstrating positive ESG characteristics at a particular point in time might not exhibit positive or favorable ESG characteristics across all relevant metrics or methodologies or on an ongoing basis. ESG or sustainable investing practices differ by asset class, country, region, and industry and are constantly evolving. As a result, a company’s ESG or sustainable investing 33817_COL 04-15-2026 Page 9 of 15  that the target date funds or accounts will provide sufficient retirement income to a participant. Exchange Traded Funds (ETFs) and Index Mutual Funds. ETFs and index mutual funds are marketable securities that are interests in registered funds and are designed to track, before fees and expenses, the performance or returns of a relevant basket of assets, usually an underlying index. The index may be published or calculated by affiliates of JPMS. Unlike mutual funds, ETFs trade like common stock on a stock exchange. ETFs experience price changes throughout the day as they are bought and sold. ETFs typically have higher daily liquidity and lower fees than mutual fund shares. Physical replication and synthetic replication are two of the most common structures used in the construction of ETFs and index mutual funds. Physically replicated ETFs and index mutual funds buy all or a representative portion of the underlying securities in the index that they track. In contrast, some ETFs and index mutual funds do not purchase the underlying assets but gain exposure to them by use of swaps or other derivative instruments. In addition to the general risks of investing in mutual funds, there are specific risks to consider with respect to an investment in these passive investment vehicles including, but not limited to: index. ETF and index mutual • Variance from benchmark fund performance will differ from the performance of the applicable index for a variety of reasons. For example, ETFs and index mutual funds incur operating expenses and portfolio transaction costs not incurred by the benchmark index, may not be fully invested in the securities of their indices at all times, or may hold securities not included in their indices. In addition, corporate actions with respect to the equity securities underlying ETFs and index mutual funds (such as mergers and spin-offs) may impact the variance between the performances of the funds and applicable indices. LIBOR Discontinuance Risk. The London Interbank Offering Rate (LIBOR) was intended to represent the rate at which contributing banks may obtain short-term borrowings from each other in the London interbank market. After the global financial crisis, regulators globally determined that existing interest rate benchmarks should be reformed based on a number of factors, including that LIBOR and other interbank offering rates (IBORs) are no longer representative of the underlying markets. New or alternative references rates have since been used in place of LIBOR. Replacement rates that have been identified include the Secured Overnight Financing Rate (SOFR, which is intended to replace U.S. dollar LIBOR and measures the cost of U.S. dollar overnight borrowings collateralized by treasuries) and the Sterling Overnight Index Average rate (SONIA, which is intended to replace pound sterling LIBOR and measures the overnight interest rate paid by banks in the sterling market). Markets are slowly developing in response to these new rates. As a result of the benchmark reforms, publication of all LIBOR settings has ceased, and the Adviser and the funds and accounts it manages have generally transitioned to successor or alternative reference rates as necessary. Although the transition process away from IBORs for most instruments has been completed, there is no assurance that any such alternative reference rate will be similar to or produce the same value or economic equivalence as LIBOR or that it will have the same volume or liquidity as did LIBOR prior to its discontinuance, which may affect the value, volatility, liquidity, or return on certain of a fund’s or other client account’s loans, notes, derivatives, and other instruments or investments comprising some or all of a fund’s or other client account’s portfolio and result in costs incurred in connection with changing reference rates used for positions, closing out positions and entering into new trades. The transition from LIBOR to alternative reference rates may result in operational issues for a fund or a client account or their investments. Moreover, certain aspects of the transition from IBORs will rely on the actions of third-party market participants, such as clearing houses, trustees, administrative agents, asset servicers, and certain service providers; no assurances can be given as to the impact of the transition away from LIBOR on a fund or other client account or their investments. These risks may also apply with respect to changes in connection with other IBORs (e.g., Euribor) and a wide range of other index levels, rates, and values that are treated as “benchmarks” and are the subject of recent regulatory reform. • Passive investing risk. Passive investing differs from active investing in that ETF and index mutual fund managers are not seeking to outperform their benchmark. As a result, managers may hold securities that are components of their underlying index, regardless of the current or projected performance of the specific security or market sector. Passive managers do not attempt to take defensive positions based upon market conditions, including declining markets. This approach could cause a passive vehicle’s performance to be lower than if it employed an active strategy. Mutual Funds. Mutual funds are sold by prospectus. Clients should review the prospectus to determine whether the fund is an appropriate investment by considering the investment’s objectives, risk, charges, and expenses. A fund’s net asset value will change with changes in the international equity and fixed income markets and the value of the mutual funds in which it invests. The investment performance of funds that implement their strategies by investing in underlying funds is directly related to the performance and risks of the underlying funds. There is no assurance that the underlying funds will achieve their investment objectives. In addition, a fund indirectly pays a portion of the expenses incurred by the underlying funds. As the underlying funds or the fund’s allocations among the underlying funds change from time to time, or to the extent that the expense ratio of the underlying funds changes, the weighted average operating expenses borne by the fund may increase or decrease. In addition, a fund may hold a significant percentage of the shares of an underlying fund. As a result, the fund’s investments in an underlying fund may create a conflict of interest because a situation could occur where an action for the fund could be adverse to the interest of an underlying fund or vice versa. If a fund invests in closed-end investment companies, it may incur added expenses such as additional management fees and trading costs. • Secondary market risk. With respect to ETFs, shares are bought and sold in the secondary market at market prices. Although ETFs are required to calculate their net asset values (NAV) on a daily basis, at times the market price of an ETF’s shares may be more than the NAV (trading at a premium) or less than the NAV (trading at a discount). Given the differing nature of the relevant secondary markets for ETFs, certain ETFs may trade at a larger premium or discount to NAV than shares of other ETFs depending on the markets where such ETFs are traded. The risk of deviation from NAV for ETFs generally is heightened in times of market volatility or periods of steep market declines. For example, during periods of market volatility, securities underlying ETFs may be unavailable in the secondary market, market participants may be unable to calculate accurately the NAV per share of such ETFs, and the liquidity of such ETFs may be adversely affected. This kind of market volatility may also disrupt the ability of market participants to create and redeem shares in ETFs. Furthermore, market volatility may adversely affect, sometimes materially, the prices at which market participants are willing to buy and sell shares of ETFs. As a result, under these circumstances, the market value of shares of an ETF may vary substantially from the NAV per share of such ETF, and the client may incur significant losses from the sale of ETF shares. Target Date Strategies. Target date strategies become more conservative over time, meaning they allocate more of their assets to fixed income investments than equity investments as they near the target retirement date. Despite the more conservative allocation, the target date products will continue to be exposed to market risk, including stock market risk, and the value of a target date fund or account may decline even after a fund’s or account’s allocation is at its most conservative. There is no guarantee • Tracking the index. Certain funds track financial indexes in which J.P. Morgan retains various intellectual property rights. As a result, 33817_COL 04-15-2026 Page 10 of 15  B. Administrative Proceedings Before Regulatory Authorities and Self- Regulatory Authorities JPMS has been involved in the following material legal or disciplinary events during the last 10 years. the 1) On July 27, 2016, JPMS and JPMCB entered into a Consent Agreement (Agreement) with Indiana Securities Division (ISD). The Respondents consented to the entry of the Agreement that alleged that certain conduct of the Respondents was outside the standards of honesty and ethics generally accepted in the securities trade and industry, in violation of 710 Ind. Admin. Code § 4-10-1(23) (2016). Specifically, the Agreement alleged that, between 2008 and 2013, JPMS failed to disclose to Indiana investors that certain proprietary mutual funds purchased for CSP clients offered institutional shares that were less expensive than the institutional shares JPMS chose for CSP clients. In addition, the Agreement alleged that, from February 2011 to January 2014, no account opening document or marketing materials disclosed to Indiana investment management account clients or Indiana J.P. Morgan Investment Portfolio clients that JPMCB preferred to invest client assets in proprietary mutual funds, and that between 2008 and January 2014, JPMCB did not disclose its preference for investing certain investment management account assets in certain proprietary hedge funds to Indiana clients. Lastly, the Agreement alleged that JPMCB did not disclose its preference for placement-agent-fee-paying third-party hedge fund managers in certain investment management accounts to Indiana clients until August 2015. Solely for the purpose of settling these proceedings, the Respondents consented to the Agreement, with no admissions as to liability. In the Agreement, the Respondents agreed to pay a total of $950,000 to resolve the ISD’s investigation, which was paid on August 1, 2016. J.P. Morgan may be entitled to receive index licensing fees from unaffiliated licensees of these indexes. Affiliates of JPMPI may develop or own and operate stock market and other indexes based on investment and trading strategies developed by such affiliates. Affiliates of JPMS may also assist unaffiliated entities in creating indexes that are tracked by certain ETFs and index mutual funds utilized by JPMS. Some ETFs and index mutual funds seek to track the performance of these indexes. JPMS may, from time to time, manage client accounts that invest in the ETFs and index mutual funds. In addition, J.P. Morgan may manage strategies that track the same indexes used by the ETFs and index mutual funds or that may be based on the same or substantially similar strategies used in the operation of the indexes and the ETFs and index mutual funds. The operation of the indexes, the ETFs and index mutual funds and client accounts in this manner may give rise to potential conflicts of interest. For example, client accounts that track the same indexes used by the ETFs and index mutual funds may engage in purchases and sales of securities relating to index changes prior to the implementation of index updates or at the time as of which the ETFs and index mutual funds engage in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the ETFs’ and index mutual funds’ portfolios are only rebalanced on a periodic basis corresponding with the rebalancing of an index. These differences may result in the client accounts having more favorable performance relative to that of the index and the ETFs and index mutual funds or other client accounts that track the index. Other potential conflicts include the potential for unauthorized access to index information, allowing index changes that benefit JPMS or other client accounts and not the investors in the ETFs and index mutual funds. J.P. Morgan has established certain information barriers and other policies to address the sharing of information between different businesses within J.P. Morgan, including with respect to personnel responsible for maintaining the indexes and those involved in decision-making for the ETFs and index mutual funds. Collective Investment Trusts or Funds. A collective investment trust is not open to individual investors. Unlike a mutual fund, the only way that an investor can gain access to a collective trust fund is through a retirement plan such as a 401(k) plan. Additionally, regulation of mutual funds and collective trust funds varies. Managers of collective funds are not regulated by the SEC, and these investment advisers adhere to less stringent guidelines. As a result, managers of collective funds have to disclose fund performance and the components of a portfolio only once a year, although most collective fund managers communicate performance to investors on a more frequent basis. 2) In October 2018, JPMS submitted an Acceptance, Waiver and Consent (AWC) to FINRA pursuant to which JPMS was censured and required to certify in writing to FINRA that it had engaged in a risk-based review of Chase Wealth Management (CWM) client-facing third-party vendors, that it had corrected any issues detected, and that JPMS had established and implemented systems and policies and procedures (written or otherwise) reasonable designed to achieve compliance with applicable FINRA and NASD rules. JPMS had discovered and self- reported to FINRA that a vendor responsible for the automated realignment of portfolio assets (rebalancing) and the calculation of fees was not rebalancing certain accounts due to technology upgrades by the vendor. Similarly, the vendor had converted to a new billing platform that caused billing errors that went undetected. JPMS paid total restitution of $4,620,140 to impacted customers and provided substantial assistance to FINRA by proactively undertaking an extensive lookback concerning its complex and systemic failures and reporting related findings on an ongoing basis. Without admitting or denying the findings, JPMS consented to the sanctions and to the entry of findings that it failed to establish and maintain a system and procedures reasonably designed to monitor and evaluate the performance of the vendor that handled certain functions on behalf of the Firm. Stable Value Assets. The objective of most stable value assets is to provide safety of principal and an investment return that is generally higher than a money market return, while providing Plan participants the ability to withdraw their assets for ordinary transactions at book rather than market value. However, the ability to withdraw stable value assets at book value has limitations based on the insurance contracts that wrap the underlying assets. In addition, most stable value assets have significant Plan-level liquidity restrictions and require a hold period before assets can be withdrawn from the fund by the Plan sponsor at book value and may refuse to honor book value withdrawals after communications from a Plan sponsor or Plan fiduciaries that it determines caused participants’ withdrawals. Additionally, the Plan is often restricted from offering investment alternatives or plans that are viewed as competitive with the stable value offering. Stable value assets are subject to counterparty risk of the insurers that provide the fund’s book value liquidity. Risks Associated with Particular Types of Securities C. Refer to response to Item 8.B. ITEM 9 — DISCIPLINARY INFORMATION Criminal or Civil Proceedings A. JPMS has no material civil or criminal actions to report. 3) On January 9, 2020, JPMS entered into a settlement with the SEC resulting in the SEC issuing an administrative order (the 2020 Order). JPMS consented to the entry of the 2020 Order, which found that JPMS violated Section 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The 2020 Order found that JPMS negligently omitted to state from at least January 2010 through December 2015 that (a) it received greater compensation from eligible customers’ purchases of more expensive mutual fund share classes, resulting in eligible customers not having sufficient information to understand that JPMS had a conflict of interest from sales of the more expensive share classes; and (b) the purchase of the more expensive share classes, when the customers were otherwise eligible for less expensive share classes, would negatively impact the overall return on the eligible customers’ investments, in light of the different fee structures for the different fund share classes. The 2020 Order also found that JPMS did not have adequate systems 33817_COL 04-15-2026 Page 11 of 15  and controls in place to determine whether eligible customers were eligible to purchase the less expensive share classes. Solely for the purpose of settling this proceeding, JPMS consented to the 2020 Order, without admitting or denying the findings set forth in the 2020 Order. The 2020 Order censured JPMS and directed JPMS to cease-and-desist from committing or causing any violations and any future violations of Securities Act Sections 17(a)(2) and 17(a)(3). Additionally, the 2020 Order required JPMS to pay a total of $1,822,438 in disgorgement, pre- judgment interest, and civil penalty. 6) On January 16, 2024, JPMS entered into a settlement with the SEC resulting in the SEC issuing an administrative order (the Order). JPMS consented to the entry of the Order, which found that JPMS willfully violated Rule 21F-17(a) under the Securities Exchange Act of 1934 (the Exchange Act). The Order arose out of JPMS, from 2020 through July 2023, asking certain clients and customers to whom it had issued a credit or settlement over $1000 in value to sign a confidential release agreement that required the clients to keep confidential the release agreement and all information relating to the specified account at JPMS. The confidential release agreement neither prohibited nor restricted clients from responding to any inquiry about the confidential release agreement or its underlying facts from FINRA, the SEC, or any other government entity or self-regulatory organization, or as required by law, but did not permit voluntary communications with such regulators. The Order censured JPMS and directed JPMS to cease-and- desist from committing or causing any violations and any future violations of Rule 21F-17(a) under the Exchange Act. Additionally, the Order required JPMS to pay a civil money penalty in the amount of $18,000,000. JPMS has paid the civil monetary penalty in accordance with the terms of the Order. 4) On March 9, 2020, JPMS entered into an Agreed Order (the March 2020 Order) with the Kentucky Department of Financial Institutions (KDFI). JPMS consented to the entry of the March 2020 Order that alleged that JPMS failed to disclose conflicts of interest arising from preferences for J.P. Morgan-managed mutual funds (Proprietary Mutual Funds), in violation of KRS 292.320 and 808 KAR 10:450§2(8)(c) and (11)(a). Specifically, the March 2020 Order alleged that, between 2008 and 2013, JPMS failed to disclose to Kentucky investors that (i) CSP was designed and operated with a preference for Proprietary Mutual Funds; (ii) there was an economic incentive to invest CSP assets in Proprietary Mutual Funds as a result of discounted pricing for services provided to JPMS for CSP by a JPMS affiliate, and (iii) until November 2013; JPMS failed to disclose to CSP clients the availability of certain less expensive Proprietary Mutual Fund share classes. Solely for the purpose of settling these proceedings, JPMS consented to the March 2020 Order, with no admissions as to liability. In the Agreement, JPMS agreed to pay a total of $325,000 to resolve the KDFI investigation. 7) On October 31, 2024, JPMS entered into a settlement with the SEC resulting in the SEC issuing an administrative order (the Order). JPMS consented to the entry of the Order, which found that JPMS willfully violated Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 (Advisers Act) and Rule 206(4)-7 thereunder. The Order arose out of JPMS, from at least July 2017 until October 11, 2024, failing to fully and fairly disclose the financial incentive of itself and certain of its financial advisors to recommend a certain advisory program—the Portfolio Manager Program—over other advisory programs offered by JPMS that use third-party managers. The Order also found that JPMS failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with the disclosure of conflicts of interest presented by the fee structure of the advisory programs for itself and its financial advisors. The Order censured JPMS and directed JPMS to cease-and-desist from committing or causing any violations and any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. Additionally, the Order required JPMS to pay a civil money penalty in the amount of $45,000,000. JPMS has paid the civil monetary penalty in accordance with the terms of the Order. ITEM 10 — OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. Broker-Dealer Registrations JPMS is registered with the SEC as a broker-dealer as well as an investment adviser. Some of JPMS’ management personnel and all of the Financial Advisors and their supervisors in the Program are registered with the FINRA as registered representatives of JPMS in its capacity as a broker- dealer. B. Futures/Commodities-Related Registrations In addition, JPMS is registered with the CFTC as a futures commission merchant and also acts as a commodity pool operator exempt from registration as such with the CFTC. Some of JPMS’ management personnel, and a small number of the Financial Advisors and/or their supervisors in the Program, are registered with the CFTC as associated persons of JPMS in its capacity as a futures commission merchant. C. Material Relationships with Related Persons and Potential Conflicts of Interest 5) In September 2020, JPMS, together with JPMC and JPMCB (collectively, J.P. Morgan) agreed to an administrative resolution with the CFTC for violations of the CEA and CFTC regulations related to manipulation, attempted manipulation and spoofing, as well as a charge against JPMS for failure to supervise. As described in the CFTC’s Order, from at least 2008 through 2016, former J.P. Morgan traders placed hundreds of thousands of spoof orders of precious metals futures and U.S. treasuries (UST) futures on exchanges, and, on occasion, engaged in manipulation related to precious metals barrier options. The CFTC Order further states that JPMS failed to identify, adequately investigate, and put a stop to misconduct, despite red flags, including internal surveillance alerts, inquiries from CME and the CFTC, and internal allegations of misconduct. J.P. Morgan consented to the entry of the CFTC Order without admitting or denying the findings contained therein, except to the extent that admissions were made in the related resolutions, described below, with the United States Department of Justice, Criminal Division, Fraud Section, and the United States Attorney’s Office for the District of Connecticut (together, DOJ) and the SEC. JPMS also agreed to an administrative resolution with the SEC for violations of Section 17(a)(3) of the Securities Act of 1933. Pursuant to the SEC Order, JPMS admitted to hundreds of manipulative trading events involving spoofing by certain former J.P. Morgan traders in the UST cash securities secondary market between April 2015 and January 2016. JPMC separately entered into a deferred prosecution agreement (DPA) with DOJ with respect to a criminal information, charging JPMC with two counts of wire fraud (the Information) related to the same conduct underlying the CFTC and SEC Orders. JPMS and JPMCB also agreed to certain terms and obligations of the DPA. J.P. Morgan admitted, accepted and acknowledged responsibility for the acts of its officers, directors, employees, and agents as described in the Information and the Statement of Facts accompanying the DPA, and that the allegations described therein are true and accurate. In resolving these three actions, J.P. Morgan agreed to pay a total of $920,203,609 to DOJ, CFTC and SEC, consisting of civil and criminal monetary penalties, restitution and disgorgement. J.P. Morgan agreed to cease and desist from any further violations, and also agreed, among other things, to certain cooperation, remediation, and reporting requirements. JPMS has several relationships or arrangements with related persons that are material to its investment advisory business or to its clients in the Program. Affiliates of JPMS are the sponsors and/or general partners of certain open-end mutual funds (including money market funds), closed- end funds, ETFs, and other pooled investment vehicles. JPMS and its 33817_COL 04-15-2026 Page 12 of 15  • The maintenance of personal securities accounts by JPMS’ investment Financial Advisors; • The reporting to JPMS Compliance personnel of certain personal securities holdings and transactions by certain of JPMS’ investment Financial Advisors, including all Financial Advisors in the Program; • Certain trading restrictions and holding periods applicable to personal securities transactions of certain of JPMS’ investment Financial Advisors; • Trading by investment Financial Advisors while in possession of material non-public information; affiliates may provide investment management, distribution, and other services to, and receive compensation from or in connection with, such funds. As discussed above, in the Program, JPMS will not recommend or otherwise provide advice on Affiliated Products. In addition to the mutual funds and other pooled investment vehicles sponsored and managed by affiliates of JPMS, JPMS’ ultimate parent company, JPMorgan Chase & Co., is a publicly traded corporation the common stock of which is listed and trades on the NYSE. Other affiliates of JPMS also may issue securities through public or private distributions. All or substantially all registered representatives also are employees of JPMCB. In their capacities as employees of JPMCB and outside of the Program, Financial Advisors may market and sell products and services of JPMCB to clients and be compensated in connection with such sales. • Periodic certification by certain of JPMS’ investment Financial Advisors, including all Financial Advisors in the Program, of their review, understanding, and compliance with the Code of Ethics; • JPMS’ administration and enforcement of the Code of Ethics; and • The keeping of certain records relating to the Code of Ethics and its Additional information about these relationships or arrangements can be found in the brochures for the other investment advisory programs JPMS offers, which can be obtained at the SEC’s website adviserinfo.sec.gov. administration and enforcement by JPMS. Revenue Sharing Arrangements with Affiliates A copy of the Code of Ethics is available free of charge to any Client or prospective client upon request by contacting your Financial Advisor. B. Securities in Which JPMS or a Related Person Has a Material Financial Interest In some cases, JPMS or a related person recommends to investment advisory clients, including Clients in the Program, securities in which JPMS or a related person has a material financial interest. JPMS is party to certain revenue sharing arrangements pursuant to which it may receive compensation from certain affiliates in connection with referrals or introductions of investors by registered representatives in JPMS (including Financial Advisors in the Program) to the affiliates for the provision by the affiliates of products and services to the investors. The investors referred may be existing investment advisory clients, including Clients in the Program. When JPMS make such a referral of one of its existing investment advisory clients to an affiliate, the revenue sharing arrangement creates a conflict of interest with the client because: • from the Funds • • • JPMS has a financial incentive to make the referral because it will be entitled to compensation from the affiliate if the referred client becomes a client or customer of the affiliate; JPMS does not necessarily base such referrals on any review or due diligence of the affiliate or its personnel, products, or services; JPMS does not necessarily conduct an assessment of the suitability of the affiliate’s products or services for referred clients; and It may not be in the referred client’s best interest to become a client or customer of the affiliate. JPMS believes that this conflict is addressed in the following ways: • Typically, the referred client is not charged more for the product or service provided by the affiliate by virtue of the fact that the affiliate will compensate JPMS for the referral. Certain unaffiliated Funds that Financial Advisors recommend to Clients to make available to Plan participants may execute transactions for their portfolios through JPMS or an affiliate as broker-dealer, and JPMS or an affiliate or other related person (including Financial Advisors acting in their capacity as registered representatives of JPMS as broker-dealer) may receive compensation in connection with these transactions. Such compensation presents a conflict of interest between JPMS and Program Clients because JPMS and/or Financial Advisors may have a financial incentive to recommend that Clients make such Funds available to Plan participants: (1) in the hope or expectation that increasing the amount of assets invested with the Funds will increase the number and/or size of transactions placed by the Funds for execution by JPMS or an affiliate or other related person, and thereby result in increased compensation to JPMS and its affiliates and other related persons in the aggregate; and (2) to benefit the Funds and thereby preserve and foster valuable brokerage relationships with the Funds. Assuming that a Program Client’s Financial Advisor is aware of which Funds execute through JPMS or an affiliate or other related person and which do not, JPMS believes that this conflict is addressed in the following ways: • Clients referred to affiliates by JPMS have no obligation to become clients or customers of those affiliates, and their declining to do business with the affiliate to which they were referred will not affect their relationship with JPMS. Recommendation or Selection of Other Investment Advisers In the Program, JPMS does not recommend or select other investment advisers for Clients. JPMS is the only investment adviser in the Program, and all investment advice in the Program is provided through the Financial Advisors. ITEM 11 — CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING • Unless the Financial Advisor is individually involved in the execution of portfolio transactions for a Fund, they do not receive any direct financial benefit (such as additional compensation) from the purchase or sale by a Plan participant of Funds that execute transactions through JPMS or an affiliate or other related person rather than Funds that do not. Moreover, because Financial Advisors are compensated in the Program through the receipt of a portion of the Fee, which is typically tied to the market value of Plan assets, Financial Advisors are to that extent incentivized to recommend Funds they believe will increase in value, regardless of whether or not the Funds execute transactions through JPMS or an affiliate or other related person. A. Code of Ethics • Financial Advisors are subject to supervision JPMS believes Financial Advisors in the Program are bound by a Code of Ethics (Code of Ethics), adopted by JPMS in accordance with Rule 204A-1 under the Investment Advisers Act of 1940 (Advisers Act). is reasonably designed to ensure that any investment advice, suggestions, or recommendations provided are in accordance with criteria and other information provided by the Client and that, when acting in a fiduciary capacity, Financial Advisors are acting in accordance with their duty to place the interests of Program Clients before their own and those of JPMS. JPMS and its affiliates (including JPMorgan Distribution Services, Inc.) and other related persons also may receive other forms of compensation in The Code of Ethics describes the general standards of business conduct applicable to JPMS’ investment Financial Advisors, including Financial Advisors in the Program, and the fiduciary obligations owed by JPMS and its investment Financial Advisors to clients in its investment advisory programs. More specifically, the Code of Ethics addresses the following subjects: 33817_COL 04-15-2026 Page 13 of 15  place the interests of Clients in the Program before their own and those of JPMS; • The imposition of trading restrictions with respect to certain time periods and/or lists of issuers that are designed to prevent investment personnel (including Financial Advisors) from unfairly benefiting from unreleased research reports and recommendations; and connection with the operation and/or sale of shares of affiliated or unaffiliated Funds, which may include distribution fees paid by certain Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940 and non-Rule 12b-1 compensation (including revenue sharing, shareholder servicing fees and licensing fees for the use by a fund of a J.P. Morgan index), from certain Funds, to the extent permitted by applicable law. JPMS addresses this conflict by disclosing it to Clients and by not receiving these payments with respect to assets in the Program. • The requirement in the Code of Ethics that Financial Advisors in the Program periodically report personal securities holdings and transactions to JPMS Compliance personnel. Clients should understand that Financial Advisors typically are not required, except in certain limited circumstances, to follow or otherwise consider or adhere to research reports, analyses and opinions published or otherwise communicated by other employees of JPMS or its affiliates, including J.P. Morgan investment committees, due diligence personnel, research analysts, economists and market strategists, and the advice of Financial Advisors to Clients in the Program may differ from (and be diametrically opposed to) the content of such reports, analyses, and opinions. D. When JPMS or a Related Person Buys/Sells Securities for Itself at or About the Same Time It Recommends the Same Securities to/for Clients JPMS and its related persons (including Financial Advisors) may recommend that Clients in the Program make investment options available to Plan participants at or about the same time that JPMS or a related person buys or sells the same securities for its (or a related person’s) own account. Certain asset management firms (each, an asset manager), through their funds and separately managed accounts, currently hold a 5% or greater ownership interest in J.P. Morgan publicly traded stock. This ownership interest presents a conflict of interest when JPMCB, JPMS, JPMPI, and J.P. Morgan recommend or purchase the publicly traded security of the asset manager or the separately managed accounts or funds managed or advised by the asset manager. JPMCB, JPMS, JPMPI, and J.P. Morgan address this conflict by disclosing the asset manager’s ownership interest and by subjecting the asset manager’s separately managed accounts and funds to a research process. Additionally, the financial advisers and portfolio managers that may purchase or recommend securities, separately managed accounts and funds of an asset manager that has an ownership interest in J.P. Morgan, do not receive any additional compensation for that purchase or recommendation. A fund ownership interest in J.P. Morgan can cause the fund and its affiliates to determine that they are unable to pursue a transaction or the transaction will be limited or the timing altered. J.P. Morgan monitors ownership interests in J.P. Morgan for regulatory purposes and to identify and mitigate actual and perceived conflicts of interest. As of March 2, 2026, the Vanguard Group, Inc. and BlackRock, Inc. hold more than a 5% interest in J.P. Morgan. C. When JPMS or a Related Person Invests in the Same Securities That It Recommends In such circumstances, the interests of JPMS and its related persons conflict with those of JPMS’ clients, including Clients in the Program, in all of the respects described in the preceding section, each of which typically involves not only trading in the same securities that clients do but also trading in them at or about the same time that clients do. its related persons (including Financial Advisors) may JPMS and recommend that Clients in the Program make investment options available to Plan participants that JPMS or a related person buys or sells for itself. ITEM 12 — BROKERAGE PRACTICES In such circumstances, the interests of JPMS and its related persons conflict with those of Clients in the Program in several respects: • JPMS does not recommend or select broker-dealers for Client transactions in the Program and does not engage in securities transactions in connection with the Program. As such, the Plan Services do not include the review or recommendation of broker-dealers for Client transactions. Clients choose the financial institution through which to implement JPMS investment advice. ITEM 13 — REVIEW OF ACCOUNTS A. Frequency and Nature of Review of Client Accounts JPMS or a related person may benefit from (1) Clients or Plan participants buying securities that JPMS or the related person then sells (because purchases may increase the market price of a security JPMS or the related person owns or borrows and then sells), or (2) Clients or Plan participants selling securities that JPMS or the related person then buys (because sales may reduce the market price of a security JPMS or the related person then buys). • investment management services JPMS or a related person may benefit from (1) buying securities that Clients or Plan participants will later buy (because the subsequent purchases may increase the market price of the security JPMS or the related person already bought and owns) or (2) selling securities that Clients or Plan participants will later sell (because subsequent sales may decrease the market price of the security JPMS or the related person already sold). JPMS addresses these conflicts in the following ways: JPMS provides investment advice at the Plan-level and does not provide for Plan investment advice or participants’ accounts. As described above, JPMS will assist the Client in the ongoing monitoring of Plan investment options and will not provide ongoing monitoring of Affiliated Products. Ongoing monitoring by JPMS includes periodic reviews with Clients of the performance of Plan investment options (which are semi-annual for Plan Advisor and annual for Plan Manager). JPMS provides quarterly reports to Clients that include performance of Plan investment options on the Plan investment menu. When appropriate, based on this information, JPMS may assist Plan Advisor Client in identifying new investment options. • The maintenance of policies (including in the Code of Ethics) prohibiting JPMS employees from engaging in conduct intended to manipulate the price of securities and procedures designed to prevent and/or detect such conduct; Custom Plan Manager Services and Plan Advisor Services. The quarterly reports for Clients that have provided investment monitoring criteria accepted by JPMS will include data and other information relating to the monitoring criteria. • The maintenance of information barrier procedures designed to control the flow of information between JPMS’ and its affiliates’ proprietary trading operations and other business units; B. Factors Prompting Review of Client Accounts Other than a Periodic Review JPMS reviews the Program on an ongoing and periodic basis and has policies and procedures to supervise the Program in accordance with the Advisers Act, ERISA, and other rules and regulations. • The supervision of Financial Advisors in providing investment advice in the Program that JPMS believes to be reasonably designed to ensure that any investment advice provided is consistent with the criteria and other information provided by Clients in accordance with their duty to 33817_COL 04-15-2026 Page 14 of 15  C. Content and Frequency of Account Reports to Clients is not trying to Each Financial Advisor is responsible for reviewing the Clients advised by them on an ongoing basis. Responsibility for the ongoing supervision of each Financial Advisor’s activity in the Program lies with the supervisor designated by JPMS as generally responsible for supervising that Financial Advisor. be made, including for certain non-cash gifts or promotional items valued at $100 or less. The J.P. Morgan Code of Conduct and other gift-related policies set conditions for each of these types of payments and do not permit any gifts or promotional items unless it is clear that the gift-giving influence or reward the JPMS employee person inappropriately in connection with any business decision or transaction and that the gift is unsolicited. ITEM 14 — CLIENT REFERRALS AND OTHER COMPENSATION Providers participating in JPMS programs or otherwise utilized by J.P. Morgan are not required to make any of these types of payments. A. Economic Benefits for Providing Services to Clients JPMS does not receive economic benefits from non-clients for providing investment advice or other advisory services to Program Clients. JPMS and its affiliates do receive economic benefits from certain mutual funds and other pooled investment vehicles when Plan assets are invested in them. Although these benefits are attributable to sales of the Funds and the investment of Plan assets in the Funds, they are not benefits the Funds provide to JPMS or its affiliates in exchange for JPMS’ provision of investment advisory services to Program Clients. JPMS believes that, under any reasonable method of allocation, the gifts and other nonmonetary compensation or subsidies that may be attributable to any particular Plan are typically of insubstantial value (as any such gifts and other nonmonetary compensation or subsidies are most often attributable to JPMS’ or J.P. Morgan’s “book of business” as a whole) and, therefore, will generally be exempt from reporting on the Schedule C for the Plan’s Form 5500. Similarly, JPMS does not reasonably anticipate receiving any such gifts or other nonmonetary compensation or subsidies associated with the services it provides to any Plan in excess of $250 and, accordingly, does not believe it has reportable nonmonetary compensation for purposes of ERISA section 408(b)(2). B. Compensation to Non-Supervised Persons for Client Referrals Neither JPMS nor any related person of JPMS directly or indirectly compensates any person who is not its supervised person for Client referrals to the Program. ITEM 15 — CUSTODY JPMS does not have custody of Client funds and securities in connection with the Program. In addition, JPMS and its affiliates may from time to time enter into joint marketing activities with portfolio managers and/or sponsors of mutual funds recommended to Clients in the Program. These managers and/or sponsors may pay some or all of the cost of the marketing activities, which payment may take the form of reimbursement of JPMS. Because of the willingness of these managers and/or sponsors to provide financial support for such activities, JPMS has an incentive to allow these managers and/or sponsors (as opposed to other portfolio managers and/or sponsors who are unwilling to provide such financial support) to participate in such joint marketing activities. However, the payments by the fund managers and/or sponsors are not made in exchange for JPMS’ provision of investment advisory services to its Clients. ITEM 16 — INVESTMENT DISCRETION Refer to Item 10 for a discussion of revenue sharing arrangements between JPMS and certain of its affiliates pursuant to which JPMS may receive compensation from the affiliates in connection with referrals or introductions of clients by JPMS to the affiliates for the provision by the affiliates of products and services to the clients. In such cases, the compensation is in exchange for JPMS’ referral of clients to other affiliated financial service providers, not for JPMS’ own provision of investment advisory services to its clients. JPMS and the Client enter into an investment advisory agreement authorizing JPMS to create an investment menu for the Plan. The agreement for Plan Manager Services directs JPMS to exercise discretion over ongoing selection of investments for the Plan investment menu as well as authorizes JPMS to direct the implementation of the Plan investment menu and to exercise discretion over making changes to the investments on a Plan’s investment menu. Refer to Item 4 for a detailed description of these services. ITEM 17 — VOTING CLIENT SECURITIES JPMS will not vote proxies (or give advice about how to vote proxies) relating to securities or other property currently or formerly held by a Plan Client. JPMS and its affiliates will not be responsible for notifying Clients of proxies or of sending Clients proxy materials. Clients are responsible for voting proxies or any securities or other property in the Plan in accordance with the terms of the Plan. Clients should contact their Plan Recordkeeper with questions about proxy voting. ITEM 18 — FINANCIAL INFORMATION JPMS does not require or solicit prepayment of more than $1,200 in fees per Client 6 months or more in advance and, thus, has not included a balance sheet or its most recent fiscal year. JPMS is not aware of any financial condition that is reasonably likely to impair its ability to meet contractual commitments to its Clients, nor has JPMS been the subject of a bankruptcy petition at any time during the past 10 years. Third-party providers (such as investment managers or Recordkeepers), including companies that sponsor investment options made available to Plans through JPMS, may participate in JPMS-sponsored internal training and educational conferences and meetings, and they may make payments to, or for the benefit of, JPMS or its Financial Advisors to reimburse for certain expenses incurred for these events. Providers may also sponsor their own educational conferences or due diligence meetings and pay certain expenses of Financial Advisors attending these events. JPMS’ policies require that the training or educational portion of these conferences comprises substantially all of the event, and such conferences and meetings are subject to review and approval. Furthermore, JPMS may provide sponsorship opportunities and access to its branch offices and Financial Advisors to such providers for educational, marketing, and other promotional efforts. Any payments made by providers could lead Financial Advisors to focus on products managed by these providers when recommending products to Clients instead of those from other providers that do not commit similar resources to educational, marketing, and other promotional efforts. J.P. Morgan has implemented policies and procedures intended to ensure that J.P. Morgan and its employees avoid actual or perceived conflicts of interest when giving or receiving nonmonetary compensation from relevant parties and comply with all applicable laws and regulations. To that end, the J.P. Morgan Code of Conduct and other gift-related policies generally restrict or prohibit acceptance of gifts, entertainment, or other nonmonetary compensation in connection with the services provided to any Client or Plan, or in return for any business of J.P. Morgan. Exceptions may 33817_COL 04-15-2026 Page 15 of 15