J.P. MORGAN SECURITIES LLC

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 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 November 5, 2025 C. When JPMS or a Related Person Invests in the Same Securities That It Recommends ..................................................................... 14 383 Madison Avenue New York, NY 10179 (800) 392-5749 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 ITEM 4 — ADVISORY BUSINESS 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 1-800-392-5749. 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. A. Description of Advisory Firm Additional information about JPMS also is 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 the Brochure since the last amendment dated March 28, 2025. 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 Financial Industry Regulatory Authority (FINRA). JPMS’ investment advisory services include sponsoring a variety of wrap fee programs and providing certain consulting services to defined contribution plan sponsors. JPMS investment advisory services include sponsoring a variety of advisory programs. 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 ............................................... 4 D. Wrap Fee Program ........................................................................ 4 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 E. Financial Advisors Compensation ................................................. 5 ITEM 6 — PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................................................. 5 ITEM 7 — TYPES OF CLIENTS ................................................................ 5 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 which is made available through a JPMS “Private Client Advisor” or a “Wealth Advisor” (collectively referred to herein as 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. JPMS also maintains a separate website, chase.com/managed-account-disclosures for clients of Private Client Advisors and jpmorgan.com/adv for Wealth Advisor clients, that contains 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) or 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). 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 B. Administrative Proceedings Before Regulatory Authorities and Self-Regulatory Authorities .......................................................... 11 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 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 11-05-2025 Page 1 of 15  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 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 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: • Plan Within the Program, JPMS offers two types of investment advisory offerings: (1) non-discretionary advisory services, whereby JPMS provides investment advice with respect to Plans, such services being referred to below as “Plan Advisor Services” (which includes DC Plan Advisor Services and NQDC Plan Advisor Services); and (2) discretionary investment management services, such services being referred to below as “Plan Manager Services” (which includes 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)). 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. Investment Menu Design. Wealth Advisors 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. Investment Searches. Wealth Advisors 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 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 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 herein). 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. 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 are collectively referred to herein as “Plan Services” and are described in more detail below. • 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 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. 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 or accounts, 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 before the Client Agreement is effective are not intended, and should not be relied upon, as investment or other fiduciary advice. 1. Plan Advisor Services 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. 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 that term is 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 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 or its participants that is either incorrect or has not been updated by the Client. 33817_COL 11-05-2025 Page 2 of 15  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 herein. Selection of the recordkeeper and underlying funding platform is the responsibility of the Client. 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. Under Custom, JPMS has 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 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. • 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 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 share classes or equivalents). Financial Advisors’ compensation is not affected by the share class selected. By appointing JPMS as Investment Manager, Clients authorize JPMS to take any actions necessary to implement changes to the Plan’s investment menu. JPMS will direct the Plan’s Recordkeeper to implement the investment 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 herein), 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 Services are limited. For Custom, flexibility is available within defined parameters set by 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. 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 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. 3. Plan-Related Services 4. Limitations on Plan Services Plan Services are subject to certain limitations, including: Clients enrolled in the Program can choose to receive certain non-fiduciary Plan-Related Services described in more detail below. • Universe of Investment Options. JPMS 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 • 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 33817_COL 11-05-2025 Page 3 of 15  ERISA, state or local law or any other regulations or requirements applicable to the Plan. The Client is responsible for, and should consult with, its legal and tax professionals about, those matters. 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) 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. Participants 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 speak with other professional advisors (e.g., attorneys and/or tax professionals) 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. 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. • 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. 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. 5. Termination • 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. • 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 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 Refer to Item 4.B. above for details on how JPMS advisory services can be tailored to the individual needs of Clients. D. Wrap Fee Program • 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; 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). 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. • Legal, Tax and Accounting Advice. JPMS and its affiliates do not provide legal, tax or accounting advice and will not be responsible for ensuring that a Plan’s IPS or any other Plan documents comply with 33817_COL 11-05-2025 Page 4 of 15  E. Assets Under Management As of December 31, 2024, JPMS managed $63,284,158,740 on a discretionary basis and $283,376,877,642 on a non-discretionary basis. 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 or Plan participants 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 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 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. 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 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 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 may be invested in with JPMS or its affiliates. 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 defined contribution retirement plans and employers establishing NQDC Plans. There is no minimum asset requirement for participation in the Program. For ERISA Plans, Clients must be a “named fiduciary” (as such 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 33817_COL 11-05-2025 Page 5 of 15  term is defined in Section 402(a) of ERISA) of the Plan and have the power and authority to designate and effectuate investment alternatives under the terms of the Plan. For all Plans, Clients must have the power and authority to enter into contractual arrangements with third parties on behalf of the Plan. 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 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. 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 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. 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. 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 referred to herein as 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 33817_COL 11-05-2025 Page 6 of 15  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. 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 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 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. 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 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. 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. 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, embargoes, tariffs, sanctions and other trade barriers, regulatory events, other governmental trade or market control programs, and related geopolitical events. 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, pandemics or endemics. 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. Infectious Disease Risk. The effects of any future pandemic or other global event to 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 Risk of Loss. The particular investment options recommended or selected by Wealth Advisors or JPMS, respectively, entail varying degrees of risk. Each Client is urged to consult with their own Wealth Advisor to discuss the 33817_COL 11-05-2025 Page 7 of 15  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 pandemic or other global events 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 pandemic or other global event and the extent to which the associated conditions and governmental responses impact a separately managed account or JP Morgan Affiliated Products will also depend on future developments, which are highly uncertain, difficult to accurately predict and subject to frequent changes. 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 cyber-security risks in their own businesses, which could result in losses to J.P. Morgan or its clients. While measures have been developed which are designed to reduce the risks associated with cyber-security, there is no guarantee that those measures will be effective, particularly since J.P. Morgan does not directly control the cyber-security defenses or plans of its service providers, financial intermediaries, and companies in which they invest or with which they do business. Use of AI Tools may lead to increased risks of cyber- attacks or data breaches and the ability to launch more automated, targeted and coordinated attacks due to the vulnerability of AI technology to cybersecurity threats. 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 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, or be otherwise harmful. J.P. Morgan typically incorporates human oversight to reduce the risk of acting on potentially defective outputs. AI Tools present Data Sources Risks and Cybersecurity Risks (as further 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. Further, 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. Risks That Apply Primarily to ESG/Sustainable Investing Strategies 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 accuracy 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 the data to J.P. Morgan 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. Investment approaches that incorporate environmental, social and governance (ESG) considerations or sustainable investing 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 may invest in securities or industry sectors that underperform the market as a whole or underperform other strategies screened for ESG standards. 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 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. AI Tools often use data feeds from a number of sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool will be unable to properly function or their operation may be adversely impacted. The 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. 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. Cyber-security 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 cyber-security, including: theft, loss, misuse, improper release, corruption and destruction of, or unauthorized access to, confidential 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. Cyber-security 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 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 33817_COL 11-05-2025 Page 8 of 15  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. 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 practices and the Advisor’s assessment of such practices can change over time. J.P. Morgan takes a global approach to ESG and sustainable investing, and the solutions offered through our sustainable investing platform meet our internally developed criteria for inclusion in our sustainable investing platform and, where applicable, take into account ESG or sustainable investing regulations. As part of the due diligence process, the manager solutions team of JPMPI or any of its affiliates applies an eligibility framework that establishes minimum criteria for determining the universe of funds and strategies to be considered for inclusion in the ESG Strategies offered to our clients. 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 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. 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. 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. 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. categories, 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. 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. Further, 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. JPMS and its affiliates do 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 revenue calculations and estimations, that 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 33817_COL 11-05-2025 Page 9 of 15  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 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. • Tracking the index. Certain funds track financial indexes in which J.P. Morgan retains various intellectual property rights. As a result, 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 which track the same indexes used by the ETFs and index mutual funds or which may be based on the same, or substantially similar, strategies that are 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. • 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. 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. 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 • 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. Further, market volatility may adversely 33817_COL 11-05-2025 Page 10 of 15  offering. Stable value assets are subject to counterparty risk of the insurers that provide the fund’s book value liquidity. to be paid to the SEC by JPMCB and an affiliate in a related and concurrent settlement with the SEC. Risks Associated with Particular Types of Securities C. the 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. 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. 2) 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. 3) 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. 1) On December 18, 2015, JPMS and JPMCB (together, Respondents) entered into a settlement with the SEC resulting in the SEC issuing an order (Order). The Respondents consented to the entry of the Order that finds that JPMS violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 and Rule 206(4)-7, and JPMCB violated Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The Order finds that JPMCB negligently failed to adequately disclose (a) from February 2011 to January 2014, a preference for affiliated mutual funds in certain discretionary investment portfolios (the Discretionary Portfolios) managed by JPMCB and offered through J.P. Morgan’s U.S. Private Bank (the U.S. Private Bank) and the Chase Private Client lines of business; (b) from 2008 to 2014, a preference for affiliated hedge funds in certain of those portfolios offered through the U.S. Private Bank; and (c) from 2008 to August 2015, a preference for retrocession-paying third-party hedge funds in certain of those portfolios offered through the U.S. Private Bank. With respect to JPMS, the Order finds that, from May 2008 to 2013, JPMS negligently failed to adequately disclose, including in documents filed with the SEC, conflicts of interest associated with its use of affiliated mutual funds in the Chase Strategic Portfolio (CSP) program, specifically, a preference for affiliated mutual funds, the relationship between the discounted pricing of certain services provided by an affiliate and the amount of CSP assets invested in affiliated products, and that certain affiliated mutual funds offered a lower-cost share class than the share class purchased for CSP. In addition, the Order finds that JPMS failed to implement written policies and procedures adequate to ensure disclosure of these conflicts of interest. Solely for the purpose of settling these proceedings, the Respondents consented to the Order, admitted to the certain facts set forth in the Order and acknowledged that certain conduct set forth in the Order violated the federal securities laws. The Order censures JPMS and directs the Respondents to cease- and-desist from committing or causing any violations and any future violations of the above-enumerated statutory provisions. Additionally, the Order requires the Respondents to pay a total of $266,815,000 in disgorgement, interest and civil penalty. 4) 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 and controls in place to determine whether eligible customers were eligible to purchase the less expensive share classes. Solely for the Concurrently, on December 18, 2015, JPMCB reached a settlement agreement with the Commodity Futures Trading Commission (CFTC) to resolve its investigation of JPMCB’s disclosure of certain conflicts of interest to discretionary account clients of J.P. Morgan Private Bank’s U.S.-based wealth management business. In connection with the settlement, the CFTC issued an order (Order) finding that JPMCB violated Section 4o(1)(B) of the Commodity Exchange Act (CEA) and Regulation 4.41(a)(2) by failing to fully disclose to certain clients its preferences for investing certain discretionary portfolio assets in certain commodity pools or exempt pools, namely (a) investment funds operated by J.P. Morgan Asset Management and (b) third-party managed hedge funds that shared management and/or performance fees with an affiliate of JPMCB. The Order directs JPMCB to cease-and- desist from violating Section 4o(1)(B) of the CEA and Regulation 4.41(a)(2). Additionally, JPMCB shall pay $40 million as a civil penalty to the CFTC and disgorgement of $60 million satisfied by disgorgement 33817_COL 11-05-2025 Page 11 of 15  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. 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. 5) 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. 8) 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 6) 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 in the officers, directors, employees and agents as described 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. 7) On January 16, 2024, JPMS entered into a settlement with the SEC resulting in the SEC issuing an administrative order (the Order). JPMS 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 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 33817_COL 11-05-2025 Page 12 of 15  • 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; 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. 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. • 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 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 A. Code of Ethics • 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. • 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. 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: • The maintenance of personal securities accounts by JPMS’ investment JPMS and its affiliates (including JPMorgan Distribution Services, Inc.) and other related persons also may receive other forms of compensation in connection with the operation and/or sale of shares of affiliated or unaffiliated Funds, which may include distribution fees paid by certain Financial Advisors; 33817_COL 11-05-2025 Page 13 of 15  • 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 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 more 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 (collectively, JPM) recommends or purchases the publicly traded security of the asset manager or the separately managed accounts or funds that are managed or advised by the asset manager. JPM addresses this conflict by disclosing the ownership interest of the asset manager 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 February 26, 2025, 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. ITEM 12 — BROKERAGE PRACTICES JPMS and its related persons (including Financial Advisors) may recommend that Clients in the Program make investment options available to Plan participants that JPMS or a related person buys or sells for itself. 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 investment advice or for Plan 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 which 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. B. Factors Prompting Review of Client Accounts Other than a Periodic • 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; 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 place the interests of Clients in the Program before their own and those of JPMS; 33817_COL 11-05-2025 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 being responsible for supervising that Financial Advisor generally. 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 more 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. Further, 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 11-05-2025 Page 15 of 15 

FORM ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE J.P. MORGAN MANAGED INVESTMENT SERVICES PROGRAM C. Material Relationships with Related Persons and Potential Conflicts of Interest ................................................................... 27 D. Participation or Interest in Client Transactions and Other Conflicts of Interest .................................................................................. 29 E. Account Errors and Resolutions ................................................. 31 Code of Ethics ............................................................................ 31 F. G. Review of Accounts .................................................................... 31 Testimonials and Endorsements ................................................ 32 H. Financial Information ................................................................ 32 I. J.P. Morgan Securities LLC November 5, 2025 ITEM 4 — SERVICES, FEES AND COMPENSATION A. Description of Firm and Advisory Services 383 Madison Avenue New York, NY 10179 (800) 392-5749 chase.com/managed-account-disclosures This wrap fee disclosure brochure (Brochure) provides information about the qualifications and business practices of J.P. Morgan Securities LLC (JPMS) relating to the J.P. Morgan Managed Investment Services Program (the Program). If you have any questions about the contents of this Brochure, please contact us at 1-800-392-5749. 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. 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 wrap fee programs and providing certain consulting services to defined contribution plan sponsors. You can obtain brochures for the other programs by contacting us at 1-800-392-5749. 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. This wrap fee program ADV disclosure brochure applies to all of your Program accounts, including any Program accounts you open in the future with your J.P. Morgan Private Client Advisor or J.P. Morgan Financial Advisor, each referred to as an investment advisory representative (IAR). Annually we will provide you with a copy of our updated wrap fee program ADV disclosure brochure or a summary of material changes from the brochure previously provided to you. Retain this document for future reference as it contains important information if you decide to open new wrap fee program accounts with your IAR. You can obtain a copy of the current Brochure at any time by contacting your IAR. ITEM 2 — MATERIAL CHANGES This section describes the material and other changes to the Brochure since the initial Brochure dated October 9, 2025. ITEM 3 — TABLE OF CONTENTS JPMS offers investment advisory services through several separate channels. Similar wrap-fee programs that offer the same and similar investment strategies are offered in the different sales channels and at different fee levels with different features and with different execution experiences. For example, certain traditionally traded investment strategies available in the Advisory Program (as defined in the Form ADV Part 2A, Appendix 1, Wrap Fee Program Brochure for a different sales channel of J.P. Morgan Securities LLC) are available in the Program as a model at a lower manager fee, and the Liquidity Management Strategy is available in a different sales channel at a lower fee. The wrap-fee clients pay for investment advisory services will vary depending on the investment advisory program clients select. Information about other wrap fee programs sponsored by JPMS are contained in separate brochures, which can be obtained upon request from your IAR or at the SEC’s website at adviserinfo.sec.gov. JPMS also maintains a separate website, available at chase.com/managed-account-disclosures, that contains the wrap fee Program brochure for the Program and other important disclosures as well as the advisory brochures for J.P. Morgan Private Investments Inc. (JPMPI), J.P. Morgan Investment Management Inc. (JPMIM) and J.P. Morgan Wealth Management Solutions Inc. (WMS). This Brochure provides information about JPMS and the J.P. Morgan Managed Investment Services Program, an investment advisory program sponsored by JPMS and offered through IARs. JPMS has retained certain of its affiliates, including WMS, JPMPI, JPMIM and J.P. Morgan Chase Bank, N.A. (JPMCB), to provide services on a delegated basis in connection with the Program, as described below. Many of the tools and analytics that are used to support services provided through JPMS advisory programs are also available through JPMS without enrolling in an advisory program and paying a fee. Further, you could purchase these services separately from JPMS. However, while you can obtain similar products and services from JPMS without enrolling in an advisory program, you would not receive the same discretionary or non- discretionary account services offered through the advisory programs, the mutual fund share classes available to you will generally be more expensive, and you would generally not be able to obtain the same combination of financial planning and investment advisory services. The overall cost of purchasing the products and services separately will most ITEM 2 — MATERIAL CHANGES ............................................................. 1 ITEM 3 — TABLE OF CONTENTS ............................................................. 1 ITEM 4 — SERVICES, FEES AND COMPENSATION .................................. 1 A. Description of Firm and Advisory Services ................................... 1 Program Description and Services ............................................... 2 B. Client Profile and Account Selection ............................................ 5 C. Trade Confirmations, Statements and Performance Reporting ... 7 D. Proxy Voting, Corporate Actions and Other Legal Matters .......... 7 E. F. Fees and Compensation ............................................................... 8 ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........... 12 A. Program Minimum ..................................................................... 12 Cash Balances in Program Accounts .......................................... 12 B. ITEM 6 — PORTFOLIO MANAGER SELECTION AND EVALUATION ....... 13 ITEM 7 — CLIENT INFORMATION PROVIDED TO portfolio managers . 25 ITEM 8 — CLIENT CONTACT WITH portfolio managers ....................... 25 ITEM 9 — ADDITIONAL INFORMATION ................................................ 25 A. Disciplinary Information ............................................................ 25 B. Other Financial Industry Activities and Affiliations .................... 27 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 33821_COL 11-05-2025 Page 1 of 32  likely differ from each advisory program’s advisory fees. Clients should consider the value of these advisory services when making such comparisons. JPMS will initiate the steps necessary, including receipt of assets to open a client’s Account, and will be available to receive contribution and withdrawal instructions. JPMS will communicate to the Portfolio Manager and/or WMS changes in a client’s financial situation or investment objectives. JPMS is authorized to direct the investment of dividends, interest and other income received into the Account in accordance with a client’s Investment Strategy. Sub-Advisory Services J.P. Morgan Personal Advisors: JPMS sponsors the J.P. Morgan Personal Advisors program that is not described in this Brochure. It offers investment strategies that are similar to investment strategies available in the Program Accounts, at lower fees and features including financial planning, not available in the Program Accounts. J.P. Morgan Personal Advisors is offered through JPMS Financial Advisors. It does not provide the same level of services and does not offer the same range of investment strategies, options or customization available in Program Accounts. B. Program Description and Services sub-adviser JPMS has retained an affiliate, JPMPI, to provide both discretionary and non-discretionary sub-advisory services for the Program (the Sub- Adviser). JPMPI, as a discretionary sub-adviser for Managed Accounts, determines strategic and tactical asset allocations, is responsible for security selection (i.e., selects the Funds and Portfolio Managers and Model Managers for investment) and determines portfolio construction. JPMPI, as a non-discretionary for Guided Accounts, makes recommendations regarding allocation guidelines and risk parameters for each Guided Account Model. Implementation and Overlay Management Services The Program is a managed account program that provides clients, working with their Advisor, access to select investment solutions to help meet their investment goals. These investment solutions include investment advice from affiliated and unaffiliated investment managers that provide model portfolios to JPMS to implement (Model Portfolios) of investments and respective weightings designed to pursue a particular strategy (Model Managers) and separately managed account (SMA) investment managers that are delegated investment discretion to manage client advisory accounts assets (Portfolio Managers). Portfolio Managers include multi- manager portfolios managed by JPMPI that seek to invest in one or more Funds (as defined below) and/or in individual securities following one or more Model Portfolios that may be provided by affiliated and/or unaffiliated Model Managers (the “Multi-Manager Strategies”). You can also select an asset allocation model customized to align with your risk profile (Allocation Models). Investment portfolios can combine Portfolio Managers and Model Managers as well as mutual funds and exchange traded funds (ETFs). JPMS has retained an affiliate, WMS, to provide various implementation and overlay management services in the Program. WMS provides the following portfolio coordination services (as applicable) with respect to clients' accounts enrolled in the Program: (i) continuously monitoring account holdings; (ii) rebalancing Accounts; (iii) implementing client instructions to purchase, hold, or sell securities; (iv) implementing reasonable restrictions requested by clients and accepted for the Program Accounts; and (v) implementing certain tax harvesting and tax transition services. WMS also implements investment instructions furnished to JPMS by Model Managers and certain Portfolio Managers with respect to the securities to be purchased, held or sold for clients' Accounts. WMS exercises limited investment discretion, in that it does not generally use its investment discretion in the selection of the individual securities, but rather defers to the applicable manager of the Investment Strategy. In this Brochure, we refer to: mutual funds that hold more non-traditional investments and employ more complex strategies than traditional mutual funds as “Liquid Alternative Funds;” mutual funds, ETFs, and Liquid Alternative Funds collectively as “Funds;” a single- or multi-asset class investment strategy(ies) as “Investment Strategy(ies)”; the Funds managed by affiliates of JPMS (currently, the affiliates that sponsor or manage J.P. Morgan Funds include JPMPI and JPMIM) as “J.P. Morgan Funds;” Funds managed by third parties as “non-J.P. Morgan Funds;” and affiliated or unaffiliated investment advisers that provide discretionary investment management in SMAs, and brokerage and reporting services in connection with the Accounts, as “Portfolio Managers” (JPMIM and JPMPI, affiliates of JPMS, each act separately as a Portfolio Manager in the Program, as described below). Investment Strategies generally provide for a minimum percentage of the Advisory Account to be held in cash. If, due to withdrawals, fees or otherwise, the value of the cash allocation becomes a debit, JPMS or its affiliates will sell sufficient shares in the Fund(s) or securities within the Investment Strategy at the direction of the Portfolio Manager, or in the case of Allocation Models, that is then most over-weighted based on actual dollar value to clear the debit and replenish the cash allocation to the designated target percentage required by a client’s Allocation Model. WMS monitors the Program Accounts relative to established guidelines, and strategies are managed, rebalanced, and adjusted as appropriate given your investment objectives. Tax Harvesting from available JPMS-approved Clients invest in the Program by establishing one or more Program accounts (each, an Account). Working with your IAR, you will select the investment solution or target asset allocation for the Account, as appropriate to your Account objective, risk tolerance, liquidity needs and time horizon, choosing investment solutions. When working with your IAR, you can opt to give full investment discretion to JPMS and its affiliates or a third party through a single- or multi-asset Account, or you can retain investment discretion while receiving ongoing advice and guidance from your IAR in your Account, as described below. JPMS delegates some or all of its investment advisory discretionary authority and functions to its affiliates, including WMS and JPMPI, as well as to third-party managers. JPMS Services JPMS will assist clients in determining the suitability of the Program and defining their investment objectives and selecting a suitable investment strategy (Investment Strategies, and each, an Investment Strategy). Once a client has approved a particular Investment Strategy recommended in their Investment Proposal (as defined below), WMS will implement the recommended Investment Strategy, taking into account any reasonable investment restrictions. As part of its investment management services for taxable Accounts, WMS has the ability to sell certain investments at a loss in an effort to potentially offset or defer a client’s tax liability (Tax Harvesting) at its discretion, unless the client specifically elects to opt out of Tax Harvesting on their Account. While utilizing Tax Harvesting, an Account’s holdings can differ from those Accounts that do not utilize Tax Harvesting, and, therefore, its performance will likely differ. There is no guarantee that Tax Harvesting will perform as expected or that specific benefits will be obtained for any particular client. Accounts will be evaluated for Tax Harvesting; however, if losses do not meet thresholds, or if appropriate substitutes are not available, Tax Harvesting will not be taken even if losses are in the account. WMS will prioritize Tax Harvesting subject to other activity (tactical trades, rebalancing, etc.). The implementation of Tax Harvesting may have an adverse effect on investment performance and result in adverse tax consequences, including, but not limited to, gains derived from the sale of the security held during the wash sale period. Further, the tax consequences of Tax Harvesting may be challenged by the Internal Revenue Service (IRS) or any other tax authority. WMS will Tax Harvest only from JPMS does not make any investment decisions about the purchase and sale of underlying Funds or specific securities in an SMA or a Manager Model. 33821_COL 11-05-2025 Page 2 of 32  Investment Strategies for which it acts as Implementation Manager. Therefore, WMS will not consider Portfolio Manager assets when Tax Harvesting, except for Multi-Manager Strategies. below the target estimated tracking error, regardless of the tax liability that the Account’s owner may incur, at WMS’ discretion. Clients should understand that the sale of these securities may generate taxable income, and there are no guarantees regarding tax implications with respect to a client’s portfolio. Use of tax transition services can impact the timing of trades and delay trading to model when securities are used to fund an Account. If the client has selected a Portfolio Manager as part of the model, because the Portfolio Manager has trading discretion, portfolios may appear misaligned until all trades to model and Portfolio Manager trades are completed. Transition services will optimize for the amount to be added or reduced from the Portfolio Manager. Portfolio Managers can impact tax liability thresholds as part of their portfolio management. Clients should discuss their specific tax transition and portfolio with their tax professional. Requesting that any security be held for an extended period of time can result in deviation from the Investment Strategy or target asset allocation guidelines that a client has selected. The longer the time period for transition, the longer the deviation from the Investment Strategy or target asset allocation guidelines. As such, implementation may differ from client Accounts not using transition services (e.g., tactical trades may not be done for accounts in transition), and the client’s performance will differ from the performance of other clients that are invested in the same target asset allocation or Investment Strategy. Tax liability thresholds that are in place for an Account will be applied each new tax year unless the client, working with their Advisor, updates the parameters of their transition plan. If the client wants to add securities to their Account utilizing tax transition services, clients need to create a new transition plan or use their existing transition plan. Generally, Tax Harvesting entails a repurchase of the sold security after the “wash sale” (i.e., 30-day) period. Generally, under the wash sales rules, if a client sells a security for a loss and the client repurchases the same (or a substantially identical) security either 30 days before or 30 days after the date of the sale, the loss is disallowed. The wash sale rules apply to transactions in not only that Account but also to transactions in all other accounts held by the client, the client’s spouse and certain entities controlled by them (“related parties”), whether these accounts are held with JPMS or its affiliates or other financial institutions. WMS will not consider trading activity in these other securities accounts and also will not consider dividends generated in your Accounts, and it is the client’s responsibility to monitor and comply with the wash sale rules with respect to such accounts. Additionally, incorrect assumptions about a client’s tax attributes and transactions outside of the account being managed may lead to inefficient tax management. During the wash sale period, assets that will be invested at the discretion of WMS can include Funds during the wash sale period. Funds are investment companies and have certain embedded costs, including portfolio management fees, of which the client will bear a proportionate share while invested in the Fund. Such costs are in addition to other advisory or management fees charged to the client. The client is responsible for understanding the merits and consequences of Tax Harvesting. WMS is not responsible for validating the correctness of client- provided cost basis for securities transferred into the account. For Program Accounts, WMS will manage Tax Harvesting for the particular Program Account but cannot monitor Tax Harvesting across all client accounts enrolled in the Program. Tax Harvesting is not implemented with a view to any investments a client may own outside of the Program, regardless of whether WMS is aware of such outside investments, unless separately agreed in writing by WMS. For additional information, refer to the “Tax Risks and Risks That Apply to Tax Harvesting” below. To create a new transition plan, clients should work with their IAR either to update their existing transition plan or put a new one into place. If an updated or new transition plan is not received by WMS in a timely manner (i.e., up to 10 business days), WMS will continue to operate under the existing transition plan with regard to the securities added to the Account in trading those securities to model. If client has elected tax transition services and does not have an active or updated transition plan in effect when securities are added to the Account, WMS will apply minimum tax liability as a parameter for the tax transition services provided. WMS does not verify the accuracy of any external Account information, including Account statements provided by clients from third parties. The validity of recommendations provided by WMS and any analyses contained in any report provided by WMS is dependent upon the accuracy and thoroughness of the data and information provided by the client. The use of incomplete or inaccurate data and information will result in different outcomes. The tax implications in any report or any guidance provided by WMS pursuant to a client’s tax transition plan are not guaranteed and should not be viewed as tax advice. Actual tax incurred by clients will vary from any illustrated projections provided by JPMS pursuant to a client’s tax transition plan. Clients should contact their tax professional to review their tax transition plan. To generate potential tax losses, WMS will sell positions that have experienced a capital loss. The proceeds will generally be invested in Funds as determined by WMS during the “wash sale” period. The investment in the Funds is designed to provide market exposure during the wash sale period, but there is no guarantee that the proceeds that are invested in the Funds will perform the same as the original position sold to recognize a tax loss. The performance of the Funds and the price of such investments may be higher or lower than the original position. In addition, the deductibility of losses recognized in the Program Accounts may be subject to certain limitations depending on a client’s particular circumstances, such as investments in other Managed or Guided Accounts (as defined below) that are not covered by the Tax Harvesting analysis and investments a client makes outside the Program and the aggregate net capital losses a client recognizes during the year. In general, specific tax gain and loss requests are not appropriate for accounts enrolled in Tax Harvesting but may be implemented on an exception basis in the sole discretion of WMS. Clients that have elected transition services (as described below) cannot direct tax loss harvesting requests. WMS can limit the maximum amount of tax losses permitted in an Account. Tax Transition Services If a client seeks to transfer securities to fund their taxable Program Account, they may request that such securities be sold in a more tax- efficient manner over an extended time. Clients will work with their IAR to discuss which securities (or any particular security or securities) can be held in their portfolio and sold over an extended period of time, at WMS' sole discretion. WMS can reject or accept any tax transition plan in its discretion, including the securities permitted to be included in a transition plan. To determine whether certain equity securities are eligible for a transition, WMS references the constituents of certain market indices; however, WMS does not provide ongoing research or oversight on those positions. If the client elects not to use or to discontinue tax transition services, WMS will manage the Account without tax transition services, which would result in the recognition of any short- or long-term taxable gains, which could be significant depending on the circumstances. WMS will not be responsible for any such gains that may be realized in managing the client’s Account after the termination of tax transition services. WMS will consider specific tax gain and loss requests for taxable Accounts that are not enrolled in tax transition services (which request may be accepted or rejected in WMS’ discretion), and the extent to which WMS implements such a request may be affected by its qualitative assessment of market liquidity and other factors. For tax transition services, the client selects the estimated tracking error and tax liability thresholds for an Account subject to any limitations imposed by WMS. Clients can modify their transition plan at any time. Modification will result in realization of the full tax liability threshold of the modified plan. If an Account is funded with securities that, in aggregate, result in a tracking error that is greater than the target tracking error for that specific program, WMS will sell positions as necessary to reach or fall 33821_COL 11-05-2025 Page 3 of 32  Trade Execution Fractional share trades where a “sell” order is submitted and JPMS does not hold any shares will require JPMS to purchase one share in the market before submitting the sell order to be able to round the fractional share up to a whole share before the order can be sent for execution. As such, there could be a delay in execution of such “sell” order while JPMS obtains a share to be able to submit the fractional share trade order. As applicable, dividends are paid on fractional share positions. The dividend payable will be an amount proportionate to the fractional interest. Clients direct brokerage to JPMS. WMS can designate another broker or dealer if it believes the other broker or dealer will provide better execution than JPMS or its clearing broker. Although WMS has discretion to select brokers or dealers other than JPMS or its affiliates, WMS generally places such trades through JPMS or its affiliates because the Advisory Fee (defined below), paid by each client Account, only covers execution costs on trades executed through JPMS or its affiliates. Execution costs include fees we pay to exchanges and/or regulatory agencies on certain transactions. Certain securities included in portfolios can be less liquid or are traded infrequently. To fulfill its duty to seek best execution of transactions for client Accounts, WMS can select broker-dealers other than JPMS or its affiliates to affect a trade for a client Account, and any execution costs charged by non-JPMS broker-dealers will be paid by the client Account. Refer to “Trading Away and Associated Costs” for more detail. Corporate Actions and Proxy Voting: Fractional shares participate in both mandatory corporate actions (e.g., stock splits, mergers) as well as voluntary corporate actions (e.g., tender offers). Fractional share positions are not eligible for proxy voting. Therefore, clients will not have voting rights for any of the fractional shares held in their Account. Clients will only be allowed to participate in proxy voting with respect to whole share positions. For additional information about fractional share trading, please contact your Advisor. Benchmarks WMS’ primary objective in broker-dealer selection is to comply with its duty to seek best execution of orders for clients. Best execution does not necessarily mean the lowest commission or price, but instead involves consideration of a number of factors. In evaluating whether another broker or dealer will provide better execution, WMS will take various criteria into consideration in assessing the provider including, but not limited to, its market making ability, net cost or net realization from trade, price per unit of security, reliability and financial stability. Some Investment Strategies and Funds manage to a benchmark or index. Client portfolio holdings may differ significantly from the securities in the benchmark or index and may also hold far fewer securities than the benchmark or index. As a result, client portfolios can have higher or lower levels of risk and volatility than that of the benchmark or index. Liquid Alternative Funds In order to comply with principal trade restrictions, orders for the Program are routed for agency execution. In connection with transactions executed for Program Accounts, when permitted by applicable law and JPMS policy, WMS, acting on behalf of client Accounts, enters into transactions in securities and other instruments with or through JPMC, and causes Accounts to engage in principal transactions. A “principal transaction” occurs if WMS, acting on behalf of client Accounts, knowingly buys a security from, or sells a security to, JPMS or its affiliate's own account. Liquid Alternative Funds available are subject to asset threshold requirements. Liquid Alternative Funds refer to Funds that have one or more of the following characteristics: (1) hold non-traditional investments, (2) trade more frequently, and (3) employ more complex trading strategies and that have higher total expense ratios (plus higher annual operating expenses) than traditional mutual funds. Fractional Share Trading US Endowments and Foundations Investment Strategies In the discretion of WMS, orders will be placed for a fractional share quantity of a security with JPMS. Fractional share trading allows for the purchase and sale of fractional share positions of equity securities, closed- end funds, ETFs and other eligible securities which reduces tracking error relative to Investment Strategies by allowing Accounts to invest closer to Investment Strategy allocations by not having to round security positions to whole shares. The US Endowments & Foundations (E&F) Investment Strategies are designed to primarily service the investment goals of nonprofit entities (i.e., endowments and foundations). The Investment Strategies are made available to clients of IARs and are appropriate for a Growth investment strategy. The endowment investing approach is generally characterized by a longer-term investment horizon. A long-term investment mindset can allow a client to look through the short-term volatility and focus on the potential of enhancing long-term returns. Retirement Accounts Fractional share trading is not available for the same Investment Strategies in other JPMS channels. Orders that include a fractional share quantity cannot be routed to an exchange or other market makers for execution. Therefore, the fractional share component of an order will need to be combined with an order from a JPMS facilitation account to make a whole share, which can then be routed for execution. This means that JPMS will be trading alongside the customer fractional share trades to facilitate the order, which will be routed for execution in an agency capacity. JPMS will not act as principal or counterparty to the customer Account when executing these orders. For Accounts established for retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA) and for individual retirement accounts (IRAs) (collectively, retirement Accounts), when providing services under the Program, JPMS is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the Code with respect to the assets of the retirement Accounts invested in the Program. Additionally, for retirement Accounts that invest in the Program with JPMPI as Sub-Adviser or when WMS provides implementation or overlay services, JPMPI and WMS are “fiduciaries” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the Code with respect to the assets that they manage in the Program. Retirement Accounts can be restricted from investing in Funds that have a certain relationship with J.P. Morgan. As a result, performance of such retirement Accounts would differ from non-retirement Accounts invested in the same Investment Strategy without such restrictions. As part of the fractional share process, JPMS maintains a facilitation account that holds a small number of shares of eligible securities in inventory for sell orders and keeps cash on hand for buy orders. JPMS adds a fractional share to aggregated buy or sell orders so that the order is rounded up to whole shares, and the additional fractional share is purchased or sold by JPMS. Due to a variety of factors — such as the number of trades executed, allocating fractional shares to multiple clients at one time, and market price volatility—JPMS could accrue a net profit or loss in its fractional share facilitation account. Clients can refer to jpmorganchase.com/qpam for important documents related to the final exemptive relief that allows JPMS, JPMIM, JPMPI and (if and when necessary) WMS (the JPMC Affiliated QPAMs) to act as a QPAM under Prohibited Transaction Class Exemption (PTE) 84-14, as amended. JPMS is under no obligation to continue to offer fractional share trading in the future and in its discretion, may discontinue fractional share trading at any time. Upon termination of a client Account, fractional share positions will be sold and the proceeds placed in the sweep applicable to the Account. 33821_COL 11-05-2025 Page 4 of 32  C. Client Profile and Account Selection Client Profile and Account Opening to provide portfolio implementation services for the client’s Account invested in Model Managers (as further described below); and (vi) provide investment advisory services pursuant to the terms of the Advisory Agreement as they relate to the Program including, but not limited to, (a) open accounts with, and buying and selling shares of, the Funds; (b) modify asset allocations in Allocation Models and establish ranges allowed for each asset class in Allocation Models; (c) invest and reinvest the Account assets from time to time in Funds, including Funds to which JPMS or an affiliate or an outside broker, investment manager, or other bank or financial institution is providing investment management, custodial, transfer agency, or other products or services; and (d) sell sufficient shares of Funds or securities most overweighted based on actual dollar value to replenish the cash allocation in the Allocation Model. Portfolio Manager/Model Manager Selection Prior to opening a Program Account, the IAR consults with the client or prospective client to create a “Client Profile” based upon the client’s responses to questions regarding their financial situation, investment experience, investment objectives, time horizon, and risk tolerance. The information is evaluated and incorporated into an “Investment Proposal.” The Investment Proposal provides a recommendation of one or more Portfolio Managers, Model Managers, Allocation Models or Investment Strategies, and specifies Funds and, if appropriate, Model Managers that are included in the Model or Investment Strategy. The recommendation is the result of an objective scoring system based on the client’s responses to questions used to create the Client Profile referenced above. Based on the information in the Client Profile and Investment Proposal, the IAR will assist the client in selecting an Investment Strategy, Model, Model Manager or Portfolio Manager and will discuss the recommendation with the client to ensure that it is appropriate for their specific investment needs and risk tolerance. You will inform JPMS of any reasonable restrictions you wish to impose on the management of your Account, including specific securities or types of securities not to be purchased for your Account. Clients agree to the terms of applicable advisory and brokerage service agreements. The client’s selection of an Investment Strategy or Model is reflected in the Investment Proposal. Account Selection If JPMS recommends and the client selects one or more Portfolio Managers or Model Managers, each Portfolio Manager's or Model Manager's Investment Strategy will act independently of the other(s). JPMS will coordinate its services with those of the Portfolio Manager or Model Manager. JPMS or its affiliates will monitor and regularly evaluate, as appropriate, the performance of each Portfolio Manager and Model Manager to determine if it is following its stated investment philosophy for the Investment Strategy selected and that there have been no material changes in the business and operations of a client’s Portfolio Manager or Model Manager. The Portfolio Manager or Model Manager, not JPMS, makes investment decisions about the purchase and sale of underlying securities in a client’s Account and JPMS is not obligated to monitor each transaction directed by a Portfolio Manager or Model Manager for conformity with a client’s investment objectives and restrictions. Electronic Communications Clients have the option of investing in fully discretionary Managed Accounts (as discussed below), with J.P. Morgan or a third-party Portfolio Manager exercising investment discretion, or Guided Accounts (as discussed below), where a client would maintain investment discretion, with guidance from an IAR. Managed Accounts can also invest in Model Managers that provide non-discretionary portfolios. Based on information provided by the client, including any requested restrictions, JPMS will assist the client in selecting one or more investment solutions as described below. includes the selection of As a condition to receiving services through the Program, you must be willing to accept the terms of a global electronic consent, which requires to electronic delivery of Program documents and agreeing communications. In addition, as part of opening an Account, clients are required to complete an Account application and enter into an Investment Advisory Services Agreement and other Account agreements (collectively, the Client Agreement). The Client Agreement along with other disclosures and notices will be delivered to clients in electronic format, including through email or other electronic means. JPMS will not send paper versions of documents to clients as part of the Program unless required by applicable law or in JPMS’ sole discretion. In addition, JPMS may require that some or all of the Account opening processes be completed electronically and may provide some or all Account-related documentation online. Managed Accounts. Clients can opt for a discretionary managed account that Investment Strategies provided by J.P. Morgan and/or third-party investment managers (Managed Account) in alignment with the client’s risk profile and goals. Managed Accounts generally include either single- or multi-asset solutions that follow J.P. Morgan's asset allocation guidance and investment vehicle selection. Managed Accounts generally include either single or multi-asset solutions offered by JPMPI that follow J.P. Morgan’s asset allocation guidance and investment vehicle selection (“Core Solutions”). Clients can also select single strategies managed by affiliated or unaffiliated Portfolio Managers and Model Managers. Guided Accounts. Clients can opt to invest in a Guided Account (Guided Account), in which the client selects an asset allocation Model customized to align with their risk profile. The customized investment portfolio can combine investments in Portfolio Managers and Model Managers as well as mutual funds and ETFs. Clients retain investment discretion to (i) select and change investment products and (ii) define and adjust the target asset allocation and target portfolio. Guided Accounts may be implemented across a spectrum of asset classes, including equities, fixed-income and alternative investments. Appointment and Authorization Program clients must provide JPMS with a valid email address and are required to notify JPMS immediately in the event their email address changes or becomes inaccessible by visiting chase.com or by contacting JPMS at 1-800-392-5749. Important client notices, including new or amended agreements or documents, will be sent by email; therefore, it is important that clients maintain an accurate email address at all times. If a client fails to provide or maintain accurate contact information, including an email address, JPMS reserves the right to terminate that client’s participation in the Program. JPMS will attempt to contact clients by other means when it determines that a client’s email address is invalid. Clients must also own or have access to an electronic device with the necessary hardware and software as an initial and continued condition of participating in the Program. Refer to the Online Service E-Sign Disclosure and Consent for additional terms and conditions regarding electronic delivery of Program communications. Client Agreement As a condition to receiving investment management services through the Program, clients are required to enter into a Program Client Agreement. The Client Agreement authorizes JPMS to act as the client’s investment adviser, with investment discretion and trading authority, and authorizes Clients in the Program authorize JPMS to: (i) establish and modify the asset allocation for the particular Investment Strategy approved by the client, including adding a cash allocation where you have not allocated cash to the model; (ii) evaluate, select and monitor the Funds and Portfolio Managers and Model Managers; (iii) delegate its authority under the Client Agreement to its affiliates, including WMS and JPMPI; (iv) engage, in its sole discretion and on the client’s behalf, WMS or another affiliate as an "Overlay Manager" and an "Implementation Manager" to provide portfolio implementation and coordination services for the client’s Account (as further described below); (v) engage one or more Portfolio Managers to manage the client’s Accounts, or one or more Model Managers to provide Manager Models, and 33821_COL 11-05-2025 Page 5 of 32  JPMS to perform its services directly, or through or by delegating performance to, affiliated or unaffiliated service providers, as JPMS may from time to time designate. The Client Agreement incorporates a separate brokerage Account agreement that clients must consent to in order to enroll in the Program. Restrictions on Management of Accounts Unless enrolled in Transition Services, clients funding Accounts with securities direct JPMS, WMS or the Portfolio Manager to liquidate the securities on behalf of the client and allocate the proceeds in accordance with the Investment Strategy selected in the Investment Proposal. JPMS, WMS or the Portfolio Manager, on a best-efforts basis, will sell a portion or all of any securities that are not consistent with the Investment Strategy stated in the Investment Proposal. Neither JPMS, WMS nor the Portfolio Manager will advise clients regarding the liquidation of these securities. Liquidation will be done free of commission charges or spread on fixed income trades unless the trade is placed away from JPMS. Refer to “Trading Away and Associated Costs” below for more detail. Depending on the type of security involved, liquidation may result in redemption charges and taxable gains or losses. Before contributing mutual fund shares, clients should consider if they paid a front-end sales charge, will incur a contingent deferred sales charge or a redemption fee in the event the mutual fund shares are liquidated in accordance with the Investment Strategy selected. These mutual fund fees and charges are the responsibility of the client and are in addition to the wrap fee. Clients should review the potential tax consequences of these liquidations with their tax professional before funding their Account with securities. JPMS and its affiliates do not provide tax advice. If non-U.S. denominated securities are sold, the client will incur currency conversion charges. Clients can request reasonable restrictions on management of their Account including particular securities or categories of securities related to a sector or industry (e.g., weapons or tobacco), that will be implemented subject to acceptance by JPMS, WMS or the Portfolio Manager and in their sole discretion. JPMS, WMS or the Portfolio Manager may rely on the information about a company, industry classification, industry grouping, and issuer screening provided by J.P. Morgan or a third party to implement the investment restrictions. Category restrictions aim to screen companies with revenue derived from the restricted category, but they do not exclude all companies with any tie or revenue derived from such restricted category. JPMS does not review, guarantee or validate third-party screenings or processes. Issuer screenings and processes to implement category investment restrictions are not absolute and may change at any time and could result in the portfolio holding investments in companies that derive revenue from the restricted category. If a client’s investment is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event to the client. When liquidating securities for purposes of establishing a client’s Account, JPMS will be acting as your broker, not your investment adviser. Liquidations will be effected promptly after receipt into and acceptance of the Account by JPMS, WMS or the Portfolio Manager, at the then prevailing market prices, subject to market conditions and applicable JPMS policies. If a particular security cannot be liquidated or is not eligible for the Program, it will not be used to fund an Account and your IAR will work with you regarding disposition of the securities. Any restrictions a client imposes on the management of the Account can limit the ability to make investments or take advantage of opportunities and can cause the Account to perform differently than similar unrestricted accounts. Neither JPMS, WMS nor the Portfolio Manager are required to accept investment restrictions that they deem unreasonable and may decline an Account when they deem any client requested restriction unreasonable. Rebalancing Accounts Rebalancing has tax implications for most clients, other than those with tax- advantaged Accounts. Accounts will be rebalanced if the percentage variance at the asset class level exceeds a threshold amount that has been established as effective for rebalancing to the Investment Strategy. If JPMS, WMS or the Portfolio Manager accepts a restriction as reasonable, neither JPMS, WMS nor the Portfolio Manager has the discretion to invest the portion of the client Account that would have been invested, or was previously invested, in the restricted security in the other securities in the Account (on a pro rata basis), to select a substitute security or to hold those assets in cash. Substitute Funds are likely to have fees or expenses that are higher than the Funds normally used in the Program. In the event that a restriction request for a Fund that is currently held in a client’s Account is accepted, the Fund will be sold and a client may experience tax consequences. Category and security restrictions will not be applied to strategies that invest only in mutual funds, ETFs and other pooled investments, nor will they be applied to investments made by mutual funds, ETFs and pooled investments, so it is possible that client restrictions would not have any practical effect on an Account comprised primarily of mutual fund and ETF investments. Implementation of Investment Strategy WMS monitors Program Accounts relative to established guidelines. Investment Strategies are managed, rebalanced and adjusted as appropriate given the clients’ investment objectives. In the normal course, WMS rebalances Accounts periodically to the allocation in the chosen Investment Strategy when the asset allocation percentages deviate from established parameters set by WMS and/or, for Guided Accounts, when requested by a client or their IAR. When a client creates a Guided Account Allocation Model with no cash allocation, WMS will add a cash allocation to the model, at its discretion. To rebalance an Account, shares of Funds that are underweight or overweight compared to their asset class percentages in the Investment Strategy will be bought or sold, as applicable, until the Account holdings are consistent with the Investment Strategy. Over time, the Funds in the Account will appreciate (or depreciate) in value at different rates. Without rebalancing, the change in the percentages of each asset class held will change the level of risk from the risk level that is associated with the original allocations in the selected Investment Strategy. Changes in the sale of Fund shares may generate taxable gains or losses in a client Account. in accordance with each client’s specific The rebalancing frequency is dependent on whether a client has a Managed Account or Guided Account. After JPMS opens an Account for the client, WMS or Portfolio Manager, as applicable, will implement the selected Investment Strategy taking into account any reasonable investment restrictions a client has placed on management of the Account, as accepted by JPMS, WMS or the Portfolio Manager. JPMS, WMS or the Portfolio Manager manages client Accounts in investment the Program guidelines, objectives and any reasonable restrictions on investing in specific securities that the client provides to JPMS in writing and JPMS has accepted. Funding Accounts Cash or securities can be used to fund Accounts. Investment management will begin after JPMS has accepted the Account into the Program. Account acceptance may be delayed or rejected if the Account is overfunded or underfunded relative to the amount stated in the Investment Proposal. Cash to fund an Account will be placed in the sweep option selected by the client. Guided Account clients can choose to have their Accounts automatically reviewed for rebalancing quarterly, semi-annually, or annually. The default setting for all accounts is annual, unless changed during enrollment to another selection, or at any time thereafter. If within a Guided Account there is an Investment Strategy in which WMS or an affiliate exercises discretion, that Investment Strategy can follow a different rebalancing schedule. WMS also will facilitate the rebalancing of a Program Account upon the client’s direction. Client directed activity (e.g., contributions and withdrawals) as well as model changes can also result in the rebalancing of a Program Account. In between reviews for rebalancing, a client’s Account 33821_COL 11-05-2025 Page 6 of 32  will drift from the initial asset allocations selected by the client for the Account and can even drift outside of recommended thresholds of an Allocation Model. to send to the Proxy Service (defined below) or a client, as applicable, proxy materials or annual reports where JPMS or its affiliates have not received proxies or related shareholder communications on a timely basis or at all. Managed Accounts invested in Core Solutions will be considered for rebalancing at least on a quarterly basis, at the discretion of WMS. WMS will continuously review client asset allocations relative to the selected Investment Strategy and will generally rebalance the Managed Account to the allocation in the chosen Investment Strategy when the asset allocation percentages deviate from established parameters. To rebalance the account, shares of Funds and/or securities held in the models advised by Model Managers that are underweight or overweight compared to their asset class percentages in the Investment Strategy will be bought or sold, as applicable, until the account holdings are consistent with the Investment Strategy. Over time, the Funds and/or individual securities in the Account will appreciate (or depreciate) in value at different rates. Without rebalancing, the change in the percentages of each asset class held will change the level of risk from the risk level that is associated with the original model and/or allocations in the selected Investment Strategy. An Account will not rebalance on the scheduled date if it is not eligible at that time (i.e., there is a transition plan in place). Rebalancing preferences may cause an Account's composition and performance to deviate from the Account's model. Upon evaluating the Account for rebalancing, WMS can decide not to rebalance the Account, in whole or in part, if in its discretion it reasonably believes it would be in the Account's best interest not to do so. If WMS determines that the Account should be rebalanced, it will initiate transactions with a goal of restoring the Account as closely as practicable to a client's model. Each client has the right to vote and is solely responsible for voting proxies for any securities and other property in the client’s Account. In the Program, clients can appoint an independent services provider designated by JPMS for purposes of voting proxies (Proxy Service) as the client’s agent and attorney-in-fact, and clients can authorize the Proxy Service, in its discretion, to vote proxies for any securities and other property in the client’s Account in accordance with the Proxy Service’s proxy voting guidelines in effect from time to time (or other guidelines that the Proxy Service has been instructed to use for particular Investment Strategies), copies of which are available on request. The Proxy Service is currently Institutional Shareholder Services Inc. (ISS). Information relating to ISS services is available on the ISS website at issgovernance.com. The ISS ADV brochure is available at the SEC’s website at adviserinfo.sec.gov. The Proxy Service’s role as the agent of clients applies only to proxies that the Proxy Service generally votes and does not apply to proxies with respect to which the Proxy Service declines to vote. A client who appoints the Proxy Service will not receive proxy materials or annual reports relating to securities and other property for which the Proxy Service has accepted responsibility for voting related proxies. In limited circumstances, the Proxy Service will not vote proxies. A client can revoke its appointment of the Proxy Service upon written notice to JPMS at J.P. Morgan Securities LLC, Attn: Proxy Voting Opt Out, Mail Code: IL1-0291, PO Box 1762, Chicago, IL 60690. If a client revokes their appointment of the Proxy Service, the client will receive all proxy materials and annual reports related to securities and other property in the client’s Account, and they will be responsible for voting such proxies directly or instructing any custodian that holds such securities and other property. JPMS can, in its discretion, change the Proxy Service. JPMS will not be deemed to have or exercise proxy voting responsibility or authority by virtue of any authority to hire or change the Proxy Service. Client Designation of Portfolio Manager in the Program For clients who have elected transition services, periodic rebalancing will not take place until the transition completes. Further, rebalance requests will not be entertained when Accounts are subject to transition services (as described below) and in transition. Instead, additional controls monitoring is done for these Accounts (i.e., tracking error drift monitoring). Once the transition completes, the Account is subject to rebalancing based on the frequency selected during enrollment. Custodian JPMS, in its capacity as an SEC-registered broker-dealer, provides clearing and trade execution services for and serves as the custodian for Account assets. JPMS is a “qualified custodian” as defined in Rule 206(4)-2 under the Investment Advisers Act of 1940, as amended (the Advisers Act). D. Trade Confirmations, Statements and Performance Reporting Except for Multi-Manager Strategies, the Portfolio Manager (or its agent) to a client’s Account is designated to receive, and act on a client’s behalf, all shareholder communications (including, but not limited to, proxy statements and other proxy solicitation materials; annual reports and semiannual reports; corporate actions with respect to securities in a client’s Account, such as any conversion option, execution of waivers, consents and other instruments) and to consent to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan distributed by the issuers of securities held in client’s Account and not required by law to be sent to a client. A client can revoke this consent at any time upon written notice to JPMS at J.P. Morgan Securities LLC, Attn: Document Services, Mail Code: IL1-0291, PO Box 1762, Chicago, IL 60690. Such revocation will not affect any other authority given to the Portfolio Manager to provide discretionary portfolio management for a client’s Account. The Portfolio Manager will not be obligated to take action or render any advice involving legal action on the client’s behalf with respect to securities or other investments, which become the subject of legal notices or proceedings, including bankruptcies. Corporate Actions and Other Legal Matters In the Program, WMS will receive and respond to corporate actions with respect to securities in a client’s Account, such as: any conversion option; execution of waivers; consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. Client Rights and Responsibilities to Take Action Clients will receive trade confirmations of all transactions unless they waive receipt of individual confirmations and instead receive a periodic statement of all transactions that will contain the information required to be in a confirmation. Guided Account clients cannot waive receipt of individual trade confirmations for Funds. Clients can elect to receive a periodic statement in lieu of individual confirmations and can later choose to receive from JPMS, at no additional cost, transaction confirmations for any prior transactions effected during the period in which the client previously elected not to receive separate transaction confirmations. Clients will not pay a different fee based upon this election and can rescind this election at any time upon written notice to JPMS. Clients will receive Account statements from JPMS, as custodian, at least quarterly (monthly for months when there is activity in their Account). Clients generally will also receive quarterly performance reports containing general market commentary and analysis, charts and graphs detailing the quarterly performance of the Account versus relevant industry benchmarks and indices for Accounts during the quarter. E. Proxy Voting, Corporate Actions and Other Legal Matters Neither JPMS nor its affiliates will vote proxies (or give advice about how to vote proxies) relating to securities and other property currently or formerly held in a client’s Account. JPMS and its affiliates will not be responsible or liable for: (1) failing to notify a client of proxies; or (2) failing Each client has the right and responsibility to take any actions with respect to any legal proceedings, including, without limitation, bankruptcies and shareholder litigation, and the right to initiate or pursue any legal proceedings, including, without limitation, shareholder litigation, including with respect to transactions, securities or other investments held in the client’s Account or the issuers thereof. JPMS is not obligated to render any advice or take any action on a client’s behalf with respect to securities or 33821_COL 11-05-2025 Page 7 of 32  $2,000,000–$4,999,999.99 0.60% $5,000,000–$9,999,999.99 $10,000,000–$14,999,999.99 0.60% 0.55% $15,000,000–$24,999,999.99 $25,000,000–$49,999,999.99 0.50% 0.40% 0.30% ≥$50,000,000 other property held in the client’s Account, or the issuers thereof, which become the subject of any legal proceedings, including, without limitation, bankruptcies and shareholder litigation, to which any securities or other investments held or previously held in the Account, or the issuers thereof, become subject. In addition, JPMS is not obligated to initiate or pursue any legal proceedings, including, without limitation, shareholder litigation, on behalf of a client’s Account, including, with respect to transactions, securities or other investments held or previously held in the client’s Account, or the issuers thereof. Model Manager Fees for the Program F. Fees and Compensation Wrap Fee Additional fees are charged by Model Managers (Model Manager Fees). The Model Manager Fee is an annualized asset-based fee that covers the Model management services provided by Model Managers. These Model Manager Fees are in addition to the Advisory Fees and vary depending on the Model Manager and the asset class. The Model Manager Fee is not included in the Advisory Fee. JPMS collects the Model Manager Fee from clients and pays the Model Managers. Model Manager Fees range from approximately 0.25% to 0.50%. The applicable Model Manager Fee rate for a specific Model will be stated in the Investment Proposal for the Account. The client’s actual Model Manager Fees will be reflected in the Account statement. Clients pay an annual asset-based account fee for the Program (Advisory Fee) to JPMS pursuant to (1) the applicable fee schedule and subject to any applicable discounts or adjustments; or (2) a maximum advisory fee rate (Maximum Rate), where the agreed upon Maximum Rate will be applied unless the applicable tier on the fee schedule gives the client a lower advisory fee rate. The fee schedules for the Program are set forth below and expressed as annual percentages. The Advisory Fee for the Program Accounts will be calculated based on the average daily balance, including cash, (based on market value) of assets held in the Account calculated on a daily basis for each business day. JPMS charges fees that it believes are reasonable, but these fees are not always the lowest available from other firms, including affiliated ones. Advisory Fees for partial billing periods upon the inception or termination of a Program account will be prorated. The Advisory Fee will be reflected on the Account statement issued by the custodian for the Account. Certain Model Managers are affiliated with JPMS. Model Manager Fees of affiliated Model Managers are waived or rebated to client Program Accounts that are IRAs or tax-qualified plans, including plans subject to ERISA. In this case, JPMS may share a portion of the Advisory Fee with the affiliated Model Manager. This revenue sharing arrangement will not affect the total Account Fees due by the client. Portfolio Manager Fees The Advisory Fee is an annualized asset-based fee that covers all advisory, administrative, custodial and brokerage services provided by JPMS. The Advisory Fee for Program Accounts is payable monthly in arrears. The Program offers SMAs with additional fees charged by Portfolio Managers (Portfolio Manager Fees). The Portfolio Manager Fee is an annualized asset-based fee that covers the portfolio management services provided by Portfolio Managers. These Portfolio Manager Fees are in addition to the Advisory Fees and vary depending on the Portfolio Manager and the Investment Strategy. The Portfolio Manager Fee is not included in the Advisory Fee. JPMS collects the Portfolio Manager Fees from clients and pays the Portfolio Managers. The Advisory Fee does not cover any (i) brokerage commissions or other charges resulting from transactions not effected through JPMS or its affiliates; (ii) “mark-ups,” “markdowns” and “dealer spreads” that we or other broker-dealers may receive when acting as principal in certain transactions; (iii) certain costs or charges imposed by third parties, including odd-lot differentials, margin interest, transfer taxes, exchange fees, and other fees or taxes required by law; (iv) any retirement Account fee; (v) the cost of investment manager fees and other expenses charged by Funds; or (vi) any pass-through or other fees associated with investment in American Depositary Receipts. Program Fee Schedule Portfolio Manager Fees range from approximately 0.10% to 1%. The specific Portfolio Manager Fee rate applicable to an Account will be stated in the Investment Proposal for the Account. The client’s actual Portfolio Manager Fees are reflected in the Account statement issued by the custodian for the Account. JPMS ADVISORY FEE (Linear) Advisory Account Assets 0–$249,999.99 Annual Fee 1.45% $250,000–$499,999.99 $500,000–$999,999.99 1.30% 1.15% Certain Portfolio Managers are affiliated with JPMS. Portfolio Manager Fees of affiliated Portfolio Managers are waived or rebated to client Program Accounts that are IRAs or tax-qualified plans, including plans subject to ERISA. In this case, JPMS may share a portion of the Advisory Fee with the affiliated Portfolio Manager. This revenue sharing arrangement will not affect the total Account Fees due by the client. No Minimum Fee $1,000,000–$1,999,999.99 $2,000,000–$4,999,999.99 1.00% 0.75% $5,000,000–$9,999,999.99 $10,000,000–$14,999,999.99 0.65% 0.55% 0.50% 0.40% $15,000,000–$24,999,999.99 $25,000,000–$49,999,999.99 ≥$50,000,000 0.30% Program Managed Account Fixed Income SMA Advisory Fee Schedule No minimum fee requirement is applied to Accounts. When applicable, Accounts will be charged the appropriate fee percentage for the asset value in the Account or, if applicable, for the value of assets in related Accounts that have been combined for Advisory Fee calculation purposes. If the Account has at any time qualified for a particular fee rate based on the market value of the Account, the same fee rate shall apply so long as the market value of the Account is no lower than 10% below the minimum asset size required for the applicable fee rate. If the market value of the Account falls below 10% of the minimum asset size required for the current fee rate, the Advisory Fee rate will be assessed using the applicable fee rate reflected in the fee schedule. JPMS FIXED INCOME ADVISORY FEE Advisory Account Assets Annual Fee Method of Payment 0–$249,999.99 $250,000–$499,999.99 0.60% 0.60% Subject to restrictions for retirement accounts and asset availability, clients can request, and JPMS may allow, that one of the related accounts (including a non-retirement Program Account or J.P. Morgan bank account) $500,000–$999,999.99 $1,000,000–$1,999,999.99 0.60% 0.60% 33821_COL 11-05-2025 Page 8 of 32  pay the entire Advisory Fee, Model Manager Fee, or Portfolio Manager Fee for the combined holdings. Manager; and (ii) fixed income trades will generally indicate “traded away” and show a price for the traded security that is inclusive (i.e., net) of the commission, mark-up or mark-down paid by the client to the other broker- dealer, but it does not break out or otherwise show the amount of the commission, mark-up or mark-down separately. Some fixed income trades, due to operational factors, will not indicate “traded away”; however, all fixed income trades are “traded away” whether or not they are indicated as such. For more information on trades away, refer to “Trading Practices Disclosures for Wrap Fee Programs” available at chase.com/managed- account-disclosures. ADR Fees in the Program Once an Advisory Fee, Model Manager Fee, or Portfolio Manager Fee is charged, unless the client has elected to pay the Advisory Fee, Model Manager Fee, or Portfolio Manager Fee from a related JPMS account, if there is sufficient cash in the Deposit Account, as defined below, or sweep fund to pay the entire amount, the Advisory Fee percentage for the Account value will be paid out of the Deposit Account or sweep fund within the Account. If the Deposit Account or sweep fund does not have sufficient funds to pay the Advisory Fee in its entirety, shares of the most overweight Fund(s) or security in a model or, if applicable, at the discretion of the Portfolio Manager or Implementation Manager, securities in the portfolio Account will be sold to pay the entire fee rather than paying any of the fee from the sweep fund. This could result in the client incurring a tax liability. If due to withdrawals, payment of fees, or otherwise, the value of the Deposit Account or sweep fund would fall to zero or below, sufficient shares in the Fund(s) or security in a model currently most overweight in the Investment Strategy based on actual dollar value or, if applicable, at the discretion of the Portfolio Manager or Implementation Manager, will be sold to clear the debit and replenish the Deposit Account or sweep fund to its current target amount. Reimbursement of WMS and JPMPI JPMS reimburses the expenses of WMS and JPMPI in return for their services. Special tax rules may apply to investments in foreign issuers, including American Depositary Receipts (ADRs). For example, one or more issuers in the Portfolio may qualify as a passive foreign investment company or a controlled foreign corporation for U.S. tax purposes, and non-U.S. withholding tax may be imposed on distributions or gains. Also, in certain cases, additional U.S. tax reporting may be required. Shares of foreign companies on foreign exchanges can be purchased and the shares converted to ADRs for client Accounts if the total cost of the purchase and conversion is more advantageous than directly purchasing the ADRs. To the extent that a subsidiary of J.P. Morgan assists in the conversion of foreign stock, J.P. Morgan affiliates will receive additional compensation from the transaction but in no event should the total cost of the purchase and conversion costs exceed the cost if they had originally purchased the ADR in U.S. markets. For qualified retirement Accounts where fees to affiliates are waived, JPMS may share a portion of the Advisory Fee with the affiliated manager for the Account. Trading Away and Associated Costs If the investment in the portfolio is made through an IRA, any foreign taxes incurred generally would not be creditable against your U.S. income tax liability. You are urged to consult your tax advisor regarding investment in non-U.S. entities, including whether you may be eligible for a credit against your U.S. income tax liability for any foreign taxes paid and whether you may be eligible for a lower rate or partial refund of non-U.S. withholding taxes pursuant to one or more applicable income tax treaties. For more information on foreign issuers, please refer to the Foreign Issuers Risk section. Certain Portfolio Managers place all or substantially all of certain types of trades with a broker-dealer other than JPMS for execution, depending on the types of securities traded in an Investment Strategy. It is not uncommon for investment managers to trade away in fixed income, foreign security, and small-cap equity strategies. Investment Strategies with such types of securities could be more costly to you than Investment Strategies in which Portfolio Managers more commonly place trades with JPMS for execution. Waivers, Reductions and Negotiation of Fees Portfolio Managers place orders in fixed income or debt securities with broker-dealers other than JPMS. For these fixed income trades, the client will incur a mark-up, mark-down or spread charged by the other broker- dealer that is not covered by the Advisory Fee. In its discretion, JPMS can negotiate, reduce or completely waive the Advisory Fee for any client or group of clients. Fees are discounted for employees of JPMS and its affiliates. It is possible that similarly situated clients will pay a different Advisory Fee. Reductions, rebates and waivers of the Advisory Fee, including discounts or adjustments, are not applicable to the Portfolio Manager or Model Manager Fee. Discounts may be subject to an expiration date. From time to time, the Advisory Fee can be increased. (i.e., JPMS may increase the Advisory Fee; the Portfolio Manager or Model Manager may increase their fee). JPMS will promptly notify the client whenever a fee increase is made to the client’s Program Account(s). JPMS charges fees that it believes are reasonable in relation to the scope of services and nature of the investment advice provided, but these fees are not always the lowest available from other firms and/or our affiliates. Fixed income securities are primarily traded in dealer markets. These securities are directly purchased from or sold to a financial services firm acting as a dealer (or principal). A dealer executing such trades may include a commission, a markup (on securities it sells), a markdown (on securities it buys) or a spread (the difference between the price it will buy, or “bid,” for the security and the price at which it will sell, or “ask,” for the security) in the net price at which transactions are executed. The bid and ask are prices quoted by the dealer, so the client should understand that a dealer’s bid price would be the price at which a client is selling their security, and the dealer’s ask price would be the price at which a client is buying the security. Advisory Fees for partial billing periods upon the inception or termination of a Program account will be prorated. The Advisory Fee will be reflected on the Account statement issued by the custodian for the Account. The Advisory Fee can be more or less than the cost of paying for investment advice, trade execution, custody and reporting services separately, depending on the cost of these services if provided separately and the level of trading activity in the client’s Account. Clients should review a Portfolio Manager’s Form ADV Part 2A Brochure, ask about a Portfolio Manager’s trading practices and consider that information carefully before selecting an investment manager and its investment strategy. In particular, clients should carefully consider any additional trading costs associated with a particular Portfolio Manager and investment strategy before selecting them for their Wrap Fee Program account. Because the Advisory Fee is charged on all assets in the Account, in a low interest rate environment, a client can earn less interest on assets held in the Account as cash or cash alternatives, such as money market funds, than the amount of the Advisory Fee the client is paying JPMS with respect to such assets, and therefore, the client’s net yield with respect to such assets can be negative. When Portfolio Managers place orders with broker-dealers other than JPMS, clients that elect to receive trade confirmations will receive a trade confirmation issued by JPMS that will provide details of the trade as follows: (i) for equity trades, the trade confirmation and Account statement will generally indicate “traded away” and will list the commission you incurred as an additional cost in connection with trading away by a Portfolio 33821_COL 11-05-2025 Page 9 of 32  Relationship Pricing confirmation issued by JPMS with the details of the trade shows a price for the traded security that is inclusive (i.e., net) of the commission, mark-up or mark-down paid by the client to the other broker-dealer, but it does not break out or otherwise show the amount of the commission, mark-up or mark-down separately. For more information on trades away from the Firm, refer to the Trading Practices Disclosures for Wrap Fee Programs available at chase.com/managed-account-disclosures. Share Classes Available in Program Investment Strategies JPMS uses the value of assets in eligible Program Accounts that are in a Relationship Pricing Group, as approved by JPMS, to determine the Advisory Fee according to the applicable Advisory Fee schedule. JPMS decides which Program Accounts are eligible to be linked in a Relationship Pricing Group. Relationship pricing applies prospectively after Program Accounts are linked in a Relationship Pricing Group. ERISA, Irrevocable Trust and Entity Program Accounts are generally prohibited from being in a Relationship Pricing Group with the Program Accounts for another person, entity or relationship. ERISA Program Accounts cannot be in a Relationship Pricing Group with non-ERISA Program Accounts. Program Accounts can only be linked in a Relationship Pricing Group with other Program Accounts. Program Accounts cannot be linked in a Relationship Pricing Group with non-Program Accounts or accounts in a different program. Automatic Linking Subject to the exceptions discussed above, JPMS automatically links eligible Program Accounts with the same primary tax identification number for purposes of determining the asset size and Advisory Fee rate according to the applicable tiered Advisory Fee schedule. JPMS will not automatically link accounts in a Relationship Pricing Group in any other way. Client-Requested Linking Mutual funds typically offer different ways to buy shares with different share classes that may assess different fees and expenses. JPMS strives to make available the most appropriate share class on the platform for each Fund, with the goal of generally obtaining the lowest cost share class. However, for certain Funds, the share classes with the lowest fee structures are not available in the Program (e.g., (1) the Fund family restricts access to these share classes or (2) JPMS does not have an agreement with the Fund to distribute the share class in the Program). Clients should be aware that the share class of a Fund available through the Program may differ from the share class available to similar accounts managed by or held at JPMS or its affiliates and that certain lower cost Fund share classes may be available outside of the Program. Clients should contact their Advisor(s) for information about any limitations on share classes available through the Program. JPMS, through its brokerage accounts, has other arrangements with Fund companies that are described in the relevant brokerage documents. JPMS and its affiliates receive fees or other forms of compensation from the Funds (including money market funds) or their affiliates. JPMS believes that this conflict is addressed in the following ways: Subject to the exceptions discussed above and other than Program Accounts that are automatically linked by the same primary tax identification number, clients may request, subject to approval by JPMS, that certain family members’ Program Accounts be linked in a Relationship Pricing Group. For client-requested linking, JPMS will not link family members in a Relationship Pricing Group unless the clients proposed to be in the Relationship Pricing Group request linking. Other Fees and Expenses • 12b-1 distribution fees: JPMS receives fees from certain Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940 (Investment Company Act) (12b-1 Distribution Fees). Rule 12b-1 allows Funds to use Fund assets to pay the costs of marketing and distribution of the Fund’s shares. If JPMS receives 12b-1 Distribution Fees, it will rebate these fees to the client. Funds pay fees and expenses that are ultimately borne by clients (including, but not limited to, brokerage costs and management, administration and custody fees). The Advisory Fee does not include various additional fees that can be incurred within a client’s Account, including, but not limited to, Fund fees and expenses, transfer taxes, electronic fund and wire fees, individual retirement accounts (IRAs) and retirement plan Account fees, margin interest. ADR-related fees, or any other fees that would reasonably be assessed to a brokerage Account. If these fees are for services performed by JPMS or their affiliates, JPMS or an affiliate will receive all or a portion of the revenue from the fee. Additionally, Funds held in an Account have annual investment advisory expenses, so clients actually incur two levels of investment management fees: indirect Fund investment advisory fees to the investment adviser of each Fund and direct Program Advisory Fees to JPMS. These Fund fees and expenses are in addition to any fees paid to JPMS as the Program sponsor. (Refer to “Offset of Certain Fees to IRAs and Certain Other Retirement Accounts” below to understand the impact of Fund fees and expenses on retirement Accounts.) Clients can review the applicable prospectuses for Funds in the Program for additional information about these fees and expenses. JPMS and its affiliates collectively receive greater revenue if J.P. Morgan Funds are included in the Program, and therefore, JPMS and its affiliates have a conflict of interest in including J.P. Morgan Funds in the Program. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. responsible The Advisory Fee does not cover brokerage commissions or other charges resulting from transactions not effected through JPMS or its affiliates. In general, JPMS and WMS place orders in fixed-income or debt securities with broker-dealers other than JPMS. For these trades, the client will incur a brokerage commission, mark-up or mark-down charged by the other broker-dealer that is not covered by the Advisory Fee. JPMS or WMS also can choose to place orders in equities and other types of securities with broker-dealers other than JPMS, in which event the client will incur a brokerage commission that is not covered by the Advisory Fee. When JPMS or WMS place orders with broker-dealers other than JPMS, the trade • Other fees: JPMS enters into agreements with the Funds, their investment managers, distributors, principal underwriters, shareholder servicing agents and/or other affiliates of the Funds (Service Providers). The Funds or their Service Providers pay J.P. Morgan fees for providing certain administrative services, which include maintaining and updating separate records for each client, preparing and delivering client statements, tax reporting, proxy voting and solicitation, processing purchase and redemption orders, processing dividends, distributing prospectuses and other Fund reports, and responding to client inquiries. These fees for these services are typically called “shareholder servicing fees” when paid for by the Fund; however, these fees can be referred to as “revenue sharing” when they are paid by the Fund Service Provider from its own resources (together referred to as Servicing Fees). As of December 31, 2024, the Servicing Fees that JPMS received for non- money market funds were up to 25 basis points annually of the Fund assets, or a rate of up to $20 per year per Fund position; however, these amounts can change. The receipt by JPMS of these fees creates a conflict of interest in the selection of Funds for Accounts because the fees are different among Funds. Similarly, JPMS has a conflict to recommend mutual funds that pay Servicing Fees instead of ETFs or other securities or products that do not pay any Servicing Fee. The portfolio managers or Advisors who are for recommending investments for Accounts do not receive any direct financial benefit from the Servicing Fees. To that extent, such portfolio managers or Advisors are incentivized to invest in or recommend securities they believe will increase the value of the Account. JPMS does not retain any portion of those fees for retirement Accounts. When evaluating the fees for, and cost of, a Program, clients should consider the Servicing Fees that JPMS receives in addition to the investment advisory fees. Clients can also request a Fund prospectus for additional information regarding Fund fees. 33821_COL 11-05-2025 Page 10 of 32  distributing money market mutual funds available to Program clients. Additionally, JPMCB has agreed to pay JPMS a monthly flat fee for each Account that uses the Deposit Account; however, JPMS is currently waiving receipt of this fee. Therefore, JPMS and JPMCB have a conflict of interest in offering or utilizing the Deposit Account and in making it the default “sweep” option. JPMS believes that the conflict is addressed through: • The fact that Advisors do not receive any additional compensation for assets held in the Deposit Account as opposed to another cash alternative; • Online disclosure of the available cash options and yields at Once a particular share class is made available for a particular Fund in the Program, only that share class can be purchased for that Fund. Mutual funds will be purchased in the Account at net asset value (no-load or load- waived) and ETFs at their market price. JPMS periodically reviews the share classes offered by Funds in the Program but also relies on the Fund families to inform JPMS when and if these share classes will be made available. If JPMS identifies and makes available a class of shares for a Fund more appropriate than the class of shares previously made available for the Fund, to the extent allowed, JPMS will convert client shares of the Fund to that more appropriate share class of the same Fund. Operational and other considerations can affect the timing of the conversion of shares and can cause the timing or implementation of such conversions to differ between clients. chase.com/SweepYields; • The client’s ability to affirmatively select another available “sweep” option and to change the “sweep” option selection to an available alternative at any time; Some of the Fund share classes available through the Program are not necessarily available to clients outside of the Program. To the extent an Account is terminated, clients may not be eligible to continue to hold or purchase certain share classes outside of the Program and/or outside the firm. • The JPMorgan Chase Deposit Account Disclosure provided to the client; and Cash Allocations and the Sweep Feature • The client’s ability to obtain the prospectus for each money market mutual fund that is an available alternative to the Deposit Account. Offset of Certain Fees to IRAs and Certain Other Retirement Accounts Clients in the Program authorize JPMS, to the extent permitted by applicable law, to invest (i.e., “sweep”) available cash balances in the JPMorgan Chase Deposit Account (the Deposit Account) or one or more money market mutual funds that are managed by affiliates of JPMS and a third party. The Deposit Account is the default “sweep” option for Program clients who do not select an available “sweep” alternative or if the sweep selected is no longer available. If an Account owned by an IRA, or other client that is a qualified retirement account subject to the prohibited transaction provisions of Section 4975 of the Internal Revenue Code of 1986, as amended, and the corresponding Treasury regulations (the Code) holds any J.P. Morgan Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with Account assets will be offset against the Advisory Fee. The offset amount will be automatically applied against the Advisory Fee charged for the period and will appear as a separate line item on the client’s Account statement. This offset does not apply to Account investments in non–J.P. Morgan Funds. In addition, for those J.P. Morgan Funds that utilize unaffiliated investment sub-advisers for all or a portion of the Fund portfolio management, the amount of the Fund advisory fees paid to unaffiliated investment sub-advisers is not offset to the Advisory Fee. IAR Compensation Cash “swept” or allocated to the Deposit Account is remitted for deposit by JPMS, acting as the client’s agent, into a demand deposit account maintained at JPMCB. Balances in the Deposit Account are covered by Federal Deposit Insurance Corporation (FDIC) insurance, subject to applicable limits, terms and conditions, but are not protected by the Securities Investor Protection Corporation. JPMS does not review or monitor FDIC insurance limits for clients. Clients are responsible for monitoring the total amount of deposits that they have with JPMCB to determine the extent of FDIC deposit insurance coverage available to them on their deposits. The JPMorgan Chase Deposit Account Disclosure provides further information about the Deposit Account, including the limits, terms and conditions of FDIC insurance coverage. The Program is recommended to clients by IARs associated with JPMS. For those IARs that receive a portion of the Advisory Fee: (i) the exact portion of the fee paid to the IAR varies among IARs and can also depend upon each IAR’s overall revenue production; and (ii) no compensation is paid to the IAR for Accounts where the total client assets invested through the Firm (including brokerage, managed and annuities) is less than $100,000 (generally, such Accounts will be assigned to a team of IARs who are salaried employees). The type of compensation paid to IARs will not result in a change to a client’s Advisory Fee. The interest rate on the Deposit Account will vary based on business and economic conditions and is reset periodically at JPMCB’s sole discretion. The interest rate on the Deposit Account may be higher or lower than yields on other available cash alternatives (e.g., money market mutual funds). From time to time, JPMS may decide that it is in the best interest of clients to maintain a certain percentage of assets in cash or cash alternatives, especially when markets are volatile. However, because the Advisory Fee is charged on the value of all assets in the Account (including cash and cash alternatives), in a low interest rate environment, the net investment return on cash and cash alternatives, including the Deposit Account, will be negative. The current rates and yields for available cash options for including the Deposit Account, can be found online at Accounts, chase.com/SweepYields. These rates and yields change regularly, so it is prudent to check this website on at least a quarterly basis. JPMS or IARs may discount the Advisory Fee and/or provide a Maximum Rate. These IARs (other than those who are only compensated by salary and discretionary bonus) have a financial incentive to (1) price client Accounts at the stated fee schedule rather than providing a discount and/or a Maximum Rate and (2) limit discounts to the Advisory Fee and/or a Maximum Rate to be no more than a certain percentage below the stated fee schedule. The IAR will earn reduced compensation when IARs (1) discount the Advisory Fee more than a certain percentage below the stated advisory fee schedule and/or (2) provide a Maximum Rate that is more than a certain percentage below the applicable tier of the stated advisory fee schedule for the given billing period. Clients can and should ask their advisor for details on discounting practices and how those practices affect compensation. Discounts to the Advisory Fee and/or Maximum Rates that are more than a certain percentage below the stated fee schedule made after 01/01/25 will affect IAR compensation beginning 01/01/26. Clients may find their agreed upon discount percentage and/or Maximum Rate percentage in documents such as proposals, certain letters and/or statements. We address these conflicts of interest by maintaining policies and procedures requiring that Advisors act in your best interest, reasonably Although there is no charge to clients with respect to the Deposit Account, JPMCB benefits from the Deposit Account because, through the Deposit Account, JPMCB receives a stable, cost-effective source of funding. JPMCB uses client deposits in the Deposit Account to fund current and new businesses, including lending activities and investments. The profitability on such lending activities and investments is generally measured by the difference, or “spread,” between the interest rate paid on the deposits and other costs associated with the Deposit Account paid by JPMCB and the interest rate and other income earned by JPMCB on the loans and investments made with the deposits. The income that JPMCB earns through its lending and investing activities is usually significantly greater than the interest earned by clients through the Deposit Account. It is typically also greater than the fee earned by all J.P. Morgan entities from managing and 33821_COL 11-05-2025 Page 11 of 32  supervising their activities and disclosing these conflicts so that you can make informed decisions. Except for Guided Accounts, the Program is not intended for investors who seek to maintain control over trading in their Account, who have a short- term time horizon (or expect ongoing and significant withdrawals), or who expect or desire to maintain consistently high levels of cash or money market funds. A. Program Minimum Because Model Manager and Portfolio Manager Fees vary, and in some cases may be waived, this creates (i) an opportunity for the IAR to avoid discounting (or to limit the discount on) the JPMS Advisory Fee when recommending a Model Manager or Portfolio Manager that charges a lower or no additional fee; and thus (ii) a financial incentive to recommend Model Managers or Portfolio Managers with lower or waived fees. JPMS also benefits more if an Advisory Fee is not subject to a discount. JPMS does not give the discretion to discount to IARs who are salaried employees. JPMS has established account minimum requirements for client accounts, which vary based on the investment strategy. Minimums are subject to waiver or reduction in JPMS’ discretion and are waived for certain client accounts on occasion. If Program or Account assets fall below the initial minimums, JPMS can terminate Program participation and close Accounts at its discretion. To open or maintain an account, clients are required to enter into a Client Agreement with JPMS that stipulates the terms under which JPMS (and other investment advisers to which it delegates investment discretion) are authorized to act on behalf of the client to manage the assets listed in the Client Agreement. Because the JPMS fixed income Advisory Fee Schedule is priced lower than the JPMS Advisory Fee Schedule, IARs are paid less for client assets invested in fixed income Portfolio Managers that are subject to the lower priced JPMS fixed income Advisory Fee Schedule. This creates (i) an opportunity for the IAR to avoid the JPMS fixed income Fee Schedule when recommending a particular investment strategy or type of Account; and thus (ii) a financial incentive to recommend Investment Strategies that are not stand-alone fixed income Portfolio Managers and are subject to the higher priced JPMS Advisory Fee Schedule. The investment, sale or withdrawal of funds or securities from Accounts will be effected as soon as practicable subject to market conditions and other factors. Under normal market conditions, it can take 2-4 business days to process the investment (whether initial investments or additions), sale or withdrawal of funds in Accounts; however, timeframes can be longer due to market conditions and other factors. Managed Account. Participation in a Managed Account generally requires a minimum $10,000 investment. The minimum investment can be higher if the client selects a Portfolio Manager or Model Manager strategy, or a strategy with liquid alternatives or services that require a higher minimum. Accounts that fall below the minimum investment for the Investment Strategy as a result of client withdrawals will be subject to possible termination. JPMS IARs have a number of opportunities for selling products or services in their capacity as JPMS broker-dealer registered representatives or insurance agents. Depending on a number of factors (e.g., the size of the Program Account, changes in its value over time, the number of transactions, and the ability to negotiate fees and commissions), the amount of compensation received by certain IARs and the Firm from a Program Account can be more or less than JPMS and the IAR would receive if the client paid separately for investment advice, brokerage and other services. IARs, for themselves and the Firm, have a financial incentive to recommend the Program, especially when the Advisory Fee would be more than if the services were provided separately, or if the client had purchased a different advisory program sponsored by JPMS. Margin Debit Balances Guided Account. Participation in a Guided Account generally requires a minimum $50,000 investment. The minimum investment can be higher if the client selects a Portfolio Manager or Model Manager strategy. Guided Accounts investing in fixed income Portfolio Managers are subject to a minimum of $2,000,000. Tax Harvesting. Participation in WMS Tax Harvesting generally requires a minimum $50,000 investment for both Managed Accounts and Guided Accounts. A client can enroll in Tax Harvesting when the account is below the minimum, but Tax Harvesting will not start until the minimum is met, and parameters set. Tax Transition Services. Participation in WMS tax transition services generally requires a minimum $250,000 investment for both taxable Managed Accounts and taxable Guided Accounts. The US Endowments & Foundations investment strategy has a minimum investment of $1,000,000. B. Cash Balances in Program Accounts Margin debit balances held by a client cannot be held in an Account. This is significant because, for purposes of the calculation of the Advisory Fee, the net market value of the assets on which the fee is based will generally not be reduced by the amount of any margin debit balances held by the client in an account outside of the Program, even if some or all of the proceeds of the loan represented by the margin debit balances are held in the client’s Account, and even if some or all of the assets in the client’s Account are used to collateralize or secure the loan represented by the margin balances. JPMS has a financial incentive for the client to incur margin debt to buy securities in an Account because: (1) the client will be required to pay JPMS or its affiliates interest and fees on the debt; and (2) the net market value of the Account will be increased by the value of the additional securities purchased with the margin loan (and will not be offset by the amount of the margin debit held by the client in any account outside of the Program), resulting in a higher fee. In addition, any interest and fees paid by the client in connection with any debit balances held outside the Account will not be taken into account in the computation of the net equity or performance of the client’s Account as reflected in Account statements, performance reports or otherwise. ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS A portion of Program Accounts will be held in cash, cash equivalents or money market funds as part of the overall investment strategy for the Account and funds awaiting withdrawal by the client. Cash and cash equivalents, including money market funds, are subject to the Advisory Fee. For additional information, refer to “Cash Allocations and the Sweep Feature” in Item 4. Clients generally include individuals investing through taxable Accounts and retirement Accounts with a U.S. address. Clients whose Account address becomes a non-U.S. address will generally have their Account terminated from the Program. Cash raised for withdrawal will be charged both an Advisory Fee and an applicable Model Manager or Portfolio Manager Fee until the cash is removed from the Account. Cash that is not removed from an Account in a timely manner will be reinvested pursuant to the selected asset allocation or Investment Strategy. JPMS offers the Program to individuals, trusts, estates, charitable organizations, corporations and other business entities with U.S. addresses. Depending on the strategy, the Program is available to retirement accounts subject to Employee Retirement Income Security Act of 1974, as amended (ERISA) and the Code and the corresponding Treasury regulations (the Code). 33821_COL 11-05-2025 Page 12 of 32  ITEM 6 — PORTFOLIO MANAGER SELECTION AND EVALUATION Methods of Analysis, Investment Strategies and Risk of Loss periodically reviews the asset allocation and performance of the Investment Strategies with JPMS. In Guided, after the effective date of any changes to the target asset allocation or approved asset allocation ranges for a Model, JPMS notifies affected clients of the changes and whether clients need to rebalance to the updated asset allocation to continue the Program Account. Research Process JPMS and WMS use research provided by the manager solutions team of JPMPI or any of its affiliates to research, select and monitor the Funds, SMA/Models and investment strategies available for use in the Program. The manager solutions team of JPMPI or any of its affiliates is comprised of employees of JPMCB and other affiliates. Specialists on the manager solutions team of JPMPI or any of its affiliates are supervised persons of JPMPI. Set forth below is a general description of the primary methods of analysis that are utilized for the Program. This description is not intended to serve as a Fund, Model Manager, Portfolio Manager or Account guidelines. In connection with investments in a Fund or other securities through a Model Manager or Portfolio Manager, this description is qualified in its entirety by the information included in any applicable Fund’s prospectus or other relevant offering documentation and the Adviser’s, Portfolio Manager’s or Model Manager’s Form ADV Part 2A disclosure brochure. The Form ADV Part 2A disclosure brochure for each Model Manager or Portfolio Manager selected for a client’s Program Account is available at the SEC’s website at adviserinfo.sec.gov. JPMS and the manager solutions team of JPMPI or any of its affiliates are not responsible for the performance of any Fund, Portfolio Manager, or Model Manager (including any J.P. Morgan Fund or affiliated Portfolio Manager or Model Manager), or its compliance with its prospectus, disclosures, laws or regulations or for other matters within the Fund, Portfolio Manager or Model Manager’s control. Each Fund or Portfolio Manager’s adviser is solely responsible for the management of the Fund or the SMA. JPMS, and the manager solutions team of JPMPI or any of its affiliates cannot ensure that a given Model, Portfolio Manager or Investment Strategy’s investment objective will be attained. JPMPI Sub-Advisory Responsibilities in the Program In Managed, JPMPI, as a discretionary sub-adviser for Core Solutions, determines strategic and tactical asset allocations, is responsible for security selection (i.e., selects the Funds, Model Managers and Portfolio Managers for investment) and determines portfolio construction. JPMPI from time to time closes investment strategies to new investments. JPMS oversees the selections using an investment policy statement and remains responsible for overseeing JPMPI’s performance. The manager solutions team of JPMPI or any of its affiliates conducts due diligence of the Funds, Models and Investment Strategies that are available for use in the Program and is responsible for researching and selecting Funds and Model Managers as well as for subjecting them to a review process. The due diligence process is designed to subject both J.P. Morgan and non-J.P. Morgan Investment Strategies to the same process; however, the manager solutions team of JPMPI or any of its affiliates applies its discretion and is not required to apply all factors equally to each Fund in the search universe. J.P. Morgan maintains certain capacity limitations on investment positions in non-J.P. Morgan Funds due to liquidity concerns, regulatory requirements, and related internal policies. In circumstances where these limitations mean that WMS would not be able to invest all desired client assets in a particular non-J.P. Morgan Fund, the manager solutions team of JPMPI or any of its affiliates will likely recommend a J.P. Morgan Fund. The manager solutions team of JPMPI or any of its affiliates will begin the search process by defining an applicable universe of managed strategies, which typically will include J.P. Morgan managed strategies when there is one in the 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 then recommends particular Funds and Model Managers 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 and Model Managers as part of its ongoing review process. JPMPI, as a non-discretionary sub-adviser, provides In Guided, recommendations to JPMS regarding allocation guidelines and risk parameters for the asset allocation models (“Guided Account Models”). JPMPI does not manage Guided Account assets on a discretionary basis. Instead, each client directs the investment of their Guided Account assets across each selected asset class into one or more Funds, Model Managers or Portfolio Manager. Each asset class in a Guided Account Model has a specified allocation range and the client designates the specific asset allocation percentage desired for each asset class. JPMPI’s Discretionary Investment Process Refer to JPMPI ADV Part 2A for a detailed explanation of the research and due diligence process. Centralized Due Diligence JPMS establishes investment objectives, guidelines and policy, designates sub-adviser(s) when appropriate and is responsible for oversight of the sub-adviser(s). JPMPI determines strategic asset allocation and tactical asset allocation for the investment strategies. In addition, JPMPI selects the Funds, Model Managers and Portfolio Manager, as applicable, available through the Program using its research. JPMS (not JPMPI) is responsible for determining whether an investment strategy is suitable for a particular client. The investment policy statement specifies investment guidelines designed by JPMS to address operational considerations. These operational considerations, such as Fund concentration and capacity issues, can result in the timing or implementation of trades for a client’s account differing from that of another client or group of clients of JPMS or its affiliates. An internal governance committee provides ongoing oversight of Core Solutions to review compliance with certain guidelines. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” below for important information on the use of J.P. Morgan Funds. framework that establishes minimum criteria JPMPI Asset Allocation Process The manager solutions and operational due diligence teams of JPMPI or any of its affiliates utilize different types of research on Funds, Model Managers and Portfolio Managers. A due diligence review is performed on Funds, Model Managers and Portfolio Managers identified through both the Qualitative Research Process and Systematic Research Process. In the Qualitative Research Process, the manager solutions team of JPMPI or any of its affiliates conducts a qualitative analysis of Funds, Model Managers and Portfolio Managers on an ongoing basis. For the “Systematic Research Process,” Funds, Model Managers and Portfolio Managers are evaluated using an internally developed quantitative screening process on an ongoing basis. This evaluation reviews the portfolio manager’s organization, investment process, investment philosophy and performance using only quantitative criteria. The team reviews the Portfolio Manager’s and Model Manager’s organization, investment process, investment philosophy and performance. As part of the due diligence process, JPMPI also applies an for ESG eligibility determining the universe of ESG strategies offered to clients. Strategies that satisfy the 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. JPMPI is responsible for establishing and updating the overall strategic asset allocations for Investment Strategies, as well as tactical asset allocation. This process includes an internal committee. These asset allocations generally are the overall basis for the process described below. The JPMPI personnel who perform these functions are shared with JPMCB and perform substantially similar services for other clients. JPMPI 33821_COL 11-05-2025 Page 13 of 32    Funds, Model Managers and Portfolio Managers may be removed from (or no longer be eligible for purchase in) the applicable J.P. Morgan advisory programs if they do not continue to meet these criteria. JPMPI Initial Fund and Investment Strategy Review and Approval If a Fund, Portfolio Manager or Model Manager is terminated, the Sub- Adviser will determine whether to re-invest Program account assets in a replacement Fund, Portfolio Manager or Model Manager, and the Sub- Adviser will determine the specific Fund, Portfolio Manager or Model Manager in which to re-invest the assets, using the factors described above. Portfolio Managers and Model Managers Available in the Program The internal governance committee considers the formal presentation from the manager solutions and operational due diligence teams of JPMPI and its affiliates and approves or rejects new Funds, Model Managers and Portfolio Managers, as applicable, to be made available for JPMPI’s use in the Program. The internal governance committee review and approval process is generally the same for J.P. Morgan and non–J.P. Morgan managed investment strategies. See JPMPI ADV Part 2A for further information on the initial fund and investment strategy review and approval process. Portfolio Construction The Portfolio Managers and Model Managers available in the Program are both affiliated and non-affiliated. JPMS uses the same criteria to evaluate affiliated and non-affiliated Portfolio Managers and Model Managers, except in the case of its affiliate JPMPI (refer to “Affiliated Portfolio Managers and JPMS Conflicts” below). JPMS has a conflict of interest in including affiliated Portfolio Managers and Model Managers in the Program because JPMS and/or its affiliates will receive additional compensation when affiliated Portfolio Managers and Model Managers are selected by clients. For more information, refer to “Important Information About Your Investments and Potential Conflicts of Interest” below. JPMS is not responsible for the performance of any Portfolio Manager or Model Manager in the Program or any Portfolio Manager’s or Model Manager’s compliance with laws or regulations, or other matters within the Portfolio Manager’s or Model Manager’s control. Each Portfolio Manager is solely responsible for the management of its designated Accounts. JPMS coordinates services with the Portfolio Manager and Model Manager but is not responsible for coordinating services among multiple Portfolio Managers or Model Managers if the client has allocated assets among more than one Portfolio Manager or Model Manager. In Core Solutions, from the pool of strategies available in the Program, JPMPI selects the combination of Funds and/or Portfolio Managers or Model Managers that, in its view, fit each Model or Investment Strategy’s asset allocation goals and investment objectives. In making portfolio construction decisions, the Sub-Adviser will consider and is permitted to prefer J.P. Morgan Funds, including the Six Circles Funds, and affiliated Model Managers and Portfolio Managers. The Sub-Adviser is also more likely to select a J.P. Morgan Fund in circumstances where it would not be able to invest all desired client assets in a particular non-J.P. Morgan Fund due to capacity limitations as described under “Research Process” above. Refer to “Important Information About Your Investments and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. The Portfolio Managers and Model Managers in the Program manage the same or substantially similar strategies to those offered in the Program for clients of other affiliated and non-affiliated entities. The Advisory Fees charged for these strategies can be higher or lower than the Advisory Fee charged in the Program, and the strategies may not be handled identically to the Investment Strategies made available in the Program. Guided Account clients select one or more available Funds, Model Managers or Portfolio Managers in each asset class for their Accounts in the selected asset allocation model. Portfolio Implementation WMS provides portfolio implementation services for each individual client’s Account, except for Portfolio Manager trades other than JPMPI. JPMS as Program Sponsor has an internal governance forum that seeks to ensure that the Program offers suitable investment products to clients and that assets in the Program are managed in a compliant manner consistent with the goals of the Program and applicable law, and that fulfills JPMS’ fiduciary duties, as sponsor, to Program clients. Ongoing Review of Approved Funds and Investment Strategies Selection of Portfolio Managers, Model Managers and Investment Strategies in the Program JPMS reviews or arranges for the review of Portfolio Managers, Model Managers, and their Investment Strategies to determine whether they should be included in the Program. JPMS selects the Portfolio Manager, Model Manager and Investment Strategies based upon the research services, including recommendations, provided by JPMPI and such other information and resources that JPMS deems appropriate. The research services provided by JPMPI are described further below. An internal governance committee is responsible for the decisions to maintain Funds and Portfolio Manager or Model Managers, as applicable, as approved and available for the Program. This committee considers from the manager solutions and analysis and recommendations operational due diligence teams. From time to time, this internal governance committee may place them on probation or terminate them as part of its ongoing monitoring and oversight responsibilities. The internal is generally the same for governance committee review process J.P. Morgan and non–J.P. Morgan Investment Strategies, as further described under “Research Process” above. If a Fund or Portfolio Manager or Model Manager that is in the Program is placed on probation during the probation period, the manager solutions and operational due diligence teams will continue to review the Fund or Portfolio Manager or Model Manager. In addition, JPMPI may be limited from making additional purchases of a Fund due to capacity considerations. Termination and Replacement of Investment Strategies The decision to include a particular Portfolio Manager, Model Manager and Investment Strategy in the Program is based upon the totality of the results of the review process and does not necessarily reflect a rigid application of any or all of the processes or guidelines applied. JPMS can remove a particular Portfolio Manager, Model Manager and/or Investment Strategy from the Program at any time for any reason and will notify clients that have selected that Portfolio Manager, Model Manager and/or Investment Strategy of the removal. Generally, a Fund, Portfolio Manager or Model Manager that is terminated will be sold in a client Account, and the Sub-Adviser will not direct new purchases of that Fund, Portfolio Manager or Model Manager. A Portfolio Manager or Model Manager typically manages Investment Strategies that are made available through the Program. Each Portfolio Manager and Model Manager available through the Program has entered into a contract with JPMS to manage a model or client Accounts as set forth in the Investment Advisory Services Account Agreement provided to clients. JPMPI’s Investment Strategy Selection Process for the Multi-Manager Strategies in the Program If the Sub-Adviser removes a Fund, Portfolio Manager or Model Manager from the Program, the assets held in client Accounts will be sold and replaced with another Fund, Portfolio Manager or Model Manager that is approved for use in the Program without notice to clients. When evaluating a replacement Fund, Portfolio Manager or Model Manager, the Sub-Adviser is expected to consider the same factors described above. JPMPI, as Portfolio Manager for the Multi-Manager Strategies, is responsible for securities selection (including selecting Funds and/or Model 33821_COL 11-05-2025 Page 14 of 32  The manager research services JPMPI provides to JPMS for the Program Investment Strategies are not advisory services provided by JPMPI or tailored to clients of the Program. JPMS (not JPMPI) is solely responsible for selecting the Program and Investment Strategies to be made available in the Program, based upon the information and recommendations provided by the manager solutions team of JPMPI or any of its affiliates and such other information and resources that JPMS deems appropriate. Managers for investment) and determining portfolio construction. JPMPI, as Portfolio Manager for the Multi-Manager Strategies, constructs portfolios and identifies Funds and/or specific securities to implement investment views within the strategies’ guidelines consistent with its investment objectives. JPMPI’s process for selecting Funds and Model Managers for Portfolio Managers of the Multi-Manager Strategies is described below. Refer to “Use of J.P. Morgan Funds, and Investment Strategies and Potential Conflicts of Interest” below for important information on the use of J.P. Morgan Funds and affiliated Model Managers. In providing the manager research services, JPMPI expects to generally follow a similar process to the one described above under “Research Process,” “Ongoing Review of Approved Funds and Investment Strategies,” and “Portfolio Construction” in Item 6. JPMPI has the authority to place a Program Portfolio Manager or Model Manager on probation or to terminate it from the Program. When the manager solutions team of JPMPI or any of its affiliates’ monitoring process uncovers a significant enough concern, it will notify JPMS and will place the Portfolio Manager or Model Manager on probation or terminate it from the Program. JPMPI can terminate its manager research services on the Program Portfolio Managers or Model Managers at any time. Availability of Customized Services for Clients in JPMIM Fixed Income and Preferred Stock Investment Strategies JPMPI Review Process for Multi-Manager Investment Strategies The Multi-Manager Investment Strategies are subject to an initial and ongoing internal review process by JPMPI. This is different from the review process applied by JPMPI to other Investment Strategies in the Program and does not involve the manager solutions team of JPMPI or any of its affiliates or follow the same JPMPI governance procedure for placing an Investment Strategy on probation or terminating ongoing monitoring and oversight responsibilities for an Investment Strategy. However, JPMPI does have a process for taking action on the Multi-Manager Investment Strategies, if warranted, as a result of its ongoing internal review process. Termination, Removal, Discontinuance and Replacement of Portfolio Managers, Model Managers and Investment Strategies Taxable, Municipal and Preferred Investment Strategies are available and can be customized to individual client investment needs to various degrees depending on the Investment Strategy selected. In municipal bond portfolio strategies and taxable bond portfolio strategies, clients have the ability to select certain customizations (e.g., state preference, minimum credit quality options). The credit quality parameters that each client selects for a particular Account only apply at the time the Portfolio Manager initially purchases a particular bond for that Account. The Portfolio Manager may or may not liquidate bonds upon a credit rating downgrade. As a result, an Account can hold bonds with a credit rating below the client-selected parameter. In Preferred portfolio strategies, clients have the ability to select from an option for tax treatment. Collectively, all of the customizations are considered to be a “Customized Portfolio.” During the course of the portfolio management of a client Account, for certain strategies, a client can change their Customized Portfolio. For a municipal bond portfolio or taxable bond portfolio Account. Clients can decide whether (1) to immediately restructure the entire Account based on the new Customized Portfolio or (2) to adjust the Account as existing bond positions mature in accordance with the new Customized Portfolio. If the client does not elect for (1) or (2) as previously described, the Portfolio Manager will apply option (2) as a default. The client portfolio may hold positions that are not in line with the new Customized Portfolio if option (2) is applied. For preferred strategies, clients can only restructure an entire preferred portfolio Account. Immediately restructuring the entire Account to the new Customized Portfolio can result in taxable events upon the sale of positions. Clients should consult with their own tax professional to understand any such consequences. JPMPI Manager Research Services for Model Managers and Portfolio Managers Investment Strategies As a result of JPMPI’s research services and recommendations, and/or other information and events, Portfolio Managers, Model Managers and/or specific Investment Strategies may be terminated, replaced, removed or discontinued from the Program, in which event JPMS will notify affected clients and will either designate a Portfolio Manager, Model Manager or Investment Strategy in the Program as the default replacement for the Program Account assets invested in the removed Portfolio Manager, Model Manager or Investment Strategy, or recommend liquidation of clients’ securities in the Portfolio Manager, Model Manager or Investment Strategy. Discontinued Investment Strategies will be liquidated. If JPMS designates a default replacement or liquidation, each affected client will be notified in writing that, unless the client affirmatively selects, in writing, a replacement Investment Strategy in the Program by the date specified by JPMS (within 30 days of notification), the client’s assets will automatically be re-invested into the designated replacement Investment Strategy, without further notice to or consent of the client. In the case of a liquidation recommendation or liquidation of a discontinued Investment Strategy, the Program Account will be terminated from the Program and transferred to a JPMS limited purpose brokerage account. In designating a default replacement Investment Strategy (if any), JPMS will consider the appropriateness of the Investment Strategies available in the Program as suitable replacements for the removed Investment Strategy. JPMS also will assist the client in identifying a suitable replacement Portfolio Manager, Model Manager and/or Investment Strategy in cases where JPMS does not designate a default replacement Investment Strategy or in cases where JPMS does recommend liquidation, when an Investment Strategy is discontinued, or where the client wishes to consider alternatives to the default replacement Investment Strategy designated by JPMS. Such assistance is typically based on the same types of factors used by JPMS to identify Portfolio Managers, Model Managers, and Investment Strategies for Program clients in the first instance. The replacement Portfolio Manager can decline the Account if it deems the client’s investment restrictions unreasonable or if the client’s Account is below the replacement Portfolio Manager’s minimum account size. The replacement Portfolio Manager can sell securities to align the Account with its Investment Strategy, which can have tax consequences for clients. JPMS has engaged JPMPI to perform manager research services regarding investment strategies in the Program for potential inclusion in the Program. The manager research services that JPMPI performs for JPMS include: (1) recommending the Portfolio Manager or Model Manager to an internal governance committee, which is responsible for approving or rejecting them for use in the Programs, (2) providing initial and ongoing review of the Portfolio Manager, Model Manager and Investment Strategies, and (3) determining appropriate Portfolio Managers or Model Managers be placed on probation or terminated. The Investment Strategies are managed by an affiliated Portfolio Manager, JPMIM, JPMPI, and unaffiliated Portfolio Managers and Model Managers. JPMPI uses its manager solutions and operational due diligence teams to provide the manager research services. In providing the manager research services for the Program, JPMPI expects to generally follow a similar process to the one described under “Research Process”, “Ongoing Review of Approved Funds and Investment Strategies,” and “JPMPI Review Process for Multi-Manager Investment Strategies,” above. Refer to “JPMPI’s Investment Strategy Selection Process for the Multi-Manager Strategies in the Program” above for manager research services for multi-manager strategies available in the Program. The manager solutions team of JPMPI or any of its affiliates’ review of Program Portfolio Managers and Model Managers and their Investment Strategies, as well as other information and events, also may result in the 33821_COL 11-05-2025 Page 15 of 32  selected asset class and investment style and will assist client in selecting a Portfolio Manager or Model Manager. JPMS identifies suitable Investment Strategies for a client based on the investment objectives and other information provided by the client in the investment proposal. Clients are solely responsible for the selection of Portfolio Managers and Model Managers and Investment Strategies from among those identified by JPMS. JPMS and JPMPI cannot ensure that a given Investment Strategy’s investment objective will be attained. Potential Conflicts of Interest in the Research provided for the Program Investment Strategies Portfolio Manager, Model Manager and/or one or more of its Investment Strategies in the Program being closed to new investors pending further review. During such status, clients cannot select the Portfolio Manager, Model Manager and/or Investment Strategy for the first time, but clients with Program assets already being managed according to an affected Investment Strategy when it was closed to new investors are permitted to contribute additional assets to such client’s Account(s). Clients invested according to an affected Investment Strategy will be notified in writing that the Portfolio Manager, Model Manager and/or Investment Strategy have been closed to new investors. Further review of the affected Portfolio Manager, Model Manager and/or Investment Strategies by the manager solutions team of JPMPI or any of its affiliates can result in a re-opening to new investors. Removal and Replacement of Funds, Models or Portfolio Managers in Guided JPMS determines the number of Funds, Model Managers and Portfolio Manager in an asset class and the overall design of Guided Models. JPMPI recommends Investment Strategies managed by JPMPI, JPMIM or unaffiliated third parties for approval in the Program. JPMPI has an incentive to recommend, and JPMS has an incentive to include, JPMPI and JPMIM-managed Investment Strategies because J.P. Morgan receives more overall fees when these strategies are chosen by clients. Similarly, with respect to manager termination, JPMPI has a greater incentive to recommend the termination of unaffiliated third-party managers from the Program and a greater incentive to terminate unaffiliated Portfolio Managers, particularly where the manager’s strategy is similar to one offered by JPMPI or JPMIM. For additional potential conflicts of interest, refer to Item 9.C., below. Information About Portfolio Managers, Model Managers and Investment Strategies JPMS provides clients and prospective clients with information about Portfolio Managers and Model Managers that is provided by third parties and is based on and/or incorporates information provided by Portfolio Managers and Model Mangers, and other third-party sources. JPMS believes that this information is accurate; however, JPMS does not independently verify or guarantee the accuracy or completeness of the information. JPMS shall have no liability with respect to information provided by Portfolio Managers or Model Managers. Performance information included in the information provided by JPMS is provided by Portfolio Managers. This performance is calculated by the Portfolio Managers themselves or by third parties, and neither JPMS nor a third party engaged by it reviews Portfolio Manager performance information for JPMS to determine or verify its accuracy or its compliance with presentation standards. Portfolio Manager performance information is not calculated on a uniform and consistent basis. If a Fund, Model Manager or Portfolio Manager has been terminated from the Program, all new and additional purchases and rebalances allocated to the terminated Fund, Model Manager or Portfolio Manager will be allocated to cash. The Fund, Model Manager or Portfolio Manager held in Program Accounts will be sold and replaced with another Fund, Model Manager or Portfolio Manager in the same asset class or the proceeds will be allocated to cash. When evaluating a replacement Fund, Model Manager or Portfolio Manager, the Sub-Adviser is expected to consider the same factors described above and will notify JPMS of the replacement Fund, Model Manager or Portfolio Manager. JPMS will notify affected clients in writing of the Fund, Model Manager or Portfolio Manager termination and the recommended replacement Fund, Model Manager or Portfolio Manager for the Program Account assets invested in the terminated Fund, Model Manager or Portfolio Manager. If clients do not select an alternative replacement Fund, Model Manager or Portfolio Manager within the requested timeframe, the client’s assets will automatically be re-invested into the designated replacement Fund, Model Manager or Portfolio Manager. A client who does not approve of the replacement Fund, Model Manager or Portfolio Manager must select an alternative Fund, Model Manager or Portfolio Manager. Removal and replacement of Funds, Model Managers or Portfolio Managers can cause income tax consequences and/or penalties. At times, the alternative Fund, Model Manager or Portfolio Manager will be a J.P. Morgan Fund, Model Manager or Portfolio Manager. Program clients typically receive a quarterly performance review prepared by JPMS summarizing the investment performance of the client’s Account(s) for the prior quarter. In preparing such reviews for Program clients, JPMS uses various industry standards to measure Account performance. Clients receiving periodic written performance reviews from JPMS should review carefully the disclosures, definitions and other information contained in the reviews. Portfolio Manager Disclosure Documents and Performance The manager solutions team of JPMPI or any of its affiliates will determine, when appropriate, that a Fund, Model Manager or Portfolio Manager be put on probation. A Fund, Model Manager or Portfolio Manager on probation will not be available to new clients. Existing clients can continue to hold shares and purchase additional shares of a Fund, Model Manager or Portfolio Manager on probation, or they can choose a different Fund, Model Manager or Portfolio Manager in that asset class. If a Fund, Model Manager or Portfolio Manager on probation is reactivated, clients will be notified. If a Fund, Model Manager or Portfolio Manager on probation is terminated, it will be replaced as described above. Recommendations of Portfolio Managers and Model Managers in the Program for Particular Clients Clients will receive one or more Portfolio Manager Disclosure Documents. Clients should review the Portfolio Manager Disclosure Document carefully for important information about the Portfolio Manager, including risks associated with the selected Investment Strategy (if applicable). Each Portfolio Manager is solely responsible for the truthfulness, completeness and accuracy of its own disclosure document. JPMS is not responsible for the performance of any Portfolio Manager or any Portfolio Manager's compliance with applicable laws and regulations or other matters within the Portfolio Manager's control. Each Portfolio Manager is solely responsible for the management of that Portfolio Manager's designated Account(s). If a client selects more than one Portfolio Manager, the Portfolio Managers may engage in contrary transactions with respect to the same security. JPMS will effect transactions for an Account only if and to the extent instructed by a Portfolio Manager. JPMS shall not be responsible for any act or omission of any Portfolio Manager or any misstatement or omission contained in any document prepared by or with In connection with opening a Program Account, clients complete a client Profile that requests information about the client’s financial situation, investment experience, investment objectives, time horizon and risk tolerance. Based upon this information, the client, with the consultation of the IAR, will specify in what asset class the Account will be invested. An example of an asset class is Fixed Income. An example of an asset class subgroup is the LMS strategy which is a subgroup of fixed income that seeks to address specific fixed income investment objectives. Examples of investment style are U.S. Large Cap Growth, U.S. Small Cap Value, Municipal Fixed Income and Taxable Fixed Income. Based upon the client’s asset class selection, the IAR will provide the client with information about the Portfolio Managers and Model Managers available in the Program in the 33821_COL 11-05-2025 Page 16 of 32  the approval of any Portfolio Manager or any loss, liability, claim, damage or expense whatsoever, as incurred, arising out of or attributable to such misstatement or omission. Portfolio Managers are responsible for obtaining best execution. To learn more about Portfolio Manager trading and execution practices, refer to each Portfolio Manager's Portfolio Manager Disclosure Document. Affiliated Portfolio Managers and Model Managers and JPMS Conflicts of Interest example (to the extent the following activities are permitted in a client’s Account): (1) when J.P. Morgan invests in an investment product, such as a mutual fund, structured product, SMA, or hedge fund issued or managed by a J.P. Morgan affiliate, such as JPMIM or JPMPI; (2) when a J.P. Morgan entity obtains services, including trade execution and trade clearing, from a J.P. Morgan affiliate; (3) when J.P. Morgan receives payment as a result of purchasing an investment product for a client’s Account; or (4) when J.P. Morgan receives payment for providing services (including shareholder servicing, recordkeeping or custody) with respect to investment products purchased for a client’s Account. Other conflicts will result because of relationships that J.P. Morgan has with other clients or when J.P. Morgan acts for its own account. JPMIM and JPMPI are affiliates of JPMS that act as Portfolio Managers in the Program. JPMIM is the Portfolio Manager and Model Manager for certain Program Investment Strategies and JPMPI is the sole Portfolio Manager for Multi-Manager Investment Strategies. Investment strategies are selected from both J.P. Morgan and third-party asset managers and are subject to a review process by the manager solutions team of JPMPI or any of its affiliates. From this pool of strategies, J.P. Morgan portfolio construction teams select those strategies J.P. Morgan believes fit its asset allocation goals and forward-looking views in order to meet the investment objective of the Investment Strategy or Portfolio. As a general matter, J.P. Morgan prefers J.P. Morgan managed strategies. J.P. Morgan expects the proportion of J.P. Morgan managed strategies will be high (in fact, up to 100 percent) in strategies, such as, for example, cash and high-quality fixed income, subject to applicable law and any Account- specific considerations. J.P. Morgan may allocate a significant portion of the assets in the Program to J.P. Morgan Funds. That portion varies depending on market or other conditions. JPMIM and its Investment Strategies in the Program are subject to the same selection and review processes, conducted by the manager solutions team of JPMPI or any of its affiliates, as unaffiliated Portfolio Managers and Investment Strategies available in other Programs, though the manager solutions team of JPMPI or any of its affiliates applies its discretion and is not required to apply all factors equally to each Fund in the search universe. JPMPI’s strategies are subject to the separate though similar review process incorporating similar quantitative and qualitative assessments but implemented by different governance processes and committee. However, the JPMPI strategy review process does not include a search process to identify a universe and core peer set of strategies from which to select. For disclosures on the distinct review process over JPMPI and its Multi-Manager Investment Strategies and potential conflicts related to research and review processes conducted by JPMPI, refer to “Potential Conflicts of Interest in the Research provided for the Program Investment Strategies” and “JPMPI Review Process for Multi-Manager Investment Strategies” above. While J.P. Morgan’s internally managed investment strategies generally align well with J.P. Morgan’s forward-looking views, and J.P. Morgan is familiar with the investment processes as well as the risk and compliance philosophy of the J.P. Morgan, it is important to note that J.P. Morgan receives more overall fees when internally managed investment strategies are included. In the Program J.P. Morgan offers the option of choosing to exclude J.P. Morgan managed strategies (other than cash and liquidity products) in certain portfolios. The Six Circles Funds are mutual funds advised by JPMPI and sub-advised by third-parties. Although considered internally managed strategies, neither JPMPI nor its affiliates retain a fee for fund management or other fund services. JPMS has a conflict of interest in: (1) including JPMIM and JPMPI in the Program; (2) conducting, or having an affiliate research services provider (i.e., JPMPI) conduct, initial and periodic reviews of affiliated Portfolio Managers and their Investment Strategies in the Program; (3) identifying JPMIM, JPMPI and their Investment Strategies in the Program to clients; and (4) designating JPMPI and JPMIM Investment Strategies as default replacement Investment Strategies for Program Accounts invested in Investment Strategies that are removed from the Program when a client selects (or is re-invested into) one of their Investment Strategies. Separately Managed Accounts JPMS and its affiliates receive more total revenue than if the client were able to select an Investment Strategy of an unaffiliated Portfolio Manager. JPMS manages this conflict through disclosure to clients and by subjecting affiliated Portfolio Managers and Model Managers to a comprehensive review process. Investment Strategies invested in individual equity or fixed income securities may be managed by JPMS affiliates or by a third-party manager. When an affiliate manages these investments, there is a benefit to J.P. Morgan since it increases the overall revenue of J.P. Morgan. Additionally, a manager of an SMA may invest in products that may result in additional revenue to J.P. Morgan. Important Information About Your Investments and Potential Conflicts of Interest When J.P. Morgan selects J.P. Morgan Funds for client Accounts, J.P. Morgan receives a fee for managing the J.P. Morgan Funds. As such, J.P. Morgan will receive more total revenue when cash in a client’s Account is invested in J.P. Morgan Funds than if it was invested in third-party funds. JPMS and JPMPI address this conflict through disclosure to clients and through the investment process described in Item 6 herein. For important information about each J.P. Morgan Fund, including investment objectives, risks, charges and expenses, clients can read each Fund’s prospectus carefully and consider all the information in it before investing. The Portfolio Managers and Model Managers available in the Program include Portfolio Managers and Model Managers affiliated with JPMS. JPMS has a conflict of interest including affiliated Portfolio Managers and Model Managers in the Program because JPMS and/or its affiliates and parent company will receive more overall compensation when those Portfolio Managers and Model Managers are selected by clients. JPMS manages this conflict through disclosure to clients and by subjecting affiliated Portfolio Managers and Model Managers to a comprehensive review process. For more information on the review of affiliated Portfolio Managers, refer to “Affiliated Portfolio Managers and Model Managers and JPMS Conflicts” above. IMPORTANT INFORMATION ABOUT MUTUAL FUNDS AND EXCHANGE- TRADED FUNDS REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, AS AMENDED Use of J.P. Morgan Funds and Investment Strategies and Potential Conflicts of Interest J.P. Morgan Funds—Management Fees Investment Principles and Potential Conflicts of Interest Conflicts of interest will arise whenever J.P. Morgan has an actual or perceived economic or other incentive in its management of our clients’ accounts to act in a way that benefits J.P. Morgan. Conflicts will result, for J.P. Morgan and its affiliates are the sponsor or manager of Funds, including ETFs, that can be purchased for accounts. In such case, J.P. Morgan or its affiliates will receive a fee for managing such Funds or for providing other services to such Funds based on the value of the assets invested in the Funds. As such, J.P. Morgan and its affiliates will receive 33821_COL 11-05-2025 Page 17 of 32  Allocation of J.P. Morgan Funds in the Multi-Manager Investment Advisory Strategies more total revenue when the client’s portfolio is invested in such Funds than when it is invested in third-party Funds. When a retirement account can be invested in J.P. Morgan Funds, the retirement account will be credited an amount equal to the account’s pro rata share of all such fees paid to J.P. Morgan or its affiliates in connection with the account’s investments in J.P. Morgan Funds. J.P. Morgan Funds and Third-Party Funds—Other Fees and Expenses JPMPI can allocate a significant portion of the assets in a JPMPI Multi- Manager Strategy to J.P. Morgan Funds. That portion varies depending on market or other conditions. There are multiple Investment Strategies available in JPMPI Multi-Manager Strategies. Certain Investment Strategies invest only in mutual funds and ETFs, while other Investment Strategies also utilize Model Managers. The following chart illustrates, as of the date indicated, the allocation of J.P. Morgan Funds (excluding Six Circles Funds), non–J.P. Morgan Funds, Six Circles Funds and J.P. Morgan cash for JPMPI Multi- Manager Strategies. The chart does not reflect strategies that utilize Model Managers. For the Dynamic Multi-Asset Strategy, the chart does not reflect models that elect not to use J.P. Morgan Funds. The chart assumes the sweep vehicle is J.P. Morgan Cash. October 06, 2025—Multi-Manager Investment Advisory Strategies Multi-Manager Investment Strategy J.P. Morgan Funds Non-J.P. Morgan Funds Six Circles Funds J.P. Morgan Cash 10.00% 88.00% 0.00% 2.00% Dynamic Multi-Asset Strategy All Funds have various internal fees and other expenses that are paid by managers or issuers of the Funds or by the Funds themselves, but that ultimately are borne by the investor. These fees and expenses are in addition to any fees paid to JPMS. J.P. Morgan may receive administrative and servicing fees for providing services to both J.P. Morgan Funds and third-party Funds that are held in a client’s Account. Refer to the discussion of “Share Classes Available in Program Investment Strategies” in Item 4 above for more information on the receipt of administrative and servicing fees. Clients should review the applicable prospectuses for Funds for more information about these fees and expenses. These payments may be made by sponsors of the Funds (including affiliates of J.P. Morgan), or by the Funds themselves, and may be based on the value of the Funds in the client’s Account. Funds or their sponsors may have other business relationships with J.P. Morgan outside of its portfolio management role or with its broker-dealer affiliates of J.P. Morgan, which may provide brokerage or other services that pay commissions, fees and other compensation. 0.00% 98.00% 0.00% 2.00% Six Circles Funds Dynamic Multi-Asset Strategy – Non-Prop 28.00% 71.00% 0.00% 1.00% Dynamic Yield Strategy J.P. Morgan developed the J.P. Morgan Six Circles Funds (Six Circles Funds) exclusively for use in J.P. Morgan investment advisory accounts. 0.00% 99.00% 0.00% 1.00% Emerging Markets Growth and Income Strategy 29.00% 70.00% 0.00% 1.00% Liquidity Management Strategy 29.00% 70.00% 0.00% 1.00% Liquidity Management Strategy – Retirement 9.00% 90.00% 0.00% 1.00% Sustainable Equity Strategy 0.00% 99.00% 0.00% 1.00% Sustainable Fixed Income Strategy Six Circles Funds are specifically designed for use in discretionary Program accounts as completion funds to align with J.P. Morgan’s core portfolio views and are used in Core Solutions Investment Strategies. JPMPI acts as investment adviser to the Six Circles Funds and engages third-party investment managers as sub-advisers to the Six Circles Funds’ investment portfolios. J.P. Morgan will have certain benefits and efficiencies from investing account assets in the Six Circles Funds instead of unaffiliated Funds; however, J.P. Morgan does not retain investment advisory fees for managing the Six Circles Funds through an agreement to waive any investment advisory fees that exceed the fees owed to Six Circles Funds’ third-party sub-advisers. Six Circles Funds do not pay fees to J.P. Morgan for any other services to the Six Circles Funds. Services to the Six Circles Funds are provided by third-party service providers and are generally paid by the Six Circles Funds or J.P. Morgan. (The market value of assets invested in the Six Circles Funds will be included in calculating the advisory fees paid on the overall portfolio.) Allocations shown here are illustrative only, do not necessarily represent actual use of J.P. Morgan Funds and non-J.P. Morgan Funds represented in any particular client’s Account, and can change without notice. JPMPI has full discretionary authority to select Funds and is not required to adhere to the illustrative allocations pictured here. Refer to Item 9, Section C for more information on Potential Conflicts of Interest. Affiliated Portfolio Managers and Model Managers in the Program With respect to Portfolio Managers and Model Managers, when an affiliate serves as Model Manager, there is a benefit to J.P. Morgan since it increases the overall revenue of J.P. Morgan. Additionally, both affiliated and unaffiliated Model Managers can invest in products that can result in additional revenue to J.P. Morgan. Sub-Adviser Allocation of Assets in Core Solutions Six Circles Fund shares may only be purchased in Program accounts for which JPMC has investment discretion. Should the client choose to close its discretionary Program account but retain the interest in Six Circles Funds, Six Circles Fund shares must be held through an eligible brokerage account and no new purchases into the Six Circles Funds will be permitted (other than dividend reinvestment). Since the Six Circles Funds are completion portfolios designed to complement and work as part of the overall discretionary portfolio and are not intended to be standalone investments, each Six Circles Fund may underperform as a standalone investment, even in instances where the overall portfolio performs as intended. Further, the overall performance and liquidity of a Six Circles Fund may be negatively affected, and additional transaction costs may be incurred by the Six Circles Fund, as a result of (i) allocation decisions made by JPMC to shift discretionary client assets among the Six Circles Funds and other investments; and (ii) allocation decisions made by JPMC to shift Six Circles Fund assets among different investment strategies and sub-advisors, which may negatively affect the value of Six Circles Fund shares even if they are no longer held through a JPMC portfolio. risks, charges, and expenses, go For more information about the Six Circles Funds, including the funds’ to objectives, sixcirclesfunds.com/literature. JPMPI can allocate a portion of the assets in the Program to J.P. Morgan Funds. That portion varies depending on market or other conditions. There are multiple Models in each of the Investment Strategies available in the Program. Certain Models invest only in mutual funds and ETFs, while other Models can also invest in Liquid Alternative Funds and individual securities through Model Managers and Portfolio Managers. The prior composition of Investment Strategies in the Program is not intended to predict the future 33821_COL 11-05-2025 Page 18 of 32  Refer to Item 9, Section C for more information on Potential Conflicts of Interest. Credits for Retirement Accounts holding J.P. Morgan Funds composition of Investment Strategies or use of J.P. Morgan Funds in the Program. The use of J.P. Morgan Funds, non–J.P. Morgan Funds and JPMorgan Money Market Funds in a client’s Account will depend on the client’s asset level, the Model selected, reasonable restrictions placed by the client on the management of an Account, and other factors. Each client should review account opening documentation, confirmations, and quarterly and annual statements for more information about the actual allocation in their Account. If a Program Account owned by an IRA, or other client that is a qualified retirement plan subject to the prohibited transaction provisions of Section 4975 of the IRC, holds any J.P. Morgan Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with Program Account assets will be credited against the Advisory Fee. Refer to “Offset of Certain Fees to IRAs and Certain Other Retirement Plan Accounts” in Item 4 above. Prospectus Delivery for Managed Accounts The following charts for the Program show the allocation of assets between J.P. Morgan and non-J.P. Morgan Funds by Fund type for each Investment Strategy. The charts do not reflect models that elect not to use J.P. Morgan Funds, Models that elect only Index-Oriented Vehicles, or models that utilize Liquid Alternative Funds (other than the Aggressive Growth Investment Strategy because all Aggressive Growth Investment Strategies include Liquid Alternative Funds), Model Managers or municipal fixed income options. The charts show the difference between the taxable and retirement Models in each Investment Strategy (except for the U.S. Focused Model). Allocations shown here are illustrative only, do not necessarily represent actual use of J.P. Morgan Funds and third-party issuers and managers represented in any particular client’s Account, and can change without notice. In the Program, JPMPI has full discretionary authority to select securities, investment vehicles, Portfolio Managers and Model Managers, and is not required to adhere to the illustrative allocations pictured here. October 06, 2025—Taxable Models A discretionary investment adviser can receive prospectuses and other issuer-related materials on behalf of a client for mutual funds and ETFs in a client’s account with client authorization. JPMS, WMS, JPMPI or the Portfolio Manager, as a client’s agent, will have access to the prospectuses and issuer-related materials and can rely upon them to make mutual fund and ETF investments on the client’s behalf; however, clients will not receive such prospectuses or issuer-related materials directly, but can access them via the issuer’s website or request copies from their IAR at any time. Prospectuses and issuer-related materials contain important information and detailed descriptions of additional fees and expenses, investment minimums, risk factors and conflicts of interest disclosures as well as client’s rights, responsibilities and liabilities with respect to such investments. Additionally, contains other general this Brochure information regarding fees and expenses, invest minimums, risk factors and conflicts of interest disclosure. Core Solutions Six Circles Funds Risk of Loss J.P. Morgan Funds Non-J.P. Morgan Funds J.P. Morgan Cash 13.00% 57.00% 29.00% 1.00% Aggressive Growth Growth 7.00% 57.00% 35.00% 1.00% Balanced 6.00% 52.00% 41.00% 1.00% Conservative 4.00% 59.00% 36.00% 1.00% 2.00% 63.00% 34.00% 1.00% 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. 8.00% 26.00% 65.00% 1.00% 9.00% 61.00% 29.00% 1.00% Income Managed Equities Managed Fixed Income U.S. Focused 0.00% 99.00% 0.00% 1.00% 4.00% 95.00% 0.00% 1.00% Set forth below are certain material risk factors that are associated with the Program. There are certain other risk factors described elsewhere in this Brochure. For a more complete summary of material risk factors and conflicts of interest associated with the Program, refer to the applicable Portfolio Manager’s Form ADV Part 2A and/or any applicable prospectuses or other relevant disclosure documents. 3.00% 96.00% 0.00% 1.00% GENERAL RISKS Balanced ESG US Endowments & Foundations Core Solutions Six Circles Funds October 06, 2025—Retirement Models* J.P. Morgan Funds Non-J.P. Morgan Funds J.P. Morgan Cash 13.00% 57.00% 29.00% 1.00% Aggressive Growth Growth 7.00% 57.00% 35.00% 1.00% Balanced 6.00% 52.00% 41.00% 1.00% Conservative 4.00% 59.00% 36.00% 1.00% 2.00% 63.00% 34.00% 1.00% 8.00% 26.00% 65.00% 1.00% 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, embargoes, tariffs, sanctions and other trade barriers, regulatory events, other governmental trade or market control programs, and related geopolitical events. 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, pandemics or endemics. 9.00% 61.00% 29.00% 1.00% Income Managed Equities Managed Fixed Income U.S. Focused 0.00% 99.00% 0.00% 1.00% Balanced ESG 4.00% 95.00% 0.00% 1.00% *US Endowments & Foundations is not available to retirement accounts. Infectious Disease Risk. The effects of any future pandemic or other global events to business and market conditions may have a significant negative impact on the performance of the separately managed accounts and J.P. Morgan Fund investments; increase separately managed account and fund volatility; exacerbate pre-existing political, social, and economic risks 33821_COL 11-05-2025 Page 19 of 32  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. to separately managed accounts and J.P. Morgan Funds; 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 pandemic or other global events that affect the instruments in which a separately managed account or J.P. Morgan Funds invest, 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 pandemic or other global events and the extent to which the associated conditions and governmental responses impact a separately managed account or J.P. Morgan Affiliated Fund will also depend on future developments, which are highly uncertain, difficult to accurately predict and subject to frequent changes. Regulatory Risk. There have been legislative, tax, and regulatory changes and proposed changes that may apply to the activities of JPMS that may require legal, tax and regulatory changes, including requirements to provide additional information pertaining to a client Account to the Internal Revenue Service (IRS) or other taxing authorities. Regulatory changes and restrictions imposed by regulators, self-regulatory organizations and exchanges vary from country to country and may affect the value of client investments and their ability to pursue their investment strategies. Any such rules, regulations and other changes, and any uncertainty in respect of their implementation, may result in increased costs, reduced profit margins, and reduced investment and trading opportunities, all of which would negatively impact performance. Key Personnel Risk. If one or more key individuals become unavailable, including any of the portfolio managers of an Investment Strategy, who are important to the management of the portfolio’s assets, the portfolio could suffer material adverse effects, including substantial share redemptions that could require the portfolio to sell portfolio securities at times when markets are not favorable. 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, improper release, corruption and destruction of, or unauthorized access to, confidential 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 can 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 cyber security risks in their own businesses, which could result in losses to J.P. Morgan or its clients. While measures have been developed which 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 cybersecurity defenses or plans of its service providers, financial intermediaries and companies in which they invest or with which they do business. Use of AI Tools may lead to increased risks of cyber- attacks or data breaches and the ability to launch more automated, targeted and coordinated attacks due to the vulnerability of AI technology to cybersecurity threats. 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, or be otherwise harmful. J.P. Morgan typically incorporates human oversight to reduce the risk of acting on potentially defective outputs. AI Tools present Data Sources Risk, Cybersecurity Risk and Model Risk (as further 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 the Adviser’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Further, 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 Sources 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 accuracy 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 the data to J.P. Morgan 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 provided by third- party sources. 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 AI Tools often use data feeds from a number of sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool will be unable to properly function or their operation may be adversely impacted. The 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 33821_COL 11-05-2025 Page 20 of 32  other index levels, rates and values that are treated as “benchmarks” and are the subject of recent regulatory reform. Tax-Managed Strategies. There are risks and limitations associated with any tax-aware or tax-managed strategies (each such strategy, a Tax- Managed strategy), and these limitations may result in tax-inefficient trades and wash sales. Tax management is not tax advice and may not achieve the intended results. Although a Tax-Managed strategy may reduce a client’s taxable income, it will not eliminate it. A Tax-Managed strategy may require trade-offs that reduce pre-tax income. Managing a strategy to maximize after-tax returns may also potentially have a negative effect on a strategy’s performance. To the extent tax consequences are considered in managing a strategy, the strategy’s or Fund’s pre-tax performance may be lower than that of a similar strategy that is not tax managed. Model Risk. Some Investment Strategies can include the use of various proprietary quantitative or investment models. Investments selected using models may perform differently than expected as a result of changes from the factors’ historical — and predicted future — trends, and technical issues in the implementation of the models, including, for example, issues with data feeds. Moreover, the effectiveness of a model may diminish over time, including as a result of changes in the market and/or changes in the behavior of other market participants. A model’s return mapping is based partially on historical data regarding particular economic factors and securities prices. The operation of a model, similar to other fundamental, active investment processes, may result in negative performance, including returns that deviate materially from historical performance, both actual and pro-forma. For a model-driven investment process – and again similar to other, fundamental, and active investment processes, there is no guarantee that the use of models will result in effective investment outcomes for clients. Additionally, client accounts with lower asset levels can experience some dispersion from the established models. REITs Risk. The value of real estate securities in general, and REITs in particular, are subject to similar risks as direct investments in real estate and mortgages, and their value will be influenced by many factors including the value of the underlying properties or the underlying loans or interests. The underlying loans may be subject to the risks of default or of prepayments that occur later or earlier than expected and such loans may also include so-called "subprime" mortgages. The value of these securities will rise and fall in response to many factors, including economic conditions, the demand for rental property, interest rates and, with respect to REITs, the management skill and creditworthiness of the issuer. In particular, the value of these securities may decline when interest rates rise and will also be affected by the real estate market and by the management of the underlying properties. There is no public trading market for private or public non-traded REITs; therefore, such REITs may be more volatile and/or more illiquid than publicly traded REITs and other types of equity securities. 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. Tax Risks and Risks That Apply to Tax-Aware or Tax-Harvesting and Tax- Managed Strategies Exchange-Traded Funds 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 JPMPI. Unlike mutual funds, an ETF trades like a 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. Account transactions may give rise to tax liability for which a client is responsible. Funds may make large distributions of income and capital gains to investors at various times in a calendar year, and the client will be liable for taxes on such distributions without regard to the date of the client’s investment in a portfolio. 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 funds, there are specific risks to consider with respect to an investment in ETFs, including, but not limited to: Tax Harvesting will cause your Account holdings to differ from those accounts that do not utilize Tax Harvesting, and therefore your Account performance will differ. There is no guarantee that Tax Harvesting will perform as expected or that specific benefits will be obtained for any particular client. The implementation of Tax Harvesting may have an adverse effect on investment performance and result in adverse tax consequences, including, but not limited to, gains derived from the sale of the security held during the wash sale period. Further, the tax consequences of Tax Harvesting may be challenged by the Internal Revenue Service or any other tax authority. • Variance from benchmark index. ETF and index mutual fund performance may 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 mutual funds (such as mergers and spin-offs) may impact the variance between the performances of the funds and applicable indices. Neither JPMS, WMS nor its representatives or affiliates offer tax or accounting advice or services and the client should not solicit or rely upon any such advice from them. J.P. Morgan and its affiliates do not provide tax advice and clients should consult their own tax professional with respect to the impact of Tax Harvesting and the federal, state and local tax consequences of investing in any portfolio, including, without limitation, the potential application and impact of Section 1091 of the Code (the wash sale rules) with respect to their portfolio and their accounts with or outside of J.P. Morgan. The client is responsible for complying with all applicable tax rules, including, but not limited to, the wash sale rules, and the client is responsible for all tax consequences attributable to the disallowance of any losses under the wash sale rules. Further, certain investments may generate unwanted excise taxes, income taxes and penalties under the Code, as amended, any or all of which may affect the client’s return on investment and, if applicable, a client’s tax-exempt status. • 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. 33821_COL 11-05-2025 Page 21 of 32  The MLCD strategy typically has a monthly investment process and it can take an extended period of time (e.g., 60 days) for a client's account to be fully invested in the strategy. MLCDs provide principal protection from market downturns because the original principal is not impacted by market activity when held to maturity. There is no guarantee of principal return unless the investment is held to maturity. MLCDs are not publicly listed or traded on an exchange and therefore are illiquid investments. • Secondary market risk. ETF shares are bought and sold in the secondary market at market prices. Although ETFs are required to calculate their 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. Further, 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 would vary substantially from the NAV per share of such ETF, and the client may incur significant losses from the sale of ETF shares. Investing in an MLCD is not the same as investing directly in the underlying asset or index. The return on a MLCD at maturity generally will not be the same as the return on a direct investment in the underlying asset or index, and the maximum payment on a MLCD is subject to a cap, which would limit appreciation potential compared to a direct investment. A cap limits a client’s gain per year regardless of how well the relevant underlying asset or index performs. There are no voting rights or the right to receive dividends, distributions or other payments that would increase the return on a direct investment. Prior to maturity, the market value on the MLCD may change significantly, up or down, over a short period of time reflecting, a number of factors, including any volatility in the underlying asset or index, the time remaining until the MLCD matures, and the issuer's creditworthiness. The amount of principal or interest that can be expected to become payable on a MLCD may vary substantially from time to time. There is no guarantee that any payment in excess of the original MLCD value will be paid. • Capped upside potential risk. The return on certain MLCDs may be capped by a predetermined maximum return cap and, as a result, may be lower than the return on a direct investment in the applicable underlying index. • Federal Deposit Insurance Corporation (FDIC) Protection. MLCDs are insured CDs subject to applicable FDIC limits and regulations. In general, the original value of a MLCD held by clients is insured by the FDIC up to the amount permitted by law per issuer. A client purchasing a principal amount of MLCDs in excess of FDIC insurance limits, when aggregated with all other deposits held by the client at the respective issuer, will be subject to the credit risk of the issuer. In addition, any payment of the MLCD in excess of the applicable FDIC insurance limits is subject to the credit risk of the issuer. • Rate of return. Rate of return is calculated based on the valuation date of the CD based on the particular terms of the contract. There is no guarantee that any payment in excess of the original CD value will be paid. • Principal protection. MLCDs provide principal protection from market downturns because the original principal is not at risk, when held to maturity. The investor is risking the interest that would otherwise be paid on the CD for the term. MLCDs sold before maturity may be worth less than the purchase amount or face value. There is no guarantee of principal return unless the investment is held to maturity. investment. In addition, • Tracking the index. Certain funds track financial indexes indices in which J.P. Morgan retains various intellectual property rights. As a result, J.P. Morgan may be entitled to receive index licensing fees from unaffiliated licensees of these indices. Affiliates of JPMPI may develop or own and operate stock market and other indices based on investment and trading strategies developed by such affiliates. Affiliates of JPMPI may also assist unaffiliated entities in creating indices that are tracked by certain ETFs or certain client accounts utilized by JPMPI. Some of the ETFs advised by affiliates of JPMS (J.P. Morgan ETFs) seek to track the performance of certain of these indices. In addition, J.P. Morgan may manage client accounts which track the same indices used by the J.P. Morgan ETFs or which may be based on the same, or substantially similar, strategies that are used in the operation of the indices and the J.P. Morgan ETFs. The operation of the indices, the J.P. Morgan ETFs and client accounts in this manner may give rise to potential conflicts of interest. For example, client accounts that track the same indices used by the J.P. Morgan ETFs may engage in purchases and sales of securities relating to index changes to a time different to the implementation of index updates or J.P. Morgan ETFs engaging in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the J.P. Morgan ETFs’ 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 or less favorable performance relative to that of the index and the J.P. Morgan ETFs or other client accounts that track the index. Furthermore, J.P. Morgan may, from time to time, manage client accounts that invest in these J.P. Morgan ETFs. Other potential conflicts include the potential for unauthorized access to index information, allowing index changes that benefit JPMPI 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 coordinating the development and governance of the indices and those involved in decision-making for the ETFs and index mutual funds. • MLCD issuer credit risk. Any investment in an MLCD that exceeds applicable FDIC insurance limits is subject to the ability of the issuer to make payments when due. If the issuer defaults on its payment obligations, the client may not receive any amount in excess of applicable FDIC insurance limits and could lose all or a significant portion of the initial investment, including the loss of the client's entire the actual or perceived creditworthiness of the issuer may affect the value of MLCDs prior to maturity. Market-linked Certificates of Deposit (MLCD). MLCDs are a type of structured products (Structure) which are securities whose value is derived from an underlying asset or index. Structures have varying degrees of risk and can offer full or partial principal protection, others can subject you to the loss of the full amount invested. In addition, you are dependent on the issuer’s financial capacity to meet its obligations under a Structure. Structures may not be publicly listed or traded on an exchange and therefore may be illiquid investments. 33821_COL 11-05-2025 • Early liquidation and secondary market risk. MLCDs are highly illiquid, long-term investments and a client may not be able to redeem their MLCD at their discretion. MLCDs are typically not listed on any securities exchange, and there is no guarantee of the existence of a secondary market. Neither the issuer, the Adviser, nor any other person is required to maintain a secondary market for any MLCD. Accordingly, there may be limited opportunities, if any, to redeem MLCDs prior to maturity and a client may be unable to sell Page 22 of 32  of funds and strategies to be considered for inclusion in the ESG Strategies offered to our clients. their MLCD prior to its maturity date. MLCDs generally are repurchased only by the issuer and only upon terms and conditions acceptable to such issuer, and, in most cases, the MLCDs are non- transferable and non-negotiable. In the event an issuer consents to early liquidation, the client will likely not fully participate in the benefits of the MLCD, such as principal protection, buffers, or enhanced returns. The price offered by the issuer may be lower than the principal amount of the MLCD. • Tax treatment. MLCDs may be treated differently than traditional CDs for tax purposes. Before investing in these products, you should carefully review the disclosures concerning the reporting of interest income and consult a tax adviser if appropriate. 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 difference in 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 an investment to be classified as a “sustainable investment.” Unless otherwise specified and where permitted by applicable law, 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. that Category Restrictions and Exclusions Risks 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. 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, WMS or the Portfolio Manager may rely on information about a company, industry classification, industry grouping and/or issuer screening provided by J.P. Morgan, an affiliate service provider or a third party. Category restrictions aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category; however, they do not exclude all companies with any tie or revenue derived from such restricted category. If a client holds an investment that is perceived to belong to the restricted category, such security will be sold and could result in a taxable event for the client. incorporate ESG considerations or Investment approaches sustainable investing can include additional risks. ESG or sustainable investing strategies (together, ESG Strategies), including SMAs, 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. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries that share common characteristics and are often 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 or investment adviser selected by J.P, Morgan, will align with the beliefs or values of the client. Additionally, other investment managers and investment advisers 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. In addition to the ESG Strategies, J.P. Morgan also offers investment products that utilize ESG criteria in developing the product while seeking to maximize financial return. When evaluating investments, an investment manager or investment adviser is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause the manager/adviser to incorrectly assess an investment’s ESG or sustainable attributes. In making investment decisions, J.P. Morgan uses 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 or programs 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. Further, 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. JPMS and its affiliates do not review, guarantee or validate any third-party data, issuer screenings and ratings, screenings or processes. Moreover, processes to implement category restrictions are not absolute and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in 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. ESG and sustainable investing are not uniformly defined concepts, and scores or ratings may vary across 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 companies 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 sustainability-related practices and the Advisor’s assessment of such practices could change over time. The application of category restrictions vary by asset class. Restrictions are not available for all strategies, and WMS or the Portfolio Manager can reject a restriction if it deems the restriction to be unreasonable or not in line with the strategy. The number of restrictions that a client can select are limited based on the potential impact to the applicable Investment Strategy and potential deviation from the Investment Strategy. Only those restrictions that can be applied by WMS or the Portfolio Manager will be applied. 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. J.P. Morgan takes a global approach to ESG and sustainable investing, and the solutions offered through our sustainable investing platform meet our internally developed criteria for inclusion in our sustainable investing platform and, where applicable, take into account ESG or sustainable investing regulations. As part of the due diligence process, the manager solutions team of JPMPI or any of its affiliates applies an eligibility framework that establishes minimum criteria for determining the universe 33821_COL 11-05-2025 Page 23 of 32  Methods of Analysis and Risk of Loss—JPMS as Implementation Manager for Model Manager Investment Strategies in the Advisory Program fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. JPMS will implement Model Manager Investment Strategies. When acting as Implementation Manager, JPMS generally purchases and sells in the Accounts investments that are consistent with the Model Portfolios provided by the Model Manager, though JPMS retains investment discretion over the Account investments. Active Trading. Certain Investment Strategies engage in active and frequent trading leading to increased portfolio turnover, higher transaction costs, and the possibility of increased capital gains, including short-term capital gains that are generally taxable as ordinary income. Risks That Apply Primarily to Equity Investments Equity Securities. Investment Strategies that invest in equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected or recommended for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Geographic and Sector Focus Risk. Certain Investment Strategies concentrate their investments in a region, small group of countries, an industry or economic sector, and as a result, the value of the portfolio will generally be subject to greater volatility than a more geographically or sector diversified portfolio. Investments in issuers within a country, state, geographic region, industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio may affect the overall value of the portfolio and may cause greater losses than it would in a portfolio that holds more diversified investments. Diversification Risk. Certain asset allocation and Model Portfolio construction processes assume that diversification is beneficial. This concept is a generally accepted investment principle, although no amount of diversification can eliminate investment risk, and the investment returns of a diversified portfolio may be lower than a more concentrated portfolio or a single investment over a similar period. Equity securities that are included for inclusion in growth strategies are generally those that the IAR or Portfolio Manager believes will experience rapid earnings growth relative to value or other types of stocks. The value of these stocks generally is much more sensitive to current or expected earnings than stocks of other types of companies. Short-term events, such as a failure to meet industry earnings expectations, can cause dramatic decreases in the growth stock price compared to other types of stock. Growth stocks generally trade at higher multiples of current earnings compared to value or other stocks, leading to inflated prices and thus potentially greater declines in value. Focused Portfolio Risk. A focused portfolio Investment Strategy’s portfolio will generally have more volatility risk than a strategy that invests in securities of a greater number because changes in the value of an individual security will have a more significant effect, either negative or positive, on the portfolio’s value. To the extent that the portfolio invests its assets in fewer securities, the portfolio is subject to greater risk of loss if any of those securities lose value. in securities of foreign Equity securities that are included or recommended for inclusion in value strategies are generally those that the IAR or the Portfolio Manager believes the market has undervalued, according to the IAR’s or Portfolio Manager’s estimate of the company’s true worth. An IAR or Portfolio Manager that engages in value investing selects stocks at prices that it believes to be temporarily low relative to factors such as the company’s earnings, cash flow or dividends. A value stock can decrease in price or not increase in price as anticipated by the IAR or Portfolio Manager if other investors fail to recognize the company’s value or the factors that the IAR or Portfolio Manager believes will cause the stock price to increase do not occur. Foreign Issuers Risk. Investments issuers denominated in foreign currencies are subject to risks in addition to the risks of securities of U.S. issuers. These risks include political and economic risks, civil conflicts and war, greater volatility, expropriation and nationalization risks, sanctions or other measures by the United States or other governments, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in “emerging markets,” which may have relatively unstable governments and less-established market economies than those of developed countries. Certain Investment Strategies or Portfolio Managers may invest or may recommend investments in securities of smaller companies. Investments in smaller companies are generally riskier than investments in larger companies. Securities of smaller companies tend to be less liquid than securities of larger companies. In addition, small companies are generally more vulnerable to economic, market and industry changes. As a result, the changes in value of their securities may be more sudden or erratic than in large capitalization companies, especially over the short term. Because smaller companies may have limited product lines, markets or financial resources or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than large capitalization companies. This may cause unexpected and frequent decreases in the value of an investment. Finally, emerging companies in certain sectors may not be profitable and may not realize earning profits in the foreseeable future. Emerging Markets Risk. International investing bears greater risk due to social, economic, regulatory and political instability in countries in “emerging markets.” Emerging market securities can be more volatile and less liquid than developed market securities. Changes in exchange rates and differences in accounting and taxation policies outside the United States can also affect returns. Investments in foreign currencies and foreign issuers are subject to additional risks, including political and economic risks, greater volatility, civil conflicts and war, currency fluctuations, higher transaction costs, delayed settlement, possible foreign controls on investment, expropriation and nationalization risks, and less stringent investor protection and disclosure standards. These risks are magnified in countries in “emerging markets.” Equity Investment Conversion Risk. A non-equity investment such as a convertible debt obligation, may convert to an equity security. Alternatively, equity securities may be acquired in connection with a restructuring event related to non-equity investments. An investor may be unable to liquidate the equity investment at an advantageous time from a pricing standpoint. Other Miscellaneous Investment Risks Counterparty Risk. An account may have exposure to the credit risk of counterparties with which it deals in connection with the investment of its assets, whether engaged in exchange traded or off-exchange transactions or through brokers, dealers, custodians and exchanges through which it engages. In addition, many protections afforded to cleared transactions, such as the security afforded by transacting through a clearing house, might not be available in connection with over-the-counter (OTC) Liquidity Risk. Investments in some equity or other instruments can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a 33821_COL 11-05-2025 Page 24 of 32  transactions. Therefore, in those instances in which an account enters into OTC transactions, the account will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and will sustain losses. This includes where accounts enter into uncollateralized covered agency transactions and derivatives transactions. Currency Risk. Changes in foreign currency exchange rates will affect the value of certain portfolio securities. Generally, when the value of the U.S. dollar rises in value relative to a foreign currency, an investment impacted by that currency loses value because that currency is worth less in U.S. dollars. Currency exchange rates may fluctuate significantly over short periods of time for a number of reasons, including changes in interest rates. Devaluation of a currency by a country’s government or banking authority also will have a significant impact on the value of any investments denominated in that currency. Currency markets generally are not as regulated as securities markets, may be riskier than other types of investments, and may increase the volatility of a portfolio. Concentration of Investments. Concentration of investments in a region, a small group of countries, or an industry or economic sector or in specific securities resulting in holding a relatively small number of securities positions, each representing a relatively large portion of assets, can result in the value of an account being subject to greater volatility than a more geographically or sector diversified portfolio. Investments in issuers within a country, state, geographic region, industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio may affect the overall value of the portfolio and may cause greater losses than it would in a portfolio that holds more diversified investments. ITEM 7 — CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS that finds that JPMS violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 and Rule 206(4)-7, and JPMCB violated Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The Order finds that JPMCB negligently failed to adequately disclose (a) from February 2011 to January 2014, a preference for affiliated mutual funds in certain discretionary investment portfolios (the Discretionary Portfolios) managed by JPMCB and offered through J.P. Morgan’s U.S. Private Bank (the U.S. Private Bank) and the Chase Private Client lines of business; (b) from 2008 to 2014, a preference for affiliated hedge funds in certain of those portfolios offered through the U.S. Private Bank; and (c) from 2008 to August 2015, a preference for retrocession-paying third-party hedge funds in certain of those portfolios offered through the U.S. Private Bank. With respect to JPMS, the Order finds, that from May 2008 to 2013, JPMS negligently failed to adequately disclose, including in documents filed with the SEC, conflicts of interest associated with its use of affiliated mutual funds in the Chase Strategic Portfolio (CSP) program, specifically, a preference for affiliated mutual funds, the relationship between the discounted pricing of certain services provided by an affiliate and the amount of CSP assets invested in affiliated products, and that certain affiliated mutual funds offered a lower-cost share class than the share class purchased for CSP. In addition, the Order finds that JPMS failed to implement written policies and procedures adequate to ensure disclosure of these conflicts of interest. Solely for the purpose of settling these proceedings, the Respondents consented to the Order, admitted to the certain facts set forth in the Order, and acknowledged that certain conduct set forth in the Order violated the federal securities laws. The Order censures JPMS and directs the Respondents to cease-and-desist from committing or causing any violations and any future violations of the above-enumerated statutory provisions. Additionally, the Order requires the Respondents to pay a total of $266,815,000 in disgorgement, interest and civil penalty. Investment Strategy (or Strategies), JPMS provides to Overlay, Implementation and Portfolio Managers a summary of client information relevant to Overlay, Implementation and Portfolio Managers’ services to the client, including the client’s name, address, Account number, Social Security number or taxpayer identification number, whether the Account is taxable or non-taxable, the client’s selected investment restrictions requested by the client, and the amount to be invested. The information provided to the Overlay, the Implementation and the Portfolio Managers is updated if it becomes materially incorrect, such as in the event that the client changes the investment restrictions. ITEM 8 — CLIENT CONTACT WITH PORTFOLIO MANAGERS Personnel of JPMS, its affiliates and Portfolio Managers who are knowledgeable about the management of client Accounts are available for client consultation upon reasonable request. IARS can assist clients in contacting such personnel. Concurrently, on December 18, 2015, JPMCB reached a settlement agreement with the Commodity Futures Trading Commission (CFTC) to resolve its investigation of JPMCB’s disclosure of certain conflicts of interest to discretionary account clients of J.P. Morgan Private Bank’s U.S.-based wealth management business. In connection with the settlement, the CFTC issued an order (CFTC Order) finding that JPMCB violated Section 4o(1)(B) of the Commodity Exchange Act (CEA) and Regulation 4.41(a)(2) by failing to fully disclose to certain clients its preferences for investing certain discretionary portfolio assets in certain commodity pools or exempt pools, namely (a) investment funds operated by J.P. Morgan Asset Management, and (b) third-party managed hedge funds that shared management and/or performance fees with an affiliate of JPMCB. The CFTC Order directs JPMCB to cease- and-desist from violating Section 4o(1)(B) of the CEA and Regulation 4.41(a)(2). Additionally, JPMCB shall pay $40 million as a civil penalty to the CFTC and disgorgement of $60 million satisfied by disgorgement to be paid to the SEC by JPMCB and an affiliate in a related and concurrent settlement with the SEC. a of the Order, go to: sec.gov/litigation/ For copy admin/2015/33-9992.pdf. For Program Accounts, JPMS, JPMPI, Portfolio Manager and Model Manager personnel knowledgeable about the management of the Program Accounts are available for client consultation upon reasonable request. IARs can assist clients in contacting such personnel. For Guided Accounts, clients select Funds for their Accounts. Clients will generally have no contact with the investment advisers of the Funds. JPMS personnel knowledgeable about the management of the Guided Accounts are available for client consultation upon reasonable request. IARs can assist clients in contacting such personnel. ITEM 9 — ADDITIONAL INFORMATION A. Disciplinary Information JPMS has been involved in the following material legal or disciplinary events during the last ten years. 1) On December 18, 2015, JPMS and JPMCB (together, Respondents) entered into a settlement with the SEC resulting in the SEC issuing an order (Order). The Respondents consented to the entry of the Order 2) On or about July 28, 2016, JPMS and JPMCB entered into a Consent Agreement (Agreement) with the 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 33821_COL 11-05-2025 Page 25 of 32  (iii) until November 2013, JPMS failed to disclose to CSP clients the availability of certain less expensive J.P. Morgan Fund share classes. Solely for the purpose of settling these proceedings, JPMS consented to the March 2020 Order, with no admissions as to liability. JPMS agreed to pay a total of $325,000 to resolve the KDFI investigation. 6) 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. 3) In October 2018, JPMS submitted an 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) reasonably 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 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. 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. 4) 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 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. 7) 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. 5) 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 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 J.P. Morgan Funds; (ii) there was an economic incentive to invest CSP assets in J.P. Morgan Funds as a result of discounted pricing for services provided to JPMS for CSP by a JPMS affiliate; and 8) 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 Advisers Act and Rule 33821_COL 11-05-2025 Page 26 of 32  Affiliated Portfolio Managers and Model Managers in the Program JPMS and IARs can recommend to clients Portfolio Managers and Model Managers that are affiliated with JPMS. Should clients select an affiliated Portfolio Manager or Model Manager, it is important to note that JPMC receives more overall fees when affiliated Portfolio Managers or Model Managers are used. JPMS addresses this through disclosure to clients. Affiliated Fund Advisors and Model Managers Funds, including money market funds, pay fees and expenses that are ultimately borne by clients. Clients can review the applicable prospectuses for Funds in the Program for additional information about these fees and expenses. These fees and expenses are in addition to the Advisory Fee. Refer to “Other Fees and Expenses” in Item 4 above for more information. 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. B. Other Financial Industry Activities and Affiliations JPMS’ primary business is providing brokerage products and services as a bank-affiliated broker-dealer and making available to its customers, in addition to investment advisory services, a variety of bank, securities and insurance products through its affiliates. JPMS’ officers, managers and Advisors spend the majority of their time in administrative or supervisory duties with broker-dealer activities rather than investment advisor activities. Affiliates of JPMS provide investment advisory and other services to the J.P. Morgan Funds for compensation. Therefore, because JPMS and its affiliates will in the aggregate receive more revenue when Accounts are invested in J.P. Morgan Funds than they would receive if the Accounts were invested in non–J.P. Morgan Funds, JPMS has a conflict of interest when Accounts are invested in J.P. Morgan Funds. The use of an affiliated Sub- Adviser in the Program is also a benefit to JPMS and its affiliates since it increases the overall revenue of affiliates of JPMS and their parent company. JPMS addresses this conflict through disclosure and subjecting the J.P. Morgan Funds and non-J.P. Morgan Funds to the investment process described in Item 6 above. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” in Item 6 above for more information on the use of J.P. Morgan Funds. Securities Allocations and Limitations JPMS is affiliated with several other SEC-registered broker-dealers, investment companies, investment advisers, insurance agencies, mortgage companies and JPMCB. Other registered investment advisers, collectively referred to as “J.P. Morgan Asset Management,” are affiliated with JPMS under the common ownership by JPMC. One or more of these affiliated investment advisers, including, but not limited to, JPMIM, serve(s) as the investment adviser to various J.P. Morgan Funds. Program clients, by selecting a Program, Model or Investment Strategy which uses affiliated Portfolio Managers, or by investing in J.P. Morgan Funds within their Program Account, should note that JPMC receives more overall fees. JPMS affiliates will benefit from such selection and/or purchase as the result of receipt of the investment advisory fees. JPMS addresses this conflict through disclosure to clients. JPMS is part of a large financial services firm. In connection with providing investment advisory services to its clients, JPMS uses the products or services of its affiliates or other related persons, as described both above and below. JPMS and/or its affiliates can receive more compensation from certain Accounts that use strategies similar to those used by Accounts (Similar Accounts) than it or its affiliates receive from Accounts. JPMS or its affiliates have a conflict of interest to the extent that JPMS or an affiliate has a proprietary investment in Similar Accounts, JPMS’ and/or its affiliates’ portfolio managers have personal investments in Similar Accounts, or the Similar Accounts are investment options in JPMS’ or its affiliates’ employee benefit plans. JPMS can receive as additional compensation distribution (Rule 12b-1) fees on money market fund assets held in Program Accounts. If a client selects a money market fund for which an affiliate of JPMS serves as investment advisor, the client will pay both its pro rata share of the money market funds advisory fees paid to JPMS or an affiliate as well as the Advisory Fee on the assets invested in the money market fund. However, any 12b-1 fees received by JPMS will be credited to the client’s Program Account. C. Material Relationships with Related Persons and Potential Conflicts of Interest JPMS and its affiliates maintain certain investment limitations on the positions in securities, or other financial instruments, that JPMS or its affiliates will take on behalf of its various clients due to, among other things: (i) liquidity concerns; (ii) operational considerations; (iii) regulatory requirements applicable to JPMS or its affiliates; and (iv) internal policies related to such concerns or requirements, in light of the management of multiple portfolios and businesses by JPMS and its affiliates. Such policies preclude JPMS or its affiliates from purchasing certain securities for clients and can cause JPMS to sell certain securities held in client accounts. A potential conflict of interest also can arise if transactions in one Account closely follow related transactions in a different Account, such as when a purchase increases the value of securities previously purchased by another Account or when a sale in one Account lowers the sale price received in a sale by a second Account. JPMS has several relationships or arrangements with related persons that are material to its investment advisory business or to clients in the Program. Below is a description of such relationships and some of the conflicts of interest that arise from them. JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest that may arise between JPMS and its affiliates. These policies and procedures include information barriers designed to prevent the flow of information between JPMS and certain other affiliates, as more fully described below. The use of affiliates to provide services to clients creates certain conflicts of interest for JPMS, JPMIM, WMS and JPMPI. Among other things, there are financial incentives for JPMS, , JPMIM, WMS and JPMPI (and their affiliates), including its parent company, JPMC, to favor affiliated service providers over non-affiliated service providers, and compensation of supervised persons of JPMS , JPMIM, WMS and JPMPI generally is directly or indirectly related to the financial performance of JPMorgan. 33821_COL 11-05-2025 Conflicts of interest can arise with both the allocation of investment opportunities, including trading opportunities and pricing of trading generally, and the aggregation of orders and allocation of executed transactions specifically, because of market factors or investment restrictions imposed upon JPMS and its affiliates by law, regulation, contract or internal policies. Allocations of transactions resulting from aggregated orders, particularly orders that are only partially completed (due to limits on availability, capacity constraints and other factors) and allocation of investment opportunities generally, would raise a conflict of interest where WMS or its affiliates have an incentive to allocate investment opportunities or securities that are expected to increase in value to favored accounts, including affiliated accounts and accounts that pay higher fees. JPMS mitigates this conflict by using guidelines designed by JPMS and Page 27 of 32  Account. JPMS, directly or indirectly, receives servicing or administrative fees for certain Funds that are held in a client’s Account. Refer to the discussion of “Share Classes” in Item 4 above for more information on the receipt of administrative and servicing fees. In addition, JPMS’ affiliates receive licensing fees for their indices used by unaffiliated ETFs or other product sponsors. affiliates to allocate investment and trading opportunities among similarly situated Program Accounts on a fair and equitable basis over time. A conflict of interest also would arise if transactions in securities in one account closely follow transactions in the same securities in different accounts, especially when the transactions or series of transactions are large in relation to the securities’ trading volume and potentially have market impact, such as when a purchase increases the value of securities previously purchased by the other accounts or when a sale in one account lowers the sale price received in a sale by other accounts. JPMS has negotiated revenue sharing arrangements with a number of mutual funds and mutual fund families. Some of these mutual funds are available in the Program, and JPMS will receive additional revenue on either the mutual fund assets in Accounts or on the initial purchase of these mutual funds. Some of the mutual funds make revenue sharing payments to JPMS for mutual funds held in brokerage Accounts for which JPMS does not provide investment advisory services. Additional information about these arrangements is available at jpmorgan.com/TheGuide. Advisors are not compensated from JPMS’ receipt of shared revenues received from mutual funds. J.P. Morgan’s Use and Ownership of Trading Systems interest. J.P. Morgan will receive JPMS and its affiliates have intercompany arrangements whereby one or more affiliates share personnel for one or more purposes, including the construction and implementation of trade orders for multiple programs and affiliated entities. Any such shared personnel are subject to the policies and procedures of the applicable affiliate when acting on its affiliate’s behalf. Any such shared personnel will have potentially conflicting interests when playing these various roles. Such personnel splitting time and attention between one or more JPMS affiliates creates conflicts of interest in that the time and effort of these shared personnel will not necessarily be devoted exclusively, or even predominately, to JPMS. While the affected affiliates have adopted policies, procedures or guidelines to address conflicts of interest associated with personnel sharing, such policies, procedures or guidelines can differ and there can be no assurance that such policies, procedures or guidelines will successfully eliminate or mitigate all such conflicts in every case. Conflicts Related to the Advising of Multiple Accounts JPMS may effect trades on behalf of Program Accounts through exchanges, electronic communications networks, alternative trading systems, and similar execution systems and trading venues (collectively, Trading Systems), including Trading Systems in which J.P. Morgan has a direct or indirect ownership indirect proportionate compensation based upon its ownership percentage in relation to the transaction fees charged by such Trading Systems in which it has an ownership interest. Such Trading Systems (and the extent of J.P. Morgan’s ownership interest in any Trading System) may change from time to time. JPMS addresses this conflict by disclosure to its clients. Ownership Interest in J.P. Morgan Stock Certain asset management firms (each, an asset manager) through their funds and separately managed accounts currently hold a 5% or more 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 (collectively, JPM) recommends or purchases the publicly traded security of the asset manager or the separately managed accounts or funds that are managed or advised by the asset manager. JPM addresses this conflict by disclosing the ownership interest of the asset manager and by subjecting the asset manager’s separately managed accounts and funds to a research process. Additionally, the financial advisors 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 February 26, 2025, the Vanguard Group, Inc. and BlackRock, Inc. hold more than a 5% interest in J.P. Morgan. Payment for Order Flow Certain portfolio managers of JPMS manage or advise multiple client accounts, investment vehicles or portfolios. These portfolio managers are not required to devote all or any specific portion of their working time to the affairs of any specific client. Conflicts of interest do arise in allocating management time, services, or functions among such clients, including clients that have the same or similar type of investment strategies. JPMS addresses these conflicts by disclosing them to clients and through its supervision of portfolio managers and their teams. Responsibility for managing JPMS’ client portfolios is organized according to investment strategies within asset classes. Generally, client portfolios with similar strategies are managed by portfolio managers in the same portfolio management group using the same or similar objectives, approach and philosophy. Therefore, portfolio holdings, relative position sizes, industry and sector exposures generally tend to be similar across client portfolios with similar strategies. JPMS faces conflicts of interest when JPMS’ portfolio managers manage accounts or portfolios with similar investment objectives and strategies. For example, investment opportunities that are appropriate for certain clients may also be appropriate for other groups of clients, including the clients of JPMS, other affiliated investment advisers, and related persons, and, as a result, client accounts would have to compete for positions. There is no specific limit on the number of accounts which will be managed or advised by JPMS or its related persons. Once held by a client, certain investments compete with other investments held by other clients of JPMPI and its related persons. The conflict associated with managing assets on behalf of different clients that compete with each other are heightened when JPMS retains certain management, control or consent rights over such assets. JPMS has controls in place to monitor and mitigate these potential conflicts of interest. Also, it is JPMS’ policy, to the extent practicable, to allocate, within its reasonable discretion, investment opportunities among clients over a period of time on a fair and equitable basis. One or more of JPMS’ other client accounts may at any time hold, acquire, increase, decrease, dispose of, or otherwise deal with positions in investments in which another client account would have an interest. For instance, due to differences in investment strategies, JPMS might sell a security for a client at the same time that it might hold or purchase the same security for a different client. Distribution and Other Fees and Revenue Sharing JPMS does not receive payment for order flow from market makers for customer orders in equity securities. JPMS receives rebates from and pays fees to some registered securities exchanges for providing or taking liquidity on those exchanges, according to those exchanges’ published fee schedules approved by the SEC. Alternative trading systems also charge fees and, in some cases, pay rebates for the provision or removal of liquidity. In addition, JPMS receives marketing fees from options exchanges under marketing fee programs sponsored by some exchanges. Under some circumstances, the amount received by JPMS from a trading center over a period of time may exceed the amount that JPMS is charged by a trading center. These practices are one of many factors that may impact routing decisions and do not alter JPMS’ policy to route customer orders in securities to the trading centers where it believes customers will receive the best execution, taking into account, among other factors, price, transaction cost, volatility, reliability, market depth and speed. JPMS receives distribution fees from certain mutual funds pursuant to Rule 12b-1 under the Investment Company Act of 1940. If JPMS receives 12b-1 fees on load-waived Class A shares, it will credit these fees to the client’s 33821_COL 11-05-2025 Page 28 of 32  non-institutional clients. Refer to Item 4 for additional conflicts of interest and other information relating to the sweep Deposit Account. All (or substantially all) IARs are employees of JPMCB. In their capacities as employees of JPMCB and outside of the Program, IARs may market and sell to clients products and services of JPMCB and be compensated in connection with such sales. available in Rule 606 reports Affiliates of JPMS have ownership interests in some trading centers. Accordingly, JPMS stands to share in any profits that these trading centers earn from the execution of JPMS customer orders on those trading centers. Additional information on the material aspects of JPMS’ relationships with the primary trading centers to which JPMS routes, including descriptions of arrangements for payment for order flow and profit-sharing relationships, is at SEC JPMS’ jpmorgan.com/OrderExecution. D. Participation or Interest in Client Transactions and Other Conflicts of Interest J.P. Morgan’s Use of Index Products J.P. Morgan Acting in Multiple Commercial Capacities JPMS or one of its affiliates develop or own and operate stock market and other indexes based on investment and trading strategies developed by JPMS or its affiliates or assist unaffiliated entities in creating indexes that are tracked by certain ETFs utilized by JPMS or an affiliate. Some of the ETFs for which an affiliate of JPMS acts as investment adviser (the JPM ETFs) seek to track the performance of these indexes. JPMS and its affiliates from time to time manage client accounts that invest in these JPM ETFs. In addition, JPMS and its affiliates manage client accounts which track the same indexes used by the JPM ETFs or which are based on the same, or substantially similar, strategies that are used in the operation of the indexes and the JPM ETFs. The operation of the indexes, the JPM ETFs and the client accounts in this manner gives rise to potential conflicts of interest. For example, client accounts that track the same indexes used by the JPM ETFs may engage in purchases and sales of securities relating to index changes prior to the implementation of index updates or the time as of which the JPM ETFs engage in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the JPM ETFs’ portfolios are only rebalanced on a periodic basis corresponding with the rebalancing of an index. These differences can result in the client accounts having more favorable performance relative to that of the index and the JPM ETFs or other client accounts that track the index. Other 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 JPM ETFs. JPMS and its affiliates have established certain information barriers and other policies to address the sharing of information between different businesses within JPMS and its affiliates, including with respect to personnel responsible for maintaining the indexes and those involved in decision-making for the JPM ETFs. Other Compensation from ETFs from providing J.P. Morgan is a diversified financial services firm that provides a broad range of services and products to its clients and is a major participant in the global currency, equity, commodity, fixed income and other markets in which JPMS client Accounts invest. J.P. Morgan is typically entitled to compensation in connection with these activities, and the Program clients will not be entitled to any such compensation. In providing services and products to clients other than JPMS’ clients, J.P. Morgan from time to time faces conflicts of interest with respect to activities recommended to or performed for JPMS clients on one hand and for J.P. Morgan’s other clients on the other hand. For example, J.P. Morgan has, and continues to seek to develop, banking and other financial and advisory relationships with numerous U.S. and non-U.S. persons and governments. J.P. Morgan also advises and represents potential buyers and sellers of businesses worldwide. JPMS client Accounts have invested in, and in the future may invest in, such entities represented by J.P. Morgan or with which J.P. Morgan has a banking, advisory or other financial relationship. In addition, certain clients of J.P. Morgan, including JPMS clients, invest in entities in which J.P. Morgan holds an interest, including a J.P. Morgan Fund or J.P. Morgan ETF. In providing services to its clients and as a participant in global markets, J.P. Morgan from time to time recommends or engages in activities that compete with or otherwise adversely affect a JPMS client Account or its investments. It should be recognized that such relationships can preclude JPMS’ clients from engaging in certain transactions and can also restrict investment opportunities that would otherwise available to JPMS clients. For example, J.P. Morgan is often engaged by companies as a financial adviser, or to provide financing or other services, in connection with commercial transactions that are potential investment opportunities for JPMS’ clients. There are circumstances in which advisory accounts are precluded from participating in such transactions as a result of J.P. Morgan’s engagement by such companies. J.P. Morgan reserves the right to act for these companies in such circumstances, notwithstanding the potential adverse effect on JPMS’ clients. In addition, J.P. Morgan derives ancillary benefits investment advisory, custody, administration, prime brokerage, transfer agency, fund accounting and shareholder servicing, and other services to JPMS’ clients. Providing such services to JPMS’ clients enhances J.P. Morgan’s relationships with various facilitates additional business development, and enables parties, J.P. Morgan to obtain additional business and generate additional revenue. Certain ETFs in which Account assets may be invested in for the Program may execute transactions for their portfolios through JPMS or an affiliate as broker-dealer, and JPMS or an affiliate may receive traditional brokerage compensation and fees from the ETFs in connection with these transactions. Such compensation presents a conflict of interest between JPMS and Program clients because JPMS may have a financial incentive to invest Account assets in such ETFs: (1) in the hope or expectation that increasing the amount of assets invested with the ETFs will increase the number and/or size of transactions placed by the ETFs 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 ETFs and thereby preserve and foster valuable brokerage relationships with the ETFs. Portfolio Manager Trading Practices in the Program The following are descriptions of certain additional conflicts of interest and potential conflicts of interest that are associated with the financial or other interests that JPMS and J.P. Morgan have in transactions effected by, with or on behalf of its clients. In addition to the specific mitigants described further below, JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest. In addition, many of the activities that create these conflicts of interest are limited and/or prohibited by law and are conducted under an available exception. Certain Portfolio Managers can execute trades for institutional and other non-wrap fee clients before executing trades for clients in SMA programs, such as the “Program”. As a result, Program Accounts can pay a higher price, or receive a lower price, than the Portfolio Manager’s trades in the same security for institutional or other clients. Trade execution practices of the Portfolio Managers are described in the Portfolio Manager ADV Disclosure Document, which is provided to Program clients. JPMorgan Chase Bank, N.A. J.P. Morgan or JPMS’ related persons provide financial, consulting, investment banking, advisory, brokerage (including prime brokerage) and other services to, and receive customary compensation from, an issuer of equity or debt securities held by client Accounts. Any fees or other compensation received by J.P. Morgan in connection with such activities will not be shared with the Program clients or used to offset fees charged to Program clients. Such compensation could include financial advisory fees, monitoring fees, adviser fees or fees in connection with restructurings JPMCB is a national banking association affiliated with JPMS and is subject to supervision and regulation by the U.S. Department of Treasury's Office of the Comptroller of the Currency. JPMCB provides investment management, trustee, custody and other services to both institutional and 33821_COL 11-05-2025 Page 29 of 32  or mergers and acquisitions, as well as underwriting or placement fees, financing or commitment fees, trustee fees and brokerage fees. Additionally, from time to time, directors, officers and employees of JPMC serve on the board of directors or hold another senior position with a corporation, investment fund manager or other institution which may desire to sell an investment to, acquire an investment from or otherwise engage in a transaction with, JPMS clients. The presence of such persons in such circumstances may require the relevant person to recuse themselves from participating in a transaction or cause JPMS, a corporation, investment fund manager or other institution to determine that it (or its client) is unable to pursue a transaction because of a potential conflict of interest. In such cases, the investment opportunities available to JPMS clients and the ability of such clients to engage in transactions or retain certain investments or assets will be limited. procedures in respect thereof, may restrict or limit a client’s account’s investment activities. In addition, J.P. Morgan from time to time subscribes to or otherwise elects to become subject to investment policies on a firm- wide basis, including policies relating to environmental, social and corporate governance. JPMS may also limit transactions and activities for reputational or other reasons, including (i) when J.P. Morgan provides or may provide advice or services to an entity involved in such activity or transaction; (ii) when J.P. Morgan or a client is or may be engaged in the same or a related activity or transaction to that being considered on behalf of the client account; (iii) when J.P. Morgan or a client account has an interest in an entity involved in such activity or transaction; or (iv) when such activity or transaction on behalf of or in respect of the advisory account could affect J.P. Morgan, JPMPI, their clients or their activities. J.P. Morgan may also become subject to additional restrictions on its business activities that could have an impact on Program clients Accounts’ activities. In addition, JPMPI may restrict its investment decisions and activities on behalf of particular client accounts and not other accounts. J.P. Morgan’s Policies and Regulatory Restrictions Affecting Client Accounts Recommendation or Investments in Securities that the Adviser or Its Related Persons Has a Material Financial Interest As part of a global financial services firm, JPMS will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by J.P. Morgan, J.P. Morgan’s roles in connection with other clients and in the capital markets, J.P. Morgan’s internal policies and/or potential reputational risk. As a result, client accounts managed by JPMS may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by J.P. Morgan. JPMS and its related persons recommend or invest securities on behalf of its clients that JPMS and its related persons also purchase or sell. As a result, positions taken by JPMS and its related persons may be the same as or different from, or made contemporaneously or at different times than, positions taken for clients of JPMS. As these situations involve actual or potential conflicts of interest, JPMS has adopted policies and procedures relating to personal securities transactions, insider trading and other ethical considerations. These policies and procedures are intended to identify and mitigate actual and perceived conflicts of interest with clients and to resolve such conflicts appropriately if they do occur. The policies and procedures contain provisions regarding pre-clearance of employee trading, reporting requirements and supervisory procedures that are designed to address potential conflicts of interest with respect to the activities and relationships of related persons that might interfere or appear to interfere with making decisions in the best interest of clients, including the prevention of front-running. In addition, JPMS has implemented monitoring systems designed to ensure compliance with these policies and procedures. J.P. Morgan’s Proprietary Investments In addition, potential conflicts of interest also exist when J.P. Morgan maintains certain overall investment limitations on positions in securities or other financial instruments due to, among other things, investment restrictions imposed upon J.P. Morgan by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude, JPMS from including particular securities or financial instruments in its portfolios, even if the securities or financial instruments would otherwise meet the investment objectives of such portfolio. For example, there are limits on the aggregate amount of investments by affiliated investors in certain types of securities within a particular industry group that cannot be exceeded without additional regulatory or corporate consent. If such aggregate ownership thresholds are reached, the ability of a client to purchase or dispose of investments, or exercise rights or undertake business transactions, will be restricted. JPMS, J.P. Morgan and any of their directors, partners, officers, agents or employees also buy, sell or trade securities for their own accounts or the proprietary accounts of JPMS and/or J.P. Morgan. JPMS and/or J.P. Morgan, within their discretion, can make different investment decisions and take other actions with respect to their proprietary accounts than those made for client accounts, including the timing or nature of such investment decisions or actions. Further, JPMS is not required to purchase or sell for any client account securities that it, J.P. Morgan and any of their employees, principals or agents may purchase or sell for their own accounts or the proprietary accounts of JPMS or J.P. Morgan. JPMS, J.P. Morgan and their respective directors, officers and employees face a conflict of interest as they will have income or other incentives to favor their own accounts or the proprietary accounts of JPMS or J.P. Morgan. Conflicts of Interest Created by Contemporaneous Trading Potential conflicts of interest may also arise as a result of JPMS’ current policy to seek to manage its clients’ accounts so that the various requirements and liabilities imposed pursuant to Section 16 of the Securities Exchange Act of 1934 (Section 16 and the Exchange Act, respectively) are not triggered. Section 16 applies to, among other things, “beneficial owners” of 10% or more of any security subject to reporting under the Exchange Act. In addition to certain reporting requirements, Section 16 also imposes on such “beneficial owner” a requirement to disgorge of “short-swing” profits derived from the purchase and sale or sale and purchase of the security, executed within a 6-month period. JPMPI may be deemed to be a “beneficial owner” of securities held by its advisory clients. Consequently, and given the potential ownership level of the various accounts and funds managed for its clients, JPMS may limit the amount, or alter the timing, of purchases of securities in order not to trigger the foregoing requirements. As a result, certain contemplated transactions that otherwise would be consummated by JPMS on behalf of its clients will not take place, will be limited in their size, or will be delayed. Furthermore, J.P. Morgan has adopted policies and procedures reasonably designed to ensure compliance with economic and trade sanctions-related obligations applicable to its activities (although such obligations are not necessarily the same obligations that its clients are subject to). Such economic and trade sanctions prohibit, among other things, transactions with and the provision of services to, directly or indirectly, certain countries, territories, entities and individuals. These economic and trade sanctions, and the application by JPMS of its compliance policies and Positions taken by a certain client account may also dilute or otherwise negatively affect the values, prices or investment strategies associated with positions held by a different client account. For example, this can occur when investment decisions for one client are based on research or other information that is also used to support portfolio decisions by JPMS or an affiliate for a different client following the same, similar or different investment strategies or by an affiliate of JPMS in managing its clients’ accounts. When a portfolio decision or strategy is implemented for an Account ahead of, or contemporaneously with, similar portfolio decisions or strategies for JPMS or an affiliate's other client (whether or not the portfolio decisions emanate from the same research analysis or other information), market impact, liquidity constraints or other factors could result in one account being disadvantaged or receiving less favorable 33821_COL 11-05-2025 Page 30 of 32  • investment results than the other Account, and the costs of implementing such portfolio decisions or strategies could be increased. Confidentiality obligations to clients set forth in the J.P. Morgan privacy notices; • Conflicts of interest, which include guidance relating to restrictions on trading on material non-public information (MNPI). In addition, it is perceived as a conflict of interest when the activity in one account closely correlates with the activity in a similar account, such as when a purchase by one account increases the value of the same securities previously purchased by another account, or when a sale in one account lowers the sale price received in a sale by a second account. Furthermore, if JPMS or an affiliate manages accounts that engage in short sales of securities in which other accounts invest, JPMS or an affiliate could be seen as harming the performance of one account for the benefit of the account engaging in short sales if the short sales cause the market value of the securities to fall. Also, certain private funds managed by JPMS or its affiliates hold exclusivity rights to certain investments and therefore, other clients are prohibited from pursuing such investment opportunities. E. Account Errors and Resolutions In general, the personal trading rules under the Code of Ethics require that accounts of JPMS employees and associated persons be maintained with an approved broker and that certain trades in reportable securities for such accounts be precleared and monitored by compliance personnel. The Code of Ethics also prohibits certain types of trading activity, such as short-term and speculative trades. JPMS personnel must obtain approval prior to engaging in all covered security transactions, including those issued in private placements. In addition, JPMS personnel are not permitted to buy or sell securities issued by J.P. Morgan during certain periods throughout the year. Certain Access Persons (defined as persons with access to nonpublic information regarding JPMS’ recommendations to clients, purchases, or sales of securities for client accounts and advised funds) are prohibited from executing personal trades in a security at certain times. In addition, Access Persons are required to disclose household members’ personal security transactions and holdings information. These disclosure obligations and restrictions are designed to mitigate conflicts of interest that arise if Access Persons transact in the same securities as advisory clients. Account errors, trade errors and other operational mistakes occasionally occur in connection with the management of Funds and client Accounts. JPMS has developed policies and procedures that address the identification and correction of such errors and generally require that errors caused by JPMS and affecting a client's account be resolved promptly and fairly. Errors can result from a variety of situations, including portfolio management (e.g., inadvertent violation of investment restrictions) trading, processing or other functions (e.g., miscommunication of information, such as wrong number of shares, wrong price, wrong account, executing the order as a buy rather than a sell and vice versa). Additionally, all JPMS, WMS and JPMPI personnel are subject to the J.P. Morgan firm-wide policies and procedures, including those found in the J.P. Morgan Code of Conduct (the Code of Conduct). The Code of Conduct sets forth restrictions regarding confidential and proprietary information, information barriers, private investments, outside business activities and personal trading. All J.P. Morgan employees, including JPMS personnel, are required to familiarize themselves with, comply with, and attest annually to their compliance with provisions of the Code of Conduct’s terms as a condition of continued employment. Where appropriate, JPMS and its affiliates generally address the conflicts disclosed in this Brochure through policies and procedures. The intent of the policies and procedures is to restore a client account to the appropriate financial position as determined in good faith by the Adviser based on what it considers reasonable in light of all relevant facts and circumstances surrounding the error. JPMS makes its determinations pursuant to its error policies and procedures on a case-by-case basis, in its discretion, based on factors it considers reasonable. Under certain circumstances, JPMS may consider whether it is possible to adequately address an error through cancellation, correction, reallocation of losses and gains or other means. G. Review of Accounts Clients have ongoing reasonable access, during normal business hours, to an IAR or a centralized team of IARs who are available for consultation regarding Program Accounts. IARs are an essential component of the Program and provide clients with nondiscretionary advisory services and Account maintenance support. If a trade error is made in a client’s Account, JPMS will take action to make the Account whole. JPMS corrects trade errors in IRA and ERISA Accounts in the impacted Program Account and uses a firm account to correct all other trade errors in non-retirement Program Accounts. If bonds are erroneously sold from a client’s Account, it is possible that JPMS, the Implementation Manager or the Portfolio Manager will not be able to find the same bonds to buy back for the Account. In that case, JPMS, the Implementation Manager or Portfolio Manager will purchase bonds that it believes are equivalent in quality and yield. If a client requests that any securities be transferred out of an Account or there is a trade error in an Account, JPMS may temporarily suspend trading in the Account until the transfer is complete or the trade error is remediated. During such time, Fees (as defined in this Item 4) will continue to accrue. JPMS contacts clients at least annually to determine whether there have been any changes in the client’s financial situation, investment objectives or investment restrictions that would require changes to the client’s Account. To ensure that the Program and the selected Investment Strategy remain suitable for the client, clients are instructed to promptly notify JPMS or their Advisor(s) of any material changes to their investment objectives and/or financial situation. Clients are solely responsible for notifying JPMS in the event that any information that JPMS maintains about them is inaccurate or becomes inaccurate. F. Code of Ethics As most Program Accounts are managed in a similar manner according to the Model or Investment Strategy selected by the client, JPMS does not review individual trades or individual Program Accounts. As described in this Brochure, JPMS periodically reviews Model composition, Funds available, Model Managers, Portfolio Managers and Investment Strategies available in the Program to ensure that they continue to meet the Program requirements. For Program Accounts that have requested investment restrictions, JPMS periodically monitors the Accounts to ensure compliance with the accepted investment restrictions. JPMS has adopted a Code of Ethics (the Code of Ethics) pursuant to Rule 204A-1 under the Advisers Act. The Code of Ethics is designed to ensure that JPMS and its supervised persons comply with applicable federal securities laws and place the interests of clients first in conducting personal securities transactions. The Code of Ethics imposes certain restrictions on securities transactions in the personal accounts of supervised persons to help avoid or mitigate conflicts of interest, as described more fully below. A copy of the Code of Ethics is available free of charge to any client or prospective client upon request by contacting a client service representative or your IAR. General JPMS, JPMPI, JPMIM, Portfolio Managers and Model Manager personnel who are knowledgeable about the management of client Program Accounts are available for client consultation upon reasonable request. The Code of Ethics contains policies and procedures relating to: • Account holding reports and personal trading, including reporting and pre-clearance requirements for all personnel of JPMS; The information in this Brochure does not include all the specific review features associated with each Model, Fund, Investment Strategy, Model, Model Manager, and Portfolio Manager. Clients are urged to ask questions 33821_COL 11-05-2025 Page 31 of 32  regarding JPMS’ or JPMPI’s review process applicable to a particular Model, Fund Model Manager, Portfolio Manager or Investment Strategy, to read all product-specific disclosures, and to determine whether a particular Fund, Model Manager, Portfolio Manager, Investment Strategy or type of security is suitable for their Account in light of their circumstances, investment objectives and financial situation. Reports to Program Clients Clients receive Account statements from the custodian at least quarterly and also receive quarterly performance reports. Refer to “Trade Confirmations, Statements and Performance Reporting” above. JPMS does not provide tax advice, and discussions with IARs, Account statements and the performance reports should not be construed as tax advice and are not a substitute for careful review of Account statements or tax reporting forms by clients. Performance reviews are not a substitute for regular monthly or quarterly account statements or IRS Forms 1099 and should not be used to calculate the fees or to complete income tax returns. JPMS and its affiliates are entitled to rely on the financial and other information that clients or any third party provides to JPMS. The client is solely responsible for any information that the client provides to JPMS, and JPMS shall not be liable in connection with its use of any information provided by the client or a third party in the periodic review. JPMS and its IARs do not provide tax advice, and nothing in the performance review should be construed as advice concerning any tax matter. Neither JPMS nor any of its supervised persons acts as a Portfolio Manager in the Program. Subject to JPMS’ policies and procedures and applicable law, the periodic written performance review provided to Program clients can include information about assets in other accounts. By including such assets in the written performance review, JPMS is not undertaking to provide or be responsible for providing any services with respect to those assets. In preparing Account statements and performance reviews, JPMS may use multiple valuation sources that provide different values for a single asset. As a result, the determination of an Account's asset values may differ for different purposes and different statements, reviews and reports. Client Account asset values are available from JPMS upon request. H. Testimonials and Endorsements Program Accounts are offered and sold only through IARs associated with JPMS. In addition to compensating Advisors for their provision of investment advisory services to clients on behalf of JPMS, and/or for their referral or introduction of investors who become advisory clients of JPMS, JPMS has entered into agreements with certain unaffiliated third parties (sometimes also called a “finder,” “referrer” or “promoter”) for their referral of prospective investment advisory clients to JPMS in accordance with the Advisers Act. Under these arrangements, JPMS agrees to pay each finder when a referred prospective client is either referred or becomes an investment advisory client of JPMS. JPMS either pays the finder a flat amount or a specified portion of the fee it receives and retains relating to each such client’s advisory account. In addition to the third-party referral agreements described above, pursuant to an agreement between JPMS and JPMCB, an affiliate, JPMCB can compensate its employees for referring clients to JPMS for various products and services, including the Program and other advisory products and services. Any such payments to JPMCB employees shall not increase the total account fees paid by the client. Financial Information I. JPMS is not aware of any financial condition that is reasonably likely to impair JPMS’ ability to meet its contractual commitments to its clients, nor has JPMS been the subject of a bankruptcy petition at any time during the past 10 years. 33821_COL 11-05-2025 Page 32 of 32 

ITEM 4 — SERVICES, FEES AND COMPENSATION A. Description of Firm and Advisory Services FORM ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE J.P. MORGAN PERSONAL ADVISORS PROGRAM J.P. Morgan Securities LLC November 5, 2025 383 Madison Avenue New York, NY 10179 (800) 392-5749 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 Financial Industry Regulatory Authority (FINRA). JPMS’ investment advisory services include sponsoring a variety of wrap fee programs and providing certain consulting services to defined contribution plan sponsors. You can obtain brochures for the other programs by contacting us at 1-800-392-5749. chase.com/investments JPMS offers investment advisory services through several separate channels. Similar wrap-fee programs that offer the same and similar investment strategies are offered in the different sales channels and at different fee levels with different features. The wrap-fee clients pay for investment advisory services will vary depending on the investment advisory program clients select. This wrap fee disclosure brochure (Brochure) provides information about the qualifications and business practices of JPMS relating to the J.P. Morgan Personal Advisors Program. If you have any questions about the contents of this Brochure, please contact us at 1-800-392-5749. 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. 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 material and/or other updates since the previous Brochure that was filed on December 18, 2024: Item 4 has been updated to clarify disclosure regarding fractional share trading. IAR of JPMS, or at This Brochure provides information about JPMS and the J.P. Morgan Personal Advisors Program (the Personal Advisors Program or the Program), an investment advisory program sponsored by JPMS and is available through an investment advisory representative (IAR). JPMS has retained its affiliate, J.P. Morgan Private Investments Inc. (JPMPI) to act as sub-adviser (Sub-Adviser) and implementation manager for the Program, as discussed in further detail throughout this Brochure. Detailed information about sub-advisory and implementation manager services that JPMPI provides in the Program is contained in a separate ADV brochure, which can be obtained upon request from a JPMS Financial Advisor, who is an employee and the SEC’s website at adviserinfo.sec.gov. Item 6 has been revised to include the risks associated with the use of artificial intelligence and to enhance the disclosure regarding data sources risk, cybersecurity risk and LIBOR discontinuance risk. ITEM 3 — TABLE OF CONTENTS Many of the tools and analytics that are used to support services provided through JPMS advisory programs are also available through JPMS without enrolling in an advisory program and paying a fee. Further, you could purchase these services separately from JPMS. However, while you can obtain similar products and services from JPMS without enrolling in an advisory program, you would not receive the same discretionary or non- discretionary account services offered through the advisory programs, the mutual fund share classes available to you will generally be more expensive, and you would generally not be able to obtain the same combination of financial planning and investment advisory services. The overall cost of purchasing the products and services separately will most likely differ from each advisory program’s advisory fees. Clients should consider the value of these advisory services when making such comparisons. B. Program Description and Services The Personal Advisors Program is a financial planning and discretionary managed account program managed and offered by JPMS. Clients invest in the Program by establishing one or more Program accounts (each, an Account). Clients pay an annualized asset-based advisory fee that covers the financial planning, investment advice, investment management, trade execution, custody and reporting services provided through the Program. The Program offers different service models to clients enrolled in the Program based on asset levels. Clients with less than $250,000 invested in the Program are generally assigned to a team of IARs. Clients with $250,000 or more invested in the Program can elect to work with a dedicated IAR. All Program clients have the ability to call and schedule an appointment with an IAR at any time. Information about fees based on ITEM 2 — MATERIAL CHANGES ............................................................. 1 ITEM 3 — TABLE OF CONTENTS ............................................................. 1 ITEM 4 — SERVICES, FEES AND COMPENSATION .................................. 1 Description of Firm and Advisory Services .................................. 1 A. Program Description and Services .............................................. 1 B. Financial Plan, Investment Proposal and Account Opening ........ 3 C. Trade Confirmations, Statements and Performance Reporting ... 4 D. Proxy Voting, Corporate Actions and Other Legal Matters .......... 5 E. F. Fees and Compensation .............................................................. 5 ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ............. 8 Program Minimum ...................................................................... 8 A. Cash Balances in Program Accounts............................................ 8 B. C. Retirement Accounts ................................................................... 8 ITEM 6 — SUB-ADVISER SELECTION AND EVALUATION ....................... 8 Offsets for Retirement Accounts Holding J.P. Morgan Funds ........ 14 ITEM 7 — CLIENT INFORMATION PROVIDED TO SUB-ADVISER .......... 14 ITEM 8 — CLIENT CONTACT WITH SUB-ADVISER ................................ 14 ITEM 9 — ADDITIONAL INFORMATION ................................................ 14 A. Disciplinary Information ............................................................ 14 Other Financial Industry Activities and Affiliations ................... 16 B. C. Material Relationships with Related Persons and Potential Conflicts of Interest ............................................................................ 16 Code of Ethics ............................................................................ 19 D. Review of Accounts ................................................................... 19 E. Testimonials and Endorsements................................................ 20 F. G. Financial Information ................................................................ 20 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 33816_COL 11-05-2025 Page 1 of 20  assets under management is contained in the “Fees and Compensation” section below. (4) generally rebalancing the Program Account to the allocation in a chosen investment strategy when the asset allocation percentages deviate from established parameters; and (5) conducting tax-loss harvesting for certain taxable Accounts in the Program. JPMS as Program Sponsor has an internal governance committee that seeks to ensure that the Programs offer suitable investment products to clients and that assets in the Programs are managed in a compliant manner consistent with the goals of the Programs and applicable law Tax Harvesting Tax-loss harvesting (Tax Harvesting) is applicable to taxable Accounts in all Investment Strategies as determined at the sole discretion of JPMPI. Clients should contact their IAR for more information about Tax Harvesting. The Program invests client assets in a manner consistent with one of the multi-asset class investment strategies (each, an Investment Strategy) made available by JPMS to clients. In addition to Income, Conservative, Balanced, Growth and Aggressive Growth Investment Strategies (and a U.S.-focused version of each such Investment Strategy), there are Investment Strategies primarily consisting of funds or other investments that integrate environmental, social and governance (ESG) factors into their investment process and/or focus on sustainable themes, such as the Balanced ESG Strategy and Growth ESG Strategy. With certain Investment Strategies, clients have the ability to make elections, such as a municipal fixed income election (for taxable Accounts). Assets within an Investment Strategy are generally invested in different asset classes through one or more open-end mutual funds and exchange-traded funds (ETFs and, collectively with mutual funds, Funds). Tax Harvesting has the ability to reduce taxable income, although it will not eliminate it. JPMPI, as implementation manager, may change its Tax Harvesting parameters, including the manner and frequency of Tax Harvesting, at any time without notice. In certain market conditions, or when portfolio positions have not otherwise experienced capital losses during the relevant tax period, Tax Harvesting opportunities will be limited or may not exist. JPMPI, as implementation manager, will not attempt to harvest every tax loss that occurs in clients’ taxable Account(s). Clients should consider a different investment advisory program if they do not want Tax Harvesting. JPMPI, as sub-adviser to the Personal Advisors Program, is responsible for securities selection (including selecting Funds for investment) and determining portfolio construction. Funds sponsored or managed by unaffiliated third parties (non-J.P. Morgan Funds) as well as Funds sponsored or managed by affiliates of JPMS (J.P. Morgan Funds) will be considered for inclusion in the Program. The affiliates that sponsor or manage J.P. Morgan Funds include JPMPI and J.P. Morgan Investment Management Inc. (JPMIM). A portion of the assets in Program Investment Strategies are expected to be invested in J.P. Morgan Funds. J.P. Morgan has a financial incentive to invest Program assets in J.P. Morgan Funds because it receives more overall fees when it selects J.P. Morgan Funds rather than non-J.P. Morgan Funds. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. important information about each Fund, including For investment objectives, risks, charges and expenses, clients should read each Fund’s prospectus carefully and consider all the information in it before investing. To generate potential tax losses, JPMPI, as the implementation manager, will sell positions that have experienced a capital loss. The proceeds will generally be invested in Funds as determined by JPMPI during the “wash sale” (i.e., 30-day) period. The investment in the Funds is designed to provide market exposure during the wash sale period, but there is no guarantee that the proceeds that are invested in the Funds will perform the same as the original position. The performance of the Funds and the price of such investments may be higher or lower than the original position. Tax Harvesting generally entails a repurchase of the sold security after the wash sale period. For additional information, refer to Item 6 below (“Tax Risks and Risks That Apply to Tax-Aware or Tax-Harvesting and Tax- Managed Strategies”). The Investment Strategy for a particular client is based on the client’s discussion with a J.P. Morgan Personal Advisors (JPMPA) IAR and the client’s investment objective, risk tolerance, time horizon and other information the client provides to JPMS. The Investment Strategies available in the Program are Income, Conservative, Balanced, Balanced ESG, Growth, Growth ESG and Aggressive Growth. For more information about these Investment Strategies and related risks, clients should review JPMPI’s ADV Brochure, which can be obtained upon request from a JPMPA IAR or at the SEC’s website at adviserinfo.sec.gov. In order to comply with principal trade restrictions, orders for the Program are routed for agency execution. In connection with transactions executed for Program Accounts, when permitted by applicable law and JPMS policy, JPMS, acting on behalf of client Accounts, enters into transactions in securities and other instruments with or through JPMC, and causes Accounts to engage in principal transactions. A “principal transaction” occurs if JPMS, acting on behalf of client Accounts, knowingly buys a security from, or sells a security to, JPMS or its affiliate's own account. Fractional Share Trading Fractional share trading allows for the purchase and sale of fractional share positions of equity securities, closed-end funds, ETFs and other eligible securities which reduces tracking error relative to Investment Strategies by allowing Accounts to invest closer to Investment Strategy allocations by not having to round security positions to whole shares. JPMS has delegated certain of its discretionary responsibilities and authority to JPMPI as the Program’s Sub-Adviser. JPMPI, as the sub-adviser, constructs and evaluates the Investment Strategies and selects the Funds available through the Program using due diligence produced by JPMPI. JPMS oversees the selections using an investment policy statement and remains responsible for overseeing JPMPI’s role as Sub-Adviser. It is JPMS’ policy, to the extent practicable, to allocate, within its reasonable discretion, investment opportunities among clients over a period of time on a fair and equitable basis. JPMS and JPMPI (as Sub-Adviser) have full discretionary investment advisory authority, to be exercised in their exclusive judgment and consistent with the Investment Strategy selected by the client, to determine asset allocation, the allocation of assets among Funds; to select, add, remove or replace Funds; and to purchase and sell Funds for Program Accounts. Because fractional share trades cannot be routed to an exchange or other market makers for execution, the fractional share component of an order will need to be combined with shares held in inventory by JPMS to make a whole share in order to be routed for execution. This means that JPMS will be trading alongside fractional share trades to facilitate fractional share trade orders and that fractional share trade orders will be routed for execution in an agency capacity. JPMS will not be trading with these orders as principal. As part of the fractional share trading alongside process, JPMS maintains a facilitation account that holds a small number of shares of eligible securities in inventory for sell orders and keeps cash on hand for buy orders. JPMS adds a fractional share to aggregated buy or sell orders so that the order is rounded up to whole shares, and the additional fractional share is purchased or sold by JPMS. Due to a variety of factors — such as the number of trades executed, allocating fractional shares to multiple JPMS has also retained JPMPI as the implementation manager for Program Accounts. JPMPI, as the implementation manager for the Program, provides portfolio implementation and coordination services to Program Accounts. These services include: (1) managing the Accounts on a discretionary basis by implementing instructions to purchase, hold or sell shares of Funds; (2) continuously monitoring the Account holdings and coordinating the trading activity; (3) implementing specific reasonable restrictions requested by the client that are placed on the client Account; 33816_COL 11-05-2025 Page 2 of 20  clients at one time, and market price volatility — JPMS could accrue a net profit or loss in its fractional share facilitation account. that External Accounts are invested or re-invested in accordance with the proposed optimal asset allocation in your financial plan, and will not consider how External Accounts are invested when developing a client’s Program Investment Strategy. JPMS is under no obligation to continue to utilize fractional share trading in the future and in its discretion, may discontinue fractional share trading at any time. Upon termination of a client Account, fractional share positions will be sold and the proceeds placed in the sweep option selected by the client. Refer to “Cash Allocations and the Sweep Feature” for more detail. Fractional share trades where a “sell” order is submitted and JPMS does not hold any shares will require JPMS to purchase one share in the market before submitting the sell order to be able to round the fractional share up to a whole share before the order can be sent for execution. As such, there could be a delay in execution of such “sell” order while JPMS obtains a share to be able to submit the fractional share trade order. The financial plan includes a proposed asset allocation based on your goals, but it does not provide advice or recommendations regarding specific securities or other investments. If you choose to open a Program Account, your IAR will work with you to develop an “Investment Proposal” that provides a recommendation of one or more Investment Strategies available in the Program and specifies Funds that are included in the Investment Strategy. Other than the assets included in Program Accounts, which are managed on a discretionary basis through the Program, whether and how to implement any asset allocation recommendations provided in your financial plan is your responsibility and is not part of the services provided under the Program. Dividends are paid on fractional share positions. The dividend payable will be an amount proportionate to the fractional interest. Investment Proposal information Corporate Actions and Proxy Voting: Fractional shares participate in both mandatory corporate actions (e.g., stock splits, mergers) as well as voluntary corporate actions (e.g., tender offers). Fractional shares generally do not participate in proxy voting, however unless the Client has retained proxy voting rights fractional shares will be aggregated for proxy voting purposes. For additional information about fractional share trading, please contact your IAR. C. Financial Plan, Investment Proposal and Account Opening Financial Plan An IAR will request your investment objectives, time horizon and risk tolerance for one or more JPMPA Accounts. This is incorporated into an “Investment Proposal,” which will recommend one or more Investment Strategies. If your investment objectives, time horizon and risk tolerance are consistent with those for the goals identified in your financial plan, then the asset allocations for your recommended Investment Strategy and your financial plan will be consistent. If the information differs (for instance, if your investment objectives or risk tolerance for your Account differ from those contained in your financial plan), then the asset allocation for your recommended Investment Strategy will reflect your Client Profile rather than the recommended asset allocation in your financial plan. Annual or Other Updates JPMS’ financial planning process starts with a consultation with an IAR, who will ask you to provide information relating to your personal needs and goals, total wealth, tax jurisdiction, cash flows, projected spending, and willingness and ability to take risk. Your financial plan will include one or more investing goals (such as planning for college expenses or saving for a home or retirement). The plan will provide an analysis of how your assets are currently allocated among assets classes and propose an optimal asset allocation based on your goals. Each year we will invite you to schedule an appointment with an IAR to update your financial plan and review the investment objectives for your Program Account(s). JPMS will not monitor or update your financial plan or change your recommended Investment Strategy without first meeting with you to discuss any changes to your financial situation or investment objectives. Therefore, it is important that you schedule an appointment with an IAR whenever your financial situation or investment objectives change, but at least once each year, to ensure that your current financial situation and investment objectives are taken into account. Electronic Communications Your financial plan will provide projections to help you assess your ability to achieve your identified financial goals. The projections provide a snapshot of your current financial position at a point in time and are intended to help you focus your financial resources and goals. Although we encourage you to consult with your JPMPA IAR on an annual basis to review your financial plan, JPMPA will not update your financial plan based on changes to your personal or financial circumstances without meeting with you to review your plan. We do not provide ongoing or continuous monitoring of your progress toward a planning or investment goal. As a condition to receiving services through JPMPA, you must be willing to accept the terms of a global electronic consent, which requires agreeing to electronic delivery of Program documents and communications. In addition, as part of opening a Program Account, clients are required to complete an Account application and enter into an investment advisory agreement and other Account agreements (collectively, the Client Agreement). The Client Agreement along with other disclosures and notices will be delivered to clients in electronic format, including through email or other electronic means. JPMS will not send paper versions of documents to clients as part of the Program unless required by applicable law or in JPMS’ sole discretion. In addition, JPMS may require that some or all of the Account opening processes be completed electronically and may provide some or all Account-related documentation online. To cover a broad range of outcomes, JPMS’ projections will utilize “Monte Carlo” simulations or scenarios to measure your likelihood of success of reaching your goals. The projections for your goals do not attempt to predict or portray the future performance of any securities held in Accounts supporting your goals. The projections are based on forecasted asset class returns, as well as inflation rates, developed by J.P. Morgan. The projections are hypothetical in nature, are based on statistical modeling of current and historical data, do not reflect actual investment results, and are not a guarantee of future results or a guarantee of the success rate of the simulated outcomes. Although the projections seek to reasonably project the likelihood of reaching your goals, it is likely that such projections will not correlate well to other assets you hold in any accounts that are not invested with us through Program Accounts. Accordingly, your actual investment results may vary significantly from our projections. Program clients must provide JPMS with a valid email address and are required to notify JPMS immediately in the event their email address changes or becomes inaccessible by visiting chase.com or by contacting JPMS at 1-800-392-5749. Important client notices, including new or amended agreements or documents, will be sent by email; therefore, it is important that clients maintain an accurate email address at all times. If a client fails to provide or maintain accurate contact information, including an email address, JPMS reserves the right to terminate that client’s participation in the Program. JPMS will attempt to contact clients by other means when it determines that a client’s email address is invalid. Clients must also own or have access to an electronic device with the necessary Any forecasts using accounts held outside of J.P. Morgan at an unaffiliated, third-party firm (External Accounts and each, an External Account) are calculated based solely on the information you provide to JPMS for any such External Accounts. You may provide JPMS with such information manually or by using JPMS’ asset aggregation service. JPMS will not independently verify or update this information, will not have any responsibility to ensure 33816_COL 11-05-2025 Page 3 of 20  initial and continued condition of hardware and software as an participating in the Program. Refer to the Online Service E-Sign Disclosure and Consent for additional terms and conditions regarding electronic delivery of Program communications. placed away from JPMS. Depending on the type of security involved, liquidation may result in redemption charges and taxable gains or losses. Clients should review the potential tax consequences of these liquidations with their tax professional before funding their Program Account with securities. JPMS and its affiliates do not provide tax advice. If non-U.S. denominated securities are sold, the client will incur currency conversion charges. Client Agreement When liquidating securities for purposes of establishing a client’s Program Account, JPMS will be acting as your broker, not your investment adviser. Liquidations will be effected promptly after receipt into the Account at the then prevailing market prices, subject to market conditions and applicable JPMS policies. If a particular security cannot be liquidated or is not eligible for the Program, it will not be used to fund an Account and your IAR will work with you. Rebalancing Program Accounts As a condition to receiving investment management services through the Program, clients are required to enter into a Program Client Agreement. The Client Agreement authorizes JPMS to act as the client’s investment adviser, with investment discretion and trading authority, and authorizes JPMS to perform its services directly, or through or by delegating performance to, affiliated or unaffiliated service providers, as JPMS may from time to time designate. The Client Agreement incorporates a separate brokerage Account agreement that clients must consent to in order to enroll in the Program. Restrictions on Management of Accounts Rebalancing has tax implications for most clients, other than those with tax- advantaged Accounts. Program Accounts will be rebalanced if the percentage variance at the asset class level exceeds a threshold amount that has been established as effective for rebalancing to the Investment Strategy. Clients can request reasonable investment restrictions on the management of their Program Account assets by designating particular Funds that should not be purchased for an Account, subject to acceptance as reasonable by JPMPI, in its sole discretion. Note that (i) reasonable investment restrictions will not apply to the underlying portfolio of any Fund that is held or purchased in an Account, and (ii) investment restriction requests can only be made for specific Funds and not categories of Funds or securities (e.g., related to a sector or industry, such as weapons or tobacco). JPMPI will periodically rebalance Program Accounts to the allocation in the chosen Investment Strategy when the asset allocation percentages deviate from established parameters. To rebalance an Account, shares of Funds that are underweight or overweight compared to their asset class percentages in the Investment Strategy will be bought or sold, as applicable, until the Account holdings are consistent with the Investment Strategy. Over time, the Funds in the Account will appreciate (or depreciate) in value at different rates. Without rebalancing, the change in the percentages of each asset class held will change the level of risk from the risk level that is associated with the original allocations in the selected Investment Strategy. Changes in the sale of Fund shares may generate taxable gains or losses in a client Account. Any restrictions a client imposes on the management of the Account can limit the ability to make investments or take advantage of opportunities and can cause the Account to perform differently than similar unrestricted Accounts. Neither JPMS nor the IAR are required to accept investment restrictions that they deem unreasonable and may decline an Account when they deem any client requested restriction unreasonable. Trade Execution If JPMPI accepts a restriction as reasonable, JPMPI has the discretion to invest the portion of the client Account that would have been invested, or was previously invested, in the restricted security in the other securities in the Account (on a pro rata basis), to select a substitute security or to hold those assets in cash. Substitute Funds are likely to have fees or expenses that are higher than the Funds normally used in the Program. In the event that a restriction request for a Fund that is currently held in a client’s Program Account is accepted, the Fund will be sold and a client may experience tax consequences. Implementation of Investment Strategy Clients direct brokerage to JPMS. JPMS can designate another broker or dealer if it believes the other broker or dealer will provide better execution than JPMS. Although JPMS has discretion to select brokers or dealers other than the sponsor or its affiliates, JPMS generally places such trades through JPMS because the Advisory Fee (defined below), paid by each client Account, only covers execution costs on trades executed through JPMS or its affiliates. Execution costs include fees we pay to exchanges and/or regulatory agencies on certain transactions. Certain securities included in portfolios can be less liquid or are traded infrequently. To fulfill its duty to seek best execution of transactions for client Accounts, JPMS can select broker-dealers other than JPMS or its affiliates to affect a trade for a client Account, and any execution costs charged by non-JPMS broker-dealers will be paid by the client Account. After JPMS opens a Program Account for the client, JPMPI will implement the selected Investment Strategy taking into account any reasonable investment restrictions a client has placed on management of the Account, as accepted by JPMS. JPMPI manages client Accounts in the Program in accordance with each client’s specific investment guidelines, objectives and any reasonable restrictions on investing in specific securities that the client provides to JPMS and JPMS has accepted in writing. Funding Program Accounts JPMS’ primary objective in broker-dealer selection is to comply with its duty to seek best execution of orders for clients. Best execution does not necessarily mean the lowest commission or price, but instead involves consideration of a number of factors. In evaluating whether another broker or dealer will provide better execution, JPMS will consider the full range and quality of a broker’s or dealer’s services including, among other things, execution capability, commission rate, financial responsibility, market making capabilities and responsiveness. Custodian Cash or securities can be used to fund Program Accounts. Investment management will begin after JPMS has accepted the Account into the Program. Account acceptance may be delayed or rejected if the Account is overfunded or underfunded relative to the amount stated in the Investment Proposal. JPMS, in its capacity as an SEC-registered broker-dealer, provides clearing and trade execution services for and serves as the custodian for Program Account assets. JPMS is a “qualified custodian” as defined in Rule 206(4)- 2 under the Investment Advisers Act of 1940, as amended (the Advisers Act). D. Trade Confirmations, Statements and Performance Reporting Clients will receive trade confirmations of all transactions unless they waive receipt of individual confirmations and instead receive a periodic statement Clients funding Program Accounts with securities direct JPMS to liquidate the securities on behalf of the client and allocate the proceeds in accordance with the Investment Strategy selected in the Investment Proposal. JPMS, on a best-efforts basis, will sell a portion or all of any securities that are not consistent with the Investment Strategy stated in the Investment Proposal. Neither JPMS nor JPMPI will advise clients regarding the liquidation of these securities. Liquidation will be done free of commission charges or spread on fixed income trades unless the trade is 33816_COL 11-05-2025 Page 4 of 20  client’s Account or the issuers thereof. Neither JPMS nor the Sub-Adviser is obligated to render any advice or take any action on a client’s behalf with respect to securities or other property held in the client’s Account, or the issuers thereof, which become the subject of any legal proceedings, including, without limitation, bankruptcies and shareholder litigation, to which any securities or other investments held or previously held in the Account, or the issuers thereof, become subject. In addition, neither JPMS nor the Sub-Adviser is obligated to initiate or pursue any legal proceedings, including, without limitation, shareholder litigation, on behalf of a client’s Account, including, with respect to transactions, securities or other investments held or previously held in the client’s Account, or the issuers thereof. F. Fees and Compensation of all transactions that will contain the information required to be in a confirmation. Clients can elect to receive a periodic statement in lieu of individual confirmations and can later choose to receive from JPMS, at no additional cost, transaction confirmations for any prior transactions effected during the period in which the client previously elected not to receive separate transaction confirmations. Clients will not pay a different fee based upon this election and can rescind this election at any time upon written notice to JPMS. Clients will receive Program Account statements from the custodian of the Programs at least quarterly (monthly for months when there is activity in their Account). Clients generally will also receive quarterly performance reports containing general market commentary and analysis, charts and graphs detailing the quarterly performance of the Program Account versus relevant industry benchmarks and indices for Program Accounts during the quarter. Wrap Fee E. Proxy Voting, Corporate Actions and Other Legal Matters Clients pay an annual asset-based Account fee for the Program (Advisory Fee) to JPMS, pursuant to the applicable fee schedule and subject to any applicable discounts or adjustments. The following fee schedule became applicable to JPMPA Accounts on June 7, 2024: Account Assets 1 Annual Fee0F $0–$249,999.99 0.60% Neither JPMS nor JPMPI will vote proxies (or give advice about how to vote proxies) relating to securities and other property currently or formerly held in a client’s Account. JPMS and its affiliates will not be responsible or liable for: (1) failing to notify a client of proxies; or (2) failing to send to the Proxy Service (defined below) or a client, as applicable, proxy materials or annual reports where JPMS or its affiliates have not received proxies or related shareholder communications on a timely basis or at all. $250,000 or greater 0.50% Clients who maintained Account assets of $1,000,000 or greater as of May 31, 2024 will continue to pay their previously existing Account fee of 0.40% until further notice as determined by JPMS. As it relates to those clients who continue to pay their previously existing Account fee of .40%, eligibility shall be reviewed on an annual basis as determined by Account assets under management within the Program. The Advisory Fee will be computed and payable monthly in arrears based upon the market value of all assets held in the Program Account (including cash) on the last business day of the prior month or portion thereof, as determined by JPMS. Advisory Fees for partial billing periods upon the inception or termination of a Program Account will be prorated. The Advisory Fee will be reflected on the Account statement issued by the custodian for the Account. The Advisory Fee is a single (or “wrap” or “bundled”) annualized asset- based fee that covers all financial planning, investment advisory, portfolio management, administrative, custodial and brokerage services provided by JPMS and/or the Sub-Adviser. Each client has the right to vote and is solely responsible for voting proxies for any securities and other property in the client’s Account. In the Program, clients can appoint an independent services provider designated by JPMS for purposes of voting proxies (Proxy Service) as the client’s agent and attorney-in-fact, and clients can authorize the Proxy Service, in its discretion, to vote proxies for any securities and other property in the client’s Account in accordance with the Proxy Service’s proxy voting guidelines in effect from time to time (or other guidelines that the Proxy Service has been instructed to use for particular Investment Strategies), copies of which are available on request. The Proxy Service is currently Institutional Shareholder Services Inc. (ISS). Information relating to ISS services is available on the ISS website at issgovernance.com. The ISS ADV brochure is available at the SEC’s website at adviserinfo.sec.gov. The Proxy Service’s role as the agent of clients applies only to proxies that the Proxy Service generally votes and does not apply to proxies with respect to which the Proxy Service declines to vote. A client who appoints the Proxy Service will not receive proxy materials or annual reports relating to securities and other property for which the Proxy Service has accepted responsibility for voting related proxies. In limited circumstances, the Proxy Service will not vote proxies. A client can revoke its appointment of the Proxy Service upon written notice to JPMS at J.P. Morgan Securities LLC, Attn: Proxy Voting Opt Out, Mail Code: IL1-0291, PO Box 1762, Chicago, IL 60690. If a client revokes their appointment of the Proxy Service, the client will receive all proxy materials and annual reports related to securities and other property in the client’s Account, and they will be responsible for voting such proxies directly or instructing any custodian that holds such securities and other property. JPMS can, in its discretion, change the Proxy Service. JPMS will not be deemed to have or exercise proxy voting responsibility or authority by virtue of any authority to hire or change the Proxy Service. The Advisory Fee does not cover any (i) brokerage commissions or other charges resulting from transactions not effected through JPMS or its affiliates; (ii) “mark-ups,” “markdowns” and “dealer spreads” that we or other broker-dealers may receive when acting as principal in certain transactions; (iii) certain costs or charges imposed by third parties, including odd-lot differentials, margin interest, transfer taxes, exchange fees, and other fees or taxes required by law; (iv) any Account establishment, maintenance, documentation and termination fees for retirement Accounts; (v) the cost of investment manager fees and other expenses charged by Funds; or (vi) any pass-through or other fees associated with investment in American Depositary Receipts (ADRs). No Minimum Fee In the Program, JPMPI will receive and respond to corporate actions with respect to securities in a client’s Account, such as: any conversion option; execution of waivers; consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. Client Right and Responsibility to Take Action No minimum fee requirement is applied to Program Accounts. When applicable, Program Accounts will be charged the appropriate fee percentage for the asset value in the Program Account or, if applicable, for the value of assets in related Program Accounts that have been combined for Advisory Fee calculation purposes. If the Account has at any time qualified for a particular fee rate based on the market value of the Account, the same fee rate shall apply so long as the market value of the Account is no lower than 10% below the minimum asset size required for the Each client has the right and responsibility to take any actions with respect to any legal proceedings, including, without limitation, bankruptcies and shareholder litigation, and the right to initiate or pursue any legal proceedings, including, without limitation, shareholder litigation, including with respect to transactions, securities or other investments held in the 1 The same fee is applied to the entire Account (i.e., is not a “blended” fee) for Account assets over $249,999.99. 33816_COL 11-05-2025 Page 5 of 20  Other Fees and Expenses applicable fee rate. If the market value of the Account falls below 10% of the minimum asset size required for the current fee rate, the Advisory Fee rate will be assessed using the applicable fee rate reflected in the fee schedule. Method of Payment indirect Fund Once an Advisory Fee is charged, unless the client has elected to pay the Advisory Fee from a related JPMS account, if there is sufficient cash in the Deposit Account, as defined below, or sweep fund to pay the entire amount, the Advisory Fee percentage for the Program Account value will be paid out of the Deposit Account or sweep fund within the Program Account. If the Deposit Account or sweep fund does not have sufficient funds to pay the Advisory Fee in its entirety, shares of the most overweight Fund(s) will be sold to pay the entire Advisory Fee rather than paying any of the Advisory Fee from the Deposit Account or sweep fund. This could result in the client incurring a tax liability. If due to withdrawals, payment of fees, or otherwise, the value of the Deposit Account or sweep fund would fall to zero or below, sufficient shares in the Fund(s) currently most overweight in the Investment Strategy based on actual dollar value will be sold to clear the debit and replenish the Deposit Account or sweep fund to its current target amount. Reimbursement to JPMPI as the Sub-Adviser Funds pay fees and expenses that are ultimately borne by clients (including, but not limited to, brokerage costs and management, administration and custody fees). The Advisory Fee does not include various additional fees that can be incurred within a client’s Program Account, including, but not limited to, Fund fees and expenses, transfer taxes, electronic fund and wire fees, IRA and retirement plan Account fees, margin interest. ADR-related fees, or any other fees that would reasonably be assessed to a brokerage Account. If these fees are for services performed by JPMS or their affiliates, JPMS or an affiliate will receive all or a portion of the revenue from the fee. Additionally, Funds held in a Program Account have annual investment advisory expenses, so clients actually incur two levels of investment management fees: investment advisory fees to the investment adviser of each Fund and direct Program Advisory Fees to JPMS. These Fund fees and expenses are in addition to any fees paid to JPMS as the Program sponsor. (Refer to “Offset of Certain Fees to IRAs and Certain Other Retirement Accounts” below to understand the impact of Fund fees and expenses on retirement Accounts.) Clients can review the applicable prospectuses for Funds in the Program for additional information about these fees and expenses. JPMS and its affiliates collectively receive greater revenue if J.P. Morgan Funds are included in the Program, and therefore, JPMS and its affiliates have a conflict of interest in including J.P. Morgan Funds in the Program. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. JPMS reimburses the Sub-Adviser for its costs for providing investment services, including certain investment advisory, portfolio management, research and implementation services, as applicable. Waivers, Reductions and Negotiation of Fees In its discretion, JPMS can negotiate, reduce or completely waive the Advisory Fee for any client or group of clients, including in connection with promotional efforts. JPMS does not give that discretion to IARs. JPMS’ promotional efforts are subject to change, and JPMS reserves the right to offer different promotions simultaneously. Not all clients will have access to the same promotions, so it is possible that similarly situated clients will pay a different Advisory Fee. Refer to the terms associated with such promotions for details regarding how they affect the fees and expenses of the Program and the length of any such waiver or fee reduction. From time to time, the Advisory Fee can be increased. JPMS will provide clients with advance notice prior to increasing the Advisory Fee. The Advisory Fee does not cover brokerage commissions or other charges resulting from transactions not effected through JPMS or its affiliates. In general, JPMS and JPMPI place orders in fixed-income or debt securities with broker-dealers other than JPMS. For these trades, the client will incur a brokerage commission, mark-up or mark-down charged by the other broker-dealer that is not covered by the Advisory Fee. JPMS or JPMPI also can choose to place orders in equities and other types of securities with broker-dealers other than JPMS, in which event the client will incur a brokerage commission that is not covered by the Advisory Fee. When JPMS or JPMPI place orders with broker-dealers other than JPMS, the trade confirmation issued by JPMS with the details of the trade shows a price for the traded security that is inclusive (i.e., net) of the commission, mark-up or mark-down paid by the client to the other broker-dealer, but it does not break out or otherwise show the amount of the commission, mark-up or mark-down separately. For more information on trades away from the Firm, refer to the Trading Practices Disclosures for Wrap Fee Programs available at chase.com/managed-account-disclosures. Share Classes Available in Program Investment Strategies Program Accounts under the same tax identification number are automatically linked in a Relationship Pricing Group for Advisory Fee calculations. JPMS will not link Program Accounts for Relationship Pricing Group purposes in any other way. When the combined assets in the linked Accounts are sufficient to reach the next Advisory Fee breakpoint, the client will benefit from a lower overall fee. The combined Advisory Fee is then divided ratably and assessed over all of the related Program Accounts. All linked Accounts within the same Relationship Pricing Group will have the same Advisory Fee rate applied, subject to applicable discounts. Accounts that are not enrolled in the Program will not be included in a Relationship Pricing Group. JPMS charges fees that it believes are reasonable in relation to the scope of services and nature of the investment advice provided, but these fees are not always the lowest available from other firms and/or our affiliates. The Advisory Fee can be more or less than the cost of paying for investment advice, trade execution, custody and reporting services separately, depending on the cost of these services if provided separately and the level of trading activity in the client’s Account. Mutual funds typically offer different ways to buy shares with different share classes that may assess different fees and expenses. JPMS strives to make available the most appropriate share class on the platform for each Fund, with the goal of generally obtaining the lowest cost share class. However, for certain Funds, the share classes with the lowest fee structures are not available in the Program (e.g., (1) the Fund family restricts access to these share classes or (2) JPMS does not have an agreement with the Fund to distribute the share class in the Program). Clients should be aware that the share class of a Fund available through the Program may differ from the share class available to similar accounts managed by or held at JPMS or its affiliates and that certain lower cost Fund share classes may be available outside of the Program. Clients should contact their IAR(s) for information about any limitations on share classes available through the Program. JPMS, through its brokerage accounts, has other arrangements with Fund companies that are described in the relevant brokerage documents. JPMS and its affiliates receive fees or other forms of compensation from the Funds (including money market funds) or their affiliates. JPMS believes that this conflict is addressed in the following ways: Because the Advisory Fee is charged on all assets in the Account, in a low interest rate environment, a client can earn less interest on assets held in the Account as cash or cash alternatives, such as money market funds, than the amount of the Advisory Fee the client is paying JPMS with respect to such assets, and therefore, the client’s net yield with respect to such assets can be negative. • 12b-1 distribution fees: JPMS receives fees from certain Funds pursuant to Rule 12b-1 under the Investment Company Act of 1940 (Investment Company Act) (12b-1 Distribution Fees). Rule 12b-1 33816_COL 11-05-2025 Page 6 of 20  allows Funds to use Fund assets to pay the costs of marketing and distribution of the Fund’s shares. If JPMS receives 12b-1 Distribution Fees, it will rebate these fees to the client. insurance, subject to applicable limits, terms and conditions, but are not protected by the Securities Investor Protection Corporation. JPMS does not review or monitor FDIC insurance limits for clients. Clients are responsible for monitoring the total amount of deposits that they have with JPMCB to determine the extent of FDIC deposit insurance coverage available to them on their deposits. The JPMorgan Chase Deposit Account Disclosure provides further information about the Deposit Account, including the limits, terms and conditions of FDIC insurance coverage. The interest rate on the Deposit Account will vary based on business and economic conditions and is reset periodically at JPMCB’s sole discretion. The interest rate on the Deposit Account may be higher or lower than yields on other available cash alternatives (e.g., money market mutual funds). From time to time, JPMS or the Sub-Adviser may decide that it is in the best interest of clients to maintain a certain percentage of assets in cash or cash alternatives, especially when markets are volatile. However, because the Advisory Fee is charged on the value of all assets in the Account (including cash and cash alternatives), in a low interest rate environment, the net investment return on cash and cash alternatives, including the Deposit Account, will be negative. The current rates and yields for available cash options for Program Accounts, including the Deposit Account, can be found online at chase.com/SweepYields. These rates and yields change regularly, so it is prudent to check this website on at least a quarterly basis. • Other fees: JPMS enters into agreements with the Funds, their investment managers, distributors, principal underwriters, shareholder servicing agents and/or other affiliates of the Funds (Service Providers). The Funds or their Service Providers pay J.P. Morgan fees for providing certain administrative services, which include maintaining and updating separate records for each client, preparing and delivering client statements, tax reporting, proxy voting and solicitation, processing purchase and redemption orders, processing dividends, distributing prospectuses and other Fund reports, and responding to client inquiries. These fees for these services are typically called “shareholder servicing fees” when paid for by the Fund; however, these fees can be referred to as “revenue sharing” when they are paid by the Fund Service Provider from its own resources (together referred to as Servicing Fees). As of December 31, 2024, the Servicing Fees that JPMS received for non- money market funds were up to 25 basis points annually of the Fund assets, or a rate of up to $20 per year per Fund position; however, these amounts can change. The receipt by JPMS of these fees creates a conflict of interest in the selection of Funds for Accounts because the fees are different among Funds. Similarly, JPMS has a conflict to recommend mutual funds that pay Servicing Fees instead of ETFs or other securities or products that do not pay any Servicing Fee. The portfolio managers or IARs who are responsible for recommending investments for Program Accounts do not receive any direct financial benefit from the Servicing Fees. To that extent, such portfolio managers or IARs are incentivized to invest in or recommend securities they believe will increase the value of the Account. JPMS does not retain any portion of those fees for retirement Accounts. When evaluating the fees for, and cost of, a Program, clients should consider the Servicing Fees that JPMS receives in addition to the investment advisory fees. Clients can also request a Fund prospectus for additional information regarding Fund fees. Although there is no charge to clients with respect to the Deposit Account, JPMCB benefits from the Deposit Account because, through the Deposit Account, JPMCB receives a stable, cost-effective source of funding. JPMCB uses client deposits in the Deposit Account to fund current and new businesses, including lending activities and investments. The profitability on such lending activities and investments is generally measured by the difference, or “spread,” between the interest rate paid on the deposits and other costs associated with the Deposit Account paid by JPMCB and the interest rate and other income earned by JPMCB on the loans and investments made with the deposits. The income that JPMCB earns through its lending and investing activities is usually significantly greater than the interest earned by clients through the Deposit Account. It is typically also greater than the fee earned by all J.P. Morgan entities from managing and distributing money market mutual funds available to Program clients. Additionally, JPMCB has agreed to pay JPMS a monthly flat fee for each Account that uses the Deposit Account; however, JPMS is currently waiving receipt of this fee. Therefore, JPMS and JPMCB have a conflict of interest in offering or utilizing the Deposit Account and in making it the default “sweep” option. JPMS believes that the conflict is addressed through: • The fact that IARs do not receive any additional compensation for assets held in the Deposit Account as opposed to another cash alternative; • Online disclosure of the available cash options and yields at Once a particular share class is made available for a particular Fund in the Program, only that share class can be purchased for that Fund. Mutual funds will be purchased in the Account at net asset value (no-load or load- waived) and ETFs at their market price. JPMS periodically reviews the share classes offered by Funds in the Program but also relies on the Fund families to inform JPMS when and if these share classes will be made available. If JPMS identifies and makes available a class of shares for a Fund more appropriate than the class of shares previously made available for the Fund, to the extent allowed, JPMS will convert client shares of the Fund to that more appropriate share class of the same Fund. Operational and other considerations can affect the timing of the conversion of shares and can cause the timing or implementation of such conversions to differ between clients. chase.com/SweepYields; • The client’s ability to affirmatively select another available “sweep” option and to change the “sweep” option selection to an available alternative at any time; • The JPMorgan Chase Deposit Account Disclosure provided to the client; and Some of the Fund share classes available through the Program are not necessarily available to clients outside of the Program. To the extent an Account is terminated, clients may not be eligible to continue to hold or purchase certain share classes outside of the Program and/or outside the firm. Cash Allocations and the Sweep Feature • The client’s ability to obtain the prospectus for each money market mutual fund that is an available alternative to the Deposit Account. Offset of Certain Fees to IRAs and Certain Other Retirement Accounts Clients in the Program authorize JPMS, to the extent permitted by applicable law, to invest (i.e., “sweep”) available cash balances in the JPMorgan Chase Deposit Account (the Deposit Account) or one or more money market mutual funds that are managed by affiliates of JPMS. The Deposit Account is the default “sweep” option for Program clients who do not select an available “sweep” alternative or if the sweep selected is no longer available. Cash “swept” or allocated to the Deposit Account is remitted for deposit by JPMS, acting as the client’s agent, into a demand deposit account maintained at JPMorgan Chase Bank, N.A. (JPMCB). Balances in the Deposit Account are covered by Federal Deposit Insurance Corporation (FDIC) If a Program Account owned by an IRA, or other client that is a qualified retirement account subject to the prohibited transaction provisions of Section 4975 of the Internal Revenue Code, as amended (IRC), holds any J.P. Morgan Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with Program Account assets will be offset against the Advisory Fee. The offset amount will be automatically applied against the Advisory Fee charged for the period and will appear as a separate line item on the client’s Program Account statement. This offset does not apply to Account investments in non–J.P. Morgan Funds. In addition, for those J.P. Morgan Funds that utilize unaffiliated investment 33816_COL 11-05-2025 Page 7 of 20  B. Cash Balances in Program Accounts sub-advisers for all or a portion of the Fund portfolio management, the amount of the Fund advisory fees paid to unaffiliated investment sub- advisers is not offset to the Advisory Fee. IAR Compensation A portion of Program Accounts will be held in cash, cash equivalents or money market funds as part of the overall Investment Strategy for the Account. Cash and cash equivalents, including money market funds, are subject to the Advisory Fee. For additional information, refer to “Cash Allocations and the Sweep Feature” in Item 4. C. Retirement Accounts The Program is recommended to clients by IARs associated with JPMS. IARs and certain other JPMS supervised persons are eligible to receive variable compensation based on discretionary and nondiscretionary factors, including the number of qualified clients who set up consultations and/or invest in the Program. This variable compensation structure creates a financial incentive for such supervised persons to recommend the Program over other advisory programs and brokerage services offered by JPMS and its affiliates. JPMS maintains and enforces policies reasonably designed to identify and disclose and minimize or eliminate these conflicts of interest. Neither the JPMS supervised persons nor the IARs who deliver advice to for or on the basis of any Program clients are compensated recommendation or sales of specific securities. Margin Debit Balances For Program Accounts established for retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA) and for individual retirement accounts (IRAs) (collectively, retirement Accounts), when providing services under the Program, JPMS is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the IRC with respect to the assets of the retirement Accounts invested in the Program. Additionally, for retirement Accounts that invest in the Program with JPMPI as Sub-Adviser, JPMPI is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the IRC with respect to the assets that it manages in the Program. Retirement Accounts can be restricted from investing in Funds that have a certain relationship with J.P. Morgan. As a result, performance of such retirement Accounts would differ from non-retirement Accounts invested in the same Investment Strategy without such restrictions. ITEM 6 — SUB-ADVISER SELECTION AND EVALUATION Methods of Analysis, Investment Strategies and Risk of Loss Margin debit balances held by a client cannot be held in a Program Account. This is significant because, for purposes of the calculation of the Advisory Fee, the net market value of the assets on which the fee is based will generally not be reduced by the amount of any margin debit balances held by the client in an account outside of the Program, even if some or all of the proceeds of the loan represented by the margin debit balances are held in the client’s Program Account, and even if some or all of the assets in the client’s Program Account are used to collateralize or secure the loan represented by the margin balances. JPMS has a financial incentive for the client to incur margin debt to buy securities in a Program Account because: (1) the client will be required to pay JPMS or its affiliates interest and fees on the debt; and (2) the net market value of the Program Account will be increased by the value of the additional securities purchased with the margin loan (and will not be offset by the amount of the margin debit held by the client in any account outside of the Program), resulting in a higher fee. In addition, any interest and fees paid by the client in connection with any debit balances held outside the Program Account will not be taken into account in the computation of the net equity or performance of the client’s Program Account as reflected in Account statements, performance reports or otherwise. ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Set forth below is a general description of the primary methods of analysis that the Sub-Adviser utilizes for the Program. This description is not intended to serve as Fund or Account guidelines. This description is qualified in its entirety by the information included in any applicable Fund’s prospectus or other relevant offering documentation and the Sub-Adviser’s Form ADV Part 2A disclosure brochure. JPMS, the Sub-Adviser and the Manager Solutions Team (defined below) are not responsible for the performance of any Fund or its compliance with its prospectus, disclosures, laws or regulations or for other matters within the Fund and its respective adviser’s control. Each Fund’s adviser is solely responsible for the management of the Fund. JPMS, the Sub-Adviser and the Manager Solutions Team cannot ensure that a given Investment Strategy’s investment objective will be attained. Sub-Adviser’s Discretionary Investment Process Clients generally include individuals investing through taxable Accounts and retirement Accounts with a U.S. address. Clients whose Account address becomes a non-U.S. address will generally have their Account terminated from the Program. JPMPI is responsible for determining asset allocation, selecting and monitoring Funds used for Investment Strategies and for determining portfolio construction and evaluating Investment Strategies on an ongoing basis subject to the oversight of, and pursuant to, the investment policy statement approved by JPMS. The Program is not intended for investors who seek to maintain control over trading in their Account, who have a short-term time horizon (or expect ongoing and significant withdrawals), or who expect or desire to maintain consistently high levels of cash or money market funds. A. Program Minimum The Sub-Adviser’s approach is generally comparable to the approach to asset allocation, Fund and manager selection, and portfolio construction taken by the Wealth Management division of J.P. Morgan Asset & Wealth Management for Wealth Management’s Private Bank (PB) discretionary Accounts. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” below for important information on the use of J.P. Morgan Funds. Asset Allocation Process Participation in the Program generally requires an initial minimum investment of $25,000. Clients can open and maintain multiple Program Accounts, but each Account requires a $10,000 initial minimum investment. JPMS may, in its discretion, waive or reduce the minimum for certain clients from time to time. If Program or Account assets fall below the initial minimums, JPMS can terminate Program participation and close Accounts at its discretion. The investment, sale or withdrawal of funds or securities from Program Accounts will be effected as soon as practicable subject to market conditions and other factors. Under normal market conditions, it can take 2-4 business days to process the investment (whether initial investments or additions), sale or withdrawal of funds in Program Accounts; however, timeframes can be longer due to market conditions and other factors. JPMPI is responsible for establishing and updating the overall strategic asset allocations for the Investment Strategies. Asset allocations are based on the firm’s long-term capital market assumptions as well as correlation between asset classes. Each Investment Strategy’s asset allocation mix is selected to have the appropriate level of risk and return for such Investment Strategy. This process includes several internal forums. These asset allocations generally are the overall basis for the process described below. The JPMPI personnel who perform these functions are shared with JPMCB, an affiliate of JPMS and the Sub-Adviser, and perform substantially similar services for other clients. The Sub-Adviser periodically reviews the Program composition, asset allocation and performance of the Investment Strategies with JPMS. 33816_COL 11-05-2025 Page 8 of 20  Research Process circumstances where it would not be able to invest all desired client assets in a particular non-J.P. Morgan Fund due to capacity limitations as described under “Research Process” above. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. Portfolio Implementation JPMPI provides portfolio implementation services for each individual client’s Program Account. Ongoing Review of Approved Funds and Investment Strategies Another internal governance committee is responsible for the ongoing monitoring and oversight of Funds as approved and available for the Program. From time to time, this internal governance committee may place them on probation or terminate them as part of its ongoing monitoring and oversight responsibilities. The factors considered by the forum are expected to be the same for J.P. Morgan and non–J.P. Morgan managed strategies, as further described under “Research Process” above. In addition, the Sub-Adviser may be limited from making additional purchases of a Fund due to capacity considerations. The Sub-Adviser also can, for portfolio construction reasons, remove a Fund from the Program. The Sub-Adviser uses research from the JPMPI Manager Solutions Team (Manager Solutions Team) to research, select and monitor Funds. The Manager Solutions Team is comprised of employees of JPMCB and other affiliates. Specialists on the Manager Solution Team are supervised persons of JPMPI. The Manager Solutions Team conducts due diligence of the Funds and Investment Strategies that are available for use in the Program and 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 both JPMPI and non-J.P. Morgan investment strategies to the same process however, the Manager Solutions Team or any of its affiliates applies its discretion and is not required to apply all factors equally to each Fund in the search universe. J.P. Morgan maintains certain capacity limitations on investment positions in non-J.P. Morgan Funds due to liquidity concerns, regulatory requirements and related internal policies. In circumstances where these limitations mean that the Sub-Adviser would not be able to invest all desired client assets in a particular non-J.P. Morgan Fund, the Manager Solutions Team will likely recommend a J.P. Morgan Fund. The Manager Solutions Team will begin the search process by defining an applicable universe of managed strategies, which typically will include J.P. Morgan managed strategies when there is one in the desired asset class. The Manager Solutions Team utilizes both quantitative and qualitative assessments during its initial review process. The Manager internal Solutions Team then recommends particular Funds to an governance committee, which is responsible for approving or rejecting them. The Manager Solutions Team is also responsible for monitoring and re-evaluating approved Funds as part of its ongoing review process. Centralized Due Diligence A Fund that is on probation can be held in a client Account, but generally, the Sub-Adviser will not direct new purchases until the Fund is removed from probation. During the probation period, the Manager Solutions Team and operational due diligence teams will continue to review the Fund. Generally, a Fund that is terminated will be sold in a client Account, and the Sub-Adviser will not direct new purchases of that Fund. If the Sub-Adviser removes a Fund from the Program, the assets held in client Accounts will be sold and replaced with another Fund that is approved for use in the Program without notice to clients. When evaluating a replacement Fund, the Sub-Adviser is expected to consider the same factors described above. Use of J.P. Morgan Funds and Potential Conflicts of Interest JPMPI’s Manager Solutions and operational due diligence teams provide research on Funds. The “Qualitative Research Process” is used by the Program. An operational due diligence review is performed on Funds identified through the Qualitative Research Process. In the Qualitative Research Process, the Manager Solutions Team conducts a qualitative analysis of Funds on an ongoing basis. The team reviews the portfolio manager’s organization, investment process, investment philosophy and performance. Investment Principles and Potential Conflicts of Interest As part of the due diligence process, JPMPI also applies an ESG eligibility framework that establishes minimum criteria for determining the universe of funds and strategies to be considered for inclusion in JPMPI sustainable investing and ESG strategies, and conducts a periodic review to confirm the ongoing applicability of the designation of such funds and strategies as JPMPI sustainable investing and ESG strategies. Funds may be removed from (or no longer be eligible for purchase in) the Program if they do not continue to meet these criteria. Initial Fund and Investment Strategy Review and Approval Conflicts of interest will arise whenever J.P. Morgan has an actual or perceived economic or other incentive in its management of client Accounts to act in a way that benefits J.P. Morgan. Conflicts will result, for example (to the extent the following activities are permitted in a client’s Account): (1) when J.P. Morgan invests in an investment product, such as a mutual fund, managed by a J.P. Morgan affiliate, such as JPMIM or JPMPI; (2) when a J.P. Morgan entity obtains services, including trade execution and trade clearing, from a J.P. Morgan affiliate; (3) when J.P. Morgan receives payment as a result of purchasing an investment product for a client’s Account; or (4) when J.P. Morgan receives payment for providing services (including shareholder servicing, recordkeeping or custody) with respect to investment products purchased for a client’s Account. Other conflicts will result because of relationships that J.P. Morgan has with other clients or when J.P. Morgan acts for its own Account. Investment strategies are selected from both J.P. Morgan and third-party asset managers and are subject to a review process by the Manager Solutions Team. From this pool of strategies, J.P. Morgan portfolio construction teams select those strategies J.P. Morgan believes fit its asset allocation goals and forward-looking views in order to meet the Investment Strategy’s investment objective. The internal governance committee approves or rejects new Funds to be made available for the Sub-Adviser to use in the Program. There can be Funds that are not available in the Program but that are available in other programs advised by JPMPI or its affiliates. The Manager Solutions and operational due diligence teams provide a formal presentation on prospective managed strategies to the governance forum for review. The internal governance committee is expected to consider the same factors in its review and approval process for J.P. Morgan and non–J.P. Morgan managed strategies. These factors include, 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. Portfolio Construction Depending on the investments available in each Program, investment strategies are selected from both J.P. Morgan Funds and third-party asset managers and are subject to a review process by J.P. Morgan manager research teams. From this pool of investment strategies, J.P. Morgan portfolio construction teams select those investment strategies J.P. Morgan believes fit its asset allocation goals and forward-looking views in order to meet the investment objective of the Investment Strategy or portfolio. From the pool of strategies, the Sub-Adviser selects the combination of Funds that, in its view, fit each Investment Strategy’s asset allocation goals and investment objectives. In making portfolio construction decisions, the Sub-Adviser will consider and is permitted to prefer J.P. Morgan Funds. The Sub-Adviser is also more likely to select a J.P. Morgan Fund in 33816_COL 11-05-2025 Page 9 of 20  Balanced 2% 97% 1% Balanced ESG 0% 99% 1% Growth 1% 98% 1% Growth ESG 0% 99% 1% Aggressive Growth 1% 98% 1% As a general matter, J.P. Morgan prefers J.P. Morgan managed strategies. J.P. Morgan expects the proportion of J.P. Morgan managed strategies will be high (in fact, up to 100 percent) in strategies, such as, for example, cash and high-quality fixed income, subject to applicable law and any Account- specific considerations. J.P. Morgan may allocate a significant portion of the assets in the Program to J.P. Morgan Funds. That portion varies depending on market or other conditions. Allocations shown here are illustrative only, do not necessarily represent actual use of J.P. Morgan Funds and non-J.P. Morgan Funds represented in any particular client’s Account, and can change without notice. JPMPI has full discretionary authority to select Funds and is not required to adhere to the illustrative allocations pictured here. While J.P. Morgan’s internally managed investment strategies generally align well with J.P. Morgan’s forward-looking views, and J.P. Morgan is familiar with the investment processes as well as the risk and compliance philosophy of the J.P. Morgan, it is important to note that J.P. Morgan receives more overall fees when internally managed investment strategies are included. Refer to Item 9, section C for more information on Potential Conflicts of Interest. Risk of Loss When J.P. Morgan selects J.P. Morgan Funds for client Program Accounts, J.P. Morgan receives a fee for managing the J.P. Morgan Funds. As such, J.P. Morgan will receive more total revenue when cash in a client’s Account is invested in J.P. Morgan Funds than if it was invested in third-party funds. JPMS and JPMPI address this conflict through disclosure to clients and through the investment process described in Item 6 herein. For important information about each J.P. Morgan Fund, including investment objectives, risks, charges and expenses, clients can read each Fund’s prospectus carefully and consider all the information in it before investing. J.P. Morgan Funds and Third-Party Funds – Other Fees and Expenses 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. Material, Significant or Unusual Risks Relating to the Program All Funds have various internal fees and other expenses that are paid by managers or issuers of the Funds or by the Funds themselves, but that ultimately are borne by the investor. These fees and expenses are in addition to any fees paid to JPMS. J.P. Morgan may receive administrative and servicing fees for providing services to both J.P. Morgan Funds and third-party Funds that are held in a client’s Account. Refer to the discussion of “Share Classes Available in Program Investment Strategies” in Item 4 above for more information on the receipt of administrative and servicing fees. Clients should review the applicable prospectuses for Funds for more information about these fees and expenses. These payments may be made by sponsors of the Funds (including affiliates of J.P. Morgan), or by the Funds themselves, and may be based on the value of the Funds in the client’s Account. Funds or their sponsors may have other business relationships with J.P. Morgan outside of its portfolio management role or with its broker-dealer affiliates of J.P. Morgan, which may provide brokerage or other services that pay commissions, fees and other compensation. Set forth below is a summary of the material risk factors that are associated with the Program, its Investment Strategies and the types of investments used in the Program. This is a summary only. The information included in this Brochure does not include every potential risk associated with the financial planning process or with each Investment Strategy or Fund applicable to clients participating in the Program. The risk factors associated with the relevant Fund’s investment strategy are disclosed in the prospectus, offering memorandum or other materials of the Fund. Prospective investors should carefully read the relevant offering documents and consult with their own counsel and advisers as to all matters concerning investments in Funds. Clients should not rely solely on the descriptions provided below. Clients are urged to ask questions regarding risk factors applicable to a particular strategy or investment product by calling 1-800-392-5749 and determine whether the Program is suitable for them in light of their specific circumstances and investment goals. J.P. Morgan Funds — Management Fees Financial Planning Risks JPMPI or its affiliates may be sponsors or managers of Funds that J.P. Morgan purchases for Program Accounts. In such case, JPMPI or its affiliates may receive a fee for managing such Funds. As such, JPMPI and its affiliates will receive more total revenue when the client’s portfolio is invested in such Funds than when it is invested in third-party funds. JPMPI can allocate a portion of the assets in the Program to J.P. Morgan Funds. That portion varies depending on market or other conditions. The use of J.P. Morgan Funds, non–J.P. Morgan Funds and J.P. Morgan Money Market Funds in a client’s Account will depend on the client’s asset level, reasonable restrictions placed by the client on the management of an Account, and other factors. Each client should review Account opening documentation, confirmations and quarterly and annual statements for more information about the actual allocation in the client’s Account. JPMS’ financial planning process is designed to provide an overview of your financial situation and to identify what steps, if any, may be helpful to meet your particular investment needs, goals and other specific objectives. The planning process is based upon a projection of current and future investment returns and other variables, such as inflation and/or current tax rates, in order to compare your current asset allocation with a hypothetical asset allocation. The financial plan is not a comprehensive financial plan, which would be a more detailed review of your overall financial situation and would cover a broader spectrum of needs, including insurance needs, tax planning, charitable gifting, estate planning and long-term care. There is a risk that the financial plan, by not taking these needs into account, creates an inaccurate assessment of your financial situation. The financial plan is not intended to provide and should not be relied upon as providing accounting, legal, regulatory or tax advice. The following chart shows the allocation of assets between J.P. Morgan and non-J.P. Morgan Funds by Fund type for each Investment Strategy (including applicable municipal fixed income and U.S.-focused strategies). including Investment Strategy as of February 5, 2025 J.P. Morgan Funds Non-J.P. Morgan Funds J.P. Morgan Cash Income 2% 97% 1% Conservative 2% 97% 1% The calculations and analyses presented in the financial plan are based, in part, on the information that you have provided to JPMS. JPMS has not verified, and is not responsible for, the accuracy or completeness of information you provide, information regarding External Accounts. Information that you provide about your assets, risk tolerance and personal situation are key assumptions for the calculations and projections in the financial plan. Even small changes in assumptions can have a substantial impact on the results shown. Any information provided by you should be reviewed periodically and updated when either the 33816_COL 11-05-2025 Page 10 of 20  information or your circumstances change. JPMS does not provide advice with respect to assets at other firms and is not responsible for any activity conducted in accounts at other firms. A “Monte Carlo” simulation is used to calculate the results that are shown in the financial plan. Such simulations are completed by running the calculation many times, each time using a different sequence of returns. Some sequences of returns will give you better results and some will give you worse results. These multiple trials provide a range of possible results; some trials may be successful (where you meet your goals) and others unsuccessful (where you do not meet your goals). The percentage of trials that were successful is the probability that your goals, with all the underlying assumptions, could be successful. The results using Monte Carlo simulations indicate the likelihood that an event may occur as well as the likelihood that it may not occur. Such an analysis does not take into account actual market conditions, which will affect the outcome of your goals. 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, embargoes, tariffs, sanctions and other trade barriers, regulatory events, other governmental trade or market control programs, and related geopolitical events. 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, pandemics or endemics. When reviewing your financial plan, it is important to keep in mind that projections or other information contained within a financial plan regarding the likelihood of various investment outcomes is hypothetical in nature, does not reflect actual investment results, and is not a guarantee of future results. The results shown will vary each time a financial plan is created and over time. General Portfolio Risks Many of the risks defined below apply to assets within Program Accounts. Refer to JPMPI’s ADV brochure (which can be obtained at the SEC’s website at adviserinfo.sec.gov) for additional disclosures regarding the risks associated with the Program and JPMPI’s role as Sub-Adviser. Infectious Disease Risk. The effects of any future pandemic or other global event to business and market conditions may have a significant negative impact on the performance of the separately managed accounts and J.P. Morgan Fund investments; increase separately managed account and fund volatility; exacerbate preexisting political, social, and economic risks to separately managed accounts and J.P. Morgan Funds; 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 pandemic or global event that affect the instruments in which a separately managed account or J.P. Morgan Funds 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 pandemic or any other global events and the extent to which the associated conditions and governmental responses impact a separately managed account or J.P. Morgan Affiliated Fund will also depend on future developments, which are highly uncertain, difficult to accurately predict and subject to frequent changes. Regulatory Risk. There have been legislative, tax, and regulatory changes and proposed changes that may apply to the activities of JPMS that may require legal, tax and regulatory changes, including requirements to provide additional information pertaining to a client Account to the Internal Revenue Service (IRS) or other taxing authorities. Regulatory changes and restrictions imposed by regulators, self-regulatory organizations and exchanges vary from country to country and may affect the value of client investments and their ability to pursue their investment strategies. Any such rules, regulations and other changes, and any uncertainty in respect of their implementation, may result in increased costs, reduced profit margins, and reduced investment and trading opportunities, all of which would negatively impact performance. Risks Associated with the Use of Artificial Intelligence (AI) Tools. JPMS 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, or be otherwise harmful. J.P. Morgan typically incorporates human oversight to reduce the risk of acting on potentially defective outputs. AI Tools present Data Sources Risk, Cybersecurity Risk and Model Risk (as further 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 the Adviser’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Further, JPMS uses AI Tools developed by third parties, and JPMS may have limited visibility over the accuracy and completeness of such AI Tools. LIBOR Discontinuance. 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 underling markets. New or alternative reference 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 or replacement, all of 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. Data Sources Risk. Although JPMS obtains data, including alternative data, and information from third-party sources that it considers to be reliable, JPMS does not warrant or guarantee the accuracy and/or completeness of any data or information provided by these sources. JPMS has controls for certain data, that, among other things, consider the representations of such third parties with regard to the provision of the data to JPMS in compliance 33816_COL 11-05-2025 Page 11 of 20  with applicable laws. JPMS does not make any express or implied warranties of any kind with respect to such third-party data. JPMS shall not have any liability for any errors or omissions in connection with any data provided by third-party sources. 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 an investment manager will align with the beliefs or values of the client. Additionally, other investment managers and investment advisers 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. AI Tools often use data feeds from a number of sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool will be unable to properly function or their operation may be adversely impacted. The 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 JPMS and the third-party data provider. A tool’s ability to process data may also be adversely affected if JPMS experiences any disruptions to its computing resources or network connections, including disruption of cloud-based computing resources. 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 uses 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. ESG and sustainable investing are not uniformly defined concepts, and scores or ratings may vary across 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 sustainability-related practices and the IAR’s assessment of such practices could change over time. The ESG or sustainable solutions meet our internally developed criteria for inclusion in the ESG Strategies available to clients, which take into account ESG or sustainable investing regulations where applicable. As part of the due diligence process, the Manager Solutions Team applies an ESG eligibility framework that establishes minimum criteria for determining the universe of ESG Strategies offered to our clients. Strategies that satisfy our 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 JPMPI, in its discretion and as appropriate, for inclusion in any client portfolio. 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, improper release, corruption and destruction of, or unauthorized access to, confidential 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 can 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 the 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 which 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 cybersecurity defenses or plans of its service providers, financial intermediaries and companies in which they invest or with which they do business. Use of AI Tools may lead to increased risks of cyber- attacks or data breaches and the ability to launch more automated, targeted and coordinated attacks due to the vulnerability of AI technology to cybersecurity threats. 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 difference in 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 an investment to be classified as a “sustainable investment.” Unless otherwise specified and where permitted by applicable law, 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. 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. Category Restrictions and Exclusions Risks Risks That Apply Primarily to ESG/Sustainable Investing Strategies that 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. incorporate ESG considerations or Investment approaches sustainable investing can include additional risks. ESG or sustainable investing strategies (together, ESG Strategies), including SMAs, 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. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries that share common characteristics and are often subject to 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, JPMPA may rely on information about a company, industry classification, 33816_COL 11-05-2025 Page 12 of 20  industry grouping and/or issuer screening provided by J.P. Morgan or a third party. application and impact of Section 1091 of the Internal Revenue Code of 1986, as amended, and the corresponding Treasury regulations (the wash sale rules) with respect to their portfolio and their accounts with or outside of J.P. Morgan. 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. If a client holds an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event for the client. The client is responsible for complying with all applicable tax rules, including, but not limited to, the wash sale rules, and the client is responsible for all tax consequences attributable to the disallowance of any losses under the wash sale rules. Further, certain investments may generate unwanted excise taxes, income taxes and penalties under the Internal Revenue Code of 1986, as amended, any or all of which may affect the client’s return on investment and, if applicable, a client’s tax-exempt status. Tax Harvesting As part of its investment management services, J.P. Morgan has the ability to sell certain investments at a gain or loss to potentially offset a client’s tax liability at its discretion. Third-party managers or programs 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. Further, 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. JPMS and its affiliates do 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 that 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. Tax Harvesting generally entails a repurchase of the sold security after the “wash sale” (i.e., 30-day) period. Generally, under the wash sales rules, if a client sells a security for a loss and then repurchases the same (or a substantially identical) security either 30 days before or 30 days after the date of the sale, the loss is disallowed. The wash sale rules apply to transactions in not only that Account but also to transactions in all other accounts held by the client, the client’s spouse and certain entities controlled by them (related parties), whether those accounts are held with JPMS or its affiliates or other financial institutions. JPMPI will only monitor for wash sales in your Account and will not consider trading activity or otherwise monitor for wash sales in other securities accounts held by the client and its related parties. It is the client’s responsibility to comply with the wash sale rules with respect to all such accounts. The application of category restrictions vary by asset class. Restrictions are not available for all strategies, and JPMPA can reject a restriction if it deems the restriction to be unreasonable or not in line with the strategy. The number of restrictions that a client can select are limited based on the potential impact to the applicable Investment Strategy and potential deviation from the Investment Strategy. Assets will generally be invested in Funds during the wash sale period. Funds are investment companies and have certain embedded costs, including portfolio management fees, of which the client will bear a proportionate share while invested in the Fund. Such costs are in addition to other advisory or management fees charged to the client. The client is responsible for understanding the merits and consequences of Tax Harvesting. For client Accounts that can hold Funds, clients cannot prohibit or restrict JPMPI from investing in specific securities or types of securities that are held within any Fund. Category restrictions will not be applied to strategies that invest only in Funds, nor will they be applied to investments made by Funds, so it is possible that client restrictions would not have any practical effect on an Account comprised primarily of Fund investments. Tax Risks and Risks That Apply to Tax-Aware or Tax-Harvesting and Tax- Managed Strategies Tax-Managed Strategies. There are risks and limitations associated with any tax-aware or tax-managed strategies (each such strategy, a Tax- Managed strategy), and these limitations may result in tax-inefficient trades and wash sales. Tax management is not tax advice and may not achieve the intended results. Although a Tax-Managed strategy may reduce a client’s taxable income, it will not eliminate it. A Tax-Managed strategy may require trade-offs that reduce pre-tax income. Managing a strategy to maximize after-tax returns may also potentially have a negative effect on a strategy’s performance. To the extent tax consequences are considered in managing a strategy, the strategy’s or Fund’s pre-tax performance may be lower than that of a similar strategy that is not tax managed. Account transactions may give rise to tax liability for which a client is responsible. Funds may make large distributions of income and capital gains to investors at various times in a calendar year, and the client will be liable for taxes on such distributions without regard to the date of the client’s investment in a portfolio. Tax Harvesting will cause your Account holdings to differ from those accounts that do not utilize Tax Harvesting, and therefore your Account performance will differ. There is no guarantee that Tax Harvesting will perform as expected or that specific benefits will be obtained for any particular client. The implementation of Tax Harvesting may have an adverse effect on investment performance and result in adverse tax consequences, including, but not limited to, gains derived from the sale of the security held during the wash sale period. Further, the tax consequences of Tax Harvesting may be challenged by the Internal Revenue Service or any other tax authority. REITs Risk. The value of real estate securities in general, and REITs in particular, are subject to similar risks as direct investments in real estate and mortgages, and their value will be influenced by many factors including the value of the underlying properties or the underlying loans or interests. The underlying loans may be subject to the risks of default or of prepayments that occur later or earlier than expected and such loans may also include so-called "subprime" mortgages. The value of these securities will rise and fall in response to many factors, including economic conditions, the demand for rental property, interest rates and, with respect to REITs, the management skill and creditworthiness of the issuer. In particular, the value of these securities may decline when interest rates rise and will also be affected by the real estate market and by the management of the underlying properties. There is no public trading market for private or public non-traded REITs; therefore, such REITs may be more volatile and/or more illiquid than publicly traded REITs and other types of equity securities. Neither JPMPI nor its representatives or affiliates offer tax or accounting advice or services and the client should not solicit or rely upon any such advice from them. J.P. Morgan and its affiliates do not provide tax advice and clients should consult their own tax professional with respect to the impact of Tax Harvesting and the federal, state and local tax consequences of investing in any portfolio, including, without limitation, the potential 33816_COL 11-05-2025 Page 13 of 20  Offsets for Retirement Accounts Holding J.P. Morgan Funds If a Program Account owned by an IRA, or other client that is a qualified retirement plan subject to the prohibited transaction provisions of Section 4975 of the IRC, holds any J.P. Morgan Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with Program Account assets will be offset against the Advisory Fee. Refer to “Offset of Certain Fees to IRAs and Certain Other Retirement Accounts” in Item 4 above. Prospectus Delivery discounted pricing of certain services provided by an affiliate and the amount of CSP assets invested in affiliated products, and that certain affiliated mutual funds offered a lower-cost share class than the share class purchased for CSP. In addition, the Order finds that JPMS failed to implement written policies and procedures adequate to ensure disclosure of these conflicts of interest. Solely for the purpose of settling these proceedings, the Respondents consented to the Order, admitted to the certain facts set forth in the Order, and acknowledged that certain conduct set forth in the Order violated the federal securities laws. The Order censures JPMS and directs the Respondents to cease-and-desist from committing or causing any violations and any future violations of the above-enumerated statutory provisions. Additionally, the Order requires the Respondents to pay a total of $266,815,000 in disgorgement, interest and civil penalty. A discretionary investment adviser can receive prospectuses and other issuer-related materials on behalf of a client for any Funds in a client’s Account with client authorization. JPMS or JPMPI, as a client’s agent, will have access to the prospectuses and issuer-related materials and relies upon them to make Fund investments on the client’s behalf; however, clients will no longer receive such prospectuses or issuer-related materials directly, but can access them via the issuer’s website or request copies from JPMS at any time. Prospectuses and issuer-related materials contain important information and detailed descriptions of additional fees and expenses, investment minimums, risk factors and conflicts of interest disclosures as well as client’s rights, responsibilities and liabilities with respect to such investments. Additionally, this Brochure contains other general information regarding fees and expenses, risk factors and conflicts of interest. ITEM 7 — CLIENT INFORMATION PROVIDED TO SUB-ADVISER Concurrently, on December 18, 2015, JPMCB reached a settlement agreement with the Commodity Futures Trading Commission (CFTC) to resolve its investigation of JPMCB’s disclosure of certain conflicts of interest to discretionary account clients of J.P. Morgan Private Bank’s U.S.-based wealth management business. In connection with the settlement, the CFTC issued an order (CFTC Order) finding that JPMCB violated Section 4o(1)(B) of the Commodity Exchange Act (CEA) and Regulation 4.41(a)(2) by failing to fully disclose to certain clients its preferences for investing certain discretionary portfolio assets in certain commodity pools or exempt pools, namely (a) investment funds operated by J.P. Morgan Asset Management, and (b) third-party managed hedge funds that shared management and/or performance fees with an affiliate of JPMCB. The CFTC Order directs JPMCB to cease- and-desist from violating Section 4o(1)(B) of the CEA and Regulation 4.41(a)(2). Additionally, JPMCB shall pay $40 million as a civil penalty to the CFTC and disgorgement of $60 million satisfied by disgorgement to be paid to the SEC by JPMCB and an affiliate in a related and concurrent settlement with the SEC. a of the Order, go to: sec.gov/litigation/ JPMS provides to JPMPI a summary of client information relevant to JPMPI’s services to the client, including the client’s name, address, Account number, Social Security number or taxpayer identification number, whether the Account is taxable or non-taxable, the client’s selected Investment Strategy (or Strategies), investment restrictions requested by the client, and the amount to be invested. That information is updated if it becomes materially incorrect, such as in the event that the client selects a new Investment Strategy or changes their investment restrictions. copy For admin/2015/33-9992.pdf. ITEM 8 — CLIENT CONTACT WITH SUB-ADVISER JPMS and JPMPI personnel who are knowledgeable about the management of client Program Accounts are available for client consultation upon reasonable request. JPMPA IARs can assist clients in contacting such personnel. ITEM 9 — ADDITIONAL INFORMATION A. Disciplinary Information JPMS has been involved in the following material legal or disciplinary events during the last ten years. 2) On or about July 28, 2016, JPMS and JPMCB entered into a Consent Agreement (Agreement) with the 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. 3) 1) On December 18, 2015, JPMS and JPMCB (together, Respondents) entered into a settlement with the SEC resulting in the SEC issuing an order (Order). The Respondents consented to the entry of the Order that finds that JPMS violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 and Rule 206(4)-7, and JPMCB violated Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The Order finds that JPMCB negligently failed to adequately disclose (a) from February 2011 to January 2014, a preference for affiliated mutual funds in certain discretionary investment portfolios (the Discretionary Portfolios) managed by JPMCB and offered through J.P. Morgan’s U.S. Private Bank (the U.S. Private Bank) and the Chase Private Client lines of business; (b) from 2008 to 2014, a preference for affiliated hedge funds in certain of those portfolios offered through the U.S. Private Bank; and (c) from 2008 to August 2015, a preference for retrocession-paying third-party hedge funds in certain of those portfolios offered through the U.S. Private Bank. With respect to JPMS, the Order finds, that from May 2008 to 2013, JPMS negligently failed to adequately disclose, including in documents filed with the SEC, conflicts of interest associated with its use of affiliated mutual funds in the Chase Strategic Portfolio (CSP) program, specifically, a preference for affiliated mutual funds, the relationship between the In October 2018, JPMS submitted an 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) 33816_COL 11-05-2025 Page 14 of 20  reasonably 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 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. 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. 4) 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 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. 7) 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. 5) 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 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 J.P. Morgan Funds; (ii) there was an economic incentive to invest CSP assets in J.P. Morgan 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 J.P. Morgan Fund share classes. Solely for the purpose of settling these proceedings, JPMS consented to the March 2020 Order, with no admissions as to liability. JPMS agreed to pay a total of $325,000 to resolve the KDFI investigation. 6) 8) 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 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 33816_COL 11-05-2025 Page 15 of 20  penalty in the amount of $45,000,000. JPMS has paid the civil monetary penalty in accordance with the terms of the Order. and/or its affiliates’ portfolio managers have personal investments in Similar Accounts, or the Similar Accounts are investment options in JPMS’ or its affiliates’ employee benefit plans. B. Other Financial Industry Activities and Affiliations JPMS’ primary business is providing brokerage products and services as a bank-affiliated broker-dealer and making available to its customers, in addition to investment advisory services, a variety of bank, securities and insurance products through its affiliates. JPMS’ officers, managers and IARs spend the majority of their time in administrative or supervisory duties with broker-dealer activities rather than investment advisor activities. JPMS and its affiliates maintain certain investment limitations on the positions in securities (including Funds), or other financial instruments, that JPMS or its affiliates will take on behalf of its various clients due to, among other things: (i) liquidity concerns; (ii) regulatory requirements applicable to JPMS or its affiliates; and (iii) internal policies related to such concerns or requirements, in light of the management of multiple portfolios and businesses by JPMS and its affiliates. Such policies preclude JPMS or its affiliates from purchasing certain securities for clients and can cause JPMS to sell certain securities held in client Accounts. JPMS is affiliated with several other SEC-registered broker-dealers, investment companies, investment advisers, insurance agencies, mortgage companies and JPMCB. Other registered investment advisers, collectively referred to as “J.P. Morgan Asset Management,” are affiliated with JPMS under the common ownership by JPMC. One or more of these affiliated investment advisers, including, but not limited to, JPMIM, serve(s) as the investment adviser to various J.P. Morgan Funds. C. Material Relationships with Related Persons and Potential Conflicts of Interest Potential conflicts of interest can arise with both the aggregation and investment allocation of securities transactions and allocation of opportunities because of market factors or investment restrictions imposed upon JPMS and its affiliates by law, regulation, contract or internal policies. Allocations of aggregated trades, particularly trade orders that were only partially completed due to limited availability and allocation of investment opportunities generally, could raise a potential conflict of interest as JPMS or its affiliates can have an incentive to allocate securities that are expected to increase in value to favored Accounts. JPMS mitigates this conflict by using equitable guidelines adopted by JPMS and affiliates to allocate trade orders among Program Accounts. A potential conflict of interest also can arise if transactions in one Account closely follow related transactions in a different Account, such as when a purchase increases the value of securities previously purchased by another Account or when a sale in one Account lowers the sale price received in a sale by a second Account. JPMS has several relationships or arrangements with related persons that are material to its investment advisory business or to clients in the Program. Below is a description of such relationships and some of the conflicts of interest that arise from them. JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest that may arise between JPMS and its affiliates. These policies and procedures include information barriers designed to prevent the flow of information between JPMS and certain other affiliates, as more fully described below. Distribution and Other Fees and Revenue Sharing The use of affiliates to provide services to clients creates certain conflicts of interest for JPMS and JPMPI. Among other things, there are financial incentives for JPMS, JPMPI (and their affiliates), including its parent company, JPMC, to favor affiliated service providers over non-affiliated service providers, and compensation of supervised persons of JPMS and JPMPI generally is directly or indirectly related to the financial performance of J.P. Morgan. Affiliated Fund Advisors JPMS receives distribution fees from certain mutual funds pursuant to Rule 12b-1 under the Investment Company Act of 1940. If JPMS receives 12b-1 fees on load-waived Class A shares, it will credit these fees to the client’s Program Account. JPMS, directly or indirectly, receives servicing or administrative fees for certain Funds that are held in a client’s Account. Refer to the discussion of “Share Classes” in Item 4 above for more information on the receipt of administrative and servicing fees. In addition, JPMS’ affiliates receive licensing fees for their indices used by unaffiliated ETFs or other product sponsors. Funds, including money market funds, pay fees and expenses that are ultimately borne by clients. Clients can review the applicable prospectuses for Funds in the Program for additional information about these fees and expenses. These fees and expenses are in addition to the Advisory Fee. Refer to “Other Fees and Expenses” in Item 4 above for more information. about these arrangements is available JPMS has negotiated revenue sharing arrangements with a number of mutual funds and mutual fund families. Some of these mutual funds are available in the Programs, and JPMS will receive additional revenue on either the mutual fund assets in Program Accounts or on the initial purchase of these mutual funds. Some of the mutual funds make revenue sharing payments to JPMS for mutual funds held in brokerage Accounts for which JPMS does not provide investment advisory services. Additional information at jpmorgan.com/TheGuide. IARs are not compensated from JPMS’ receipt of shared revenues received from mutual funds. J.P. Morgan’s Use and Ownership of Trading Systems Affiliates of JPMS provide investment advisory and other services to the J.P. Morgan Funds for compensation. Therefore, because JPMS and its affiliates will in the aggregate receive more revenue when Program Accounts are invested in J.P. Morgan Funds than they would receive if the Program Accounts were invested in non–J.P. Morgan Funds, JPMS has a conflict of interest when Program Accounts are invested in J.P. Morgan Funds. The use of an affiliated Sub-Adviser in the Program is also a benefit to JPMS and its affiliates since it increases the overall revenue of affiliates of JPMS and their parent company. JPMS addresses this conflict through disclosure and subjecting the J.P. Morgan Funds and non-J.P. Morgan Funds to the investment process described in Item 6 above. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” in Item 6 above for more information on the use of J.P. Morgan Funds. Securities Allocations and Limitations JPMS may effect trades on behalf of Program Accounts through exchanges, electronic communications networks, alternative trading systems and similar execution systems and trading venues (collectively, Trading Systems), including Trading Systems in which J.P. Morgan has a direct or indirect ownership interest. J.P. Morgan will receive indirect proportionate compensation based upon its ownership percentage in relation to the transaction fees charged by such Trading Systems in which it has an ownership interest. Such Trading Systems (and the extent of J.P. Morgan’s ownership interest in any Trading System) may change from time to time. Ownership Interest in J.P. Morgan Stock JPMS is part of a large financial services firm. In connection with providing investment advisory services to its clients, JPMS uses the products or services of its affiliates or other related persons, as described both above and below. JPMS and/or its affiliates can receive more compensation from certain Accounts that use strategies similar to those used by Program Accounts (Similar Accounts) than it or its affiliates receive from Program Accounts. JPMS or its affiliates have a conflict of interest to the extent that JPMS or an affiliate has a proprietary investment in Similar Accounts, JPMS’ Certain unaffiliated asset management firms (each, an unaffiliated asset manager) through their funds and separately managed accounts currently hold a 5% or more ownership interest in J.P. Morgan publicly traded stock. Ownership interests in this range or of greater amounts present a conflict 33816_COL 11-05-2025 Page 16 of 20  Other Compensation from ETFs of interest when J.P. Morgan purchases publicly traded securities of the unaffiliated asset manager or the separately managed accounts or funds that are managed or advised by the asset manager on behalf of client accounts or J.P. Morgan Affiliated Funds. J.P. Morgan does not receive any additional compensation for client accounts' or J.P. Morgan Affiliated Funds' investments in publicly traded securities or funds of an unaffiliated asset manager as a result of its ownership interest in JPMC stock. 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 February 26, 2025, the Vanguard Group, Inc. and BlackRock, Inc. hold more than a 5% interest in J.P. Morgan. Payment for Order Flow Certain ETFs in which Account assets may be invested in for the Program may execute transactions for their portfolios through JPMS or an affiliate as broker-dealer, and JPMS or an affiliate may receive traditional brokerage compensation and fees from the ETFs in connection with these transactions. Such compensation presents a conflict of interest between JPMS and Program clients because JPMS may have a financial incentive to invest Program Account assets in such ETFs: (1) in the hope or expectation that increasing the amount of assets invested with the ETFs will increase the number and/or size of transactions placed by the ETFs 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 ETFs and thereby preserve and foster valuable brokerage relationships with the ETFs. JPMorgan Chase Bank, N.A. JPMCB is a national banking association affiliated with JPMS and is subject to supervision and regulation by the U.S. Department of Treasury's Office of the Comptroller of the Currency. JPMCB provides investment management, trustee, custody and other services to both institutional and non-institutional clients. Refer to Item 4 for additional conflicts of interest and other information relating to the sweep Deposit Account. J.P. Morgan Acting in Multiple Commercial Capacities JPMS does not receive payment for order flow from market makers for customer orders in equity securities. JPMS receives rebates from and pays fees to some registered securities exchanges for providing or taking liquidity on those exchanges, according to those exchanges’ published fee schedules approved by the SEC. Alternative trading systems also charge fees and, in some cases, pay rebates for the provision or removal of liquidity. In addition, JPMS receives marketing fees from options exchanges under marketing fee programs sponsored by some exchanges. Under some circumstances, the amount received by JPMS from a trading center over a period of time may exceed the amount that JPMS is charged by a trading center. These practices are one of many factors that may impact routing decisions and do not alter JPMS’ policy to route customer orders in securities to the trading centers where it believes customers will receive the best execution, taking into account, among other factors, price, transaction cost, volatility, reliability, market depth and speed. available in Rule 606 reports Affiliates of JPMS have ownership interests in some trading centers. Accordingly, JPMS stands to share in any profits that these trading centers earn from the execution of JPMS customer orders on those trading centers. Additional information on the material aspects of JPMS’ relationships with the primary trading centers to which JPMS routes, including descriptions of arrangements for payment for order flow and profit-sharing relationships, is at SEC JPMS’ jpmorgan.com/OrderExecution. J.P. Morgan’s Use of Index Products from providing J.P. Morgan is a diversified financial services firm that provides a broad range of services and products to its clients and is a major participant in the global currency, equity, commodity, fixed income and other markets in which JPMS client Accounts invest. J.P. Morgan is typically entitled to compensation in connection with these activities, and the Program clients will not be entitled to any such compensation. In providing services and products to clients other than JPMS’ clients, J.P. Morgan from time to time faces conflicts of interest with respect to activities recommended to or performed for JPMS clients on one hand and for J.P. Morgan’s other clients on the other hand. For example, J.P. Morgan has, and continues to seek to develop, banking and other financial and advisory relationships with numerous U.S. and non-U.S. persons and governments. J.P. Morgan also advises and represents potential buyers and sellers of businesses worldwide. JPMS client Accounts have invested in, and in the future may invest in, such entities represented by J.P. Morgan or with which J.P. Morgan has a banking, advisory or other financial relationship. In addition, certain clients of J.P. Morgan, including JPMS clients, invest in entities in which J.P. Morgan holds an interest, including a J.P. Morgan Fund or J.P. Morgan ETF. In providing services to its clients and as a participant in global markets, J.P. Morgan from time to time recommends or engages in activities that compete with or otherwise adversely affect a JPMS client Account or its investments. It should be recognized that such relationships can preclude JPMS’ clients from engaging in certain transactions and can also restrict investment opportunities that would otherwise available to JPMS clients. For example, J.P. Morgan is often engaged by companies as a financial adviser, or to provide financing or other services, in connection with commercial transactions that are potential investment opportunities for JPMS’ clients. There are circumstances in which advisory accounts are precluded from participating in such transactions as a result of J.P. Morgan’s engagement by such companies. J.P. Morgan reserves the right to act for these companies in such circumstances, notwithstanding the potential adverse effect on JPMS’ clients. In addition, J.P. Morgan derives ancillary benefits investment advisory, custody, administration, prime brokerage, transfer agency, fund accounting and shareholder servicing, and other services to JPMS’ clients. Providing such services to JPMS’ clients enhances J.P. Morgan’s relationships with various facilitates additional business development, and enables parties, J.P. Morgan to obtain additional business and generate additional revenue. The following are descriptions of certain additional conflicts of interest and potential conflicts of interest that are associated with the financial or other interests that JPMS and J.P. Morgan have in transactions effected by, with or on behalf of its clients. In addition to the specific mitigants described further below, JPMS has adopted policies and procedures reasonably JPMS or one of its affiliates may develop or own and operate stock market and other indices based on investment and trading strategies developed by JPMS or its affiliates or assist unaffiliated entities in creating indices that are tracked by certain ETFs utilized by JPMS or an affiliate. Some of the J.P. Morgan ETFs seek to track the performance of certain of these indices. In addition, JPMS and its affiliates may manage client accounts which track the same indices used by the J.P. Morgan ETFs or which may be based on the same, or substantially similar, strategies that are used in the operation of the indices and the J.P. Morgan ETFs. The operation of the indices, the J.P. Morgan ETFs and the client accounts in this manner may give rise to potential conflicts of interest. For example, client accounts that track the same indices used by the J.P. Morgan ETFs may engage in purchases and sales of securities relating to index changes at a time different to the implementation of index updates or as of which the J.P. Morgan ETFs engaging in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the J.P. Morgan ETFs’ 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 or less favorable performance relative to that of the index and the J.P. Morgan ETFs or other client accounts that track the index. Furthermore, J.P. Morgan may, from time to time, manage client accounts that invest in these J.P. Morgan ETFs. 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 J.P. Morgan ETFs. JPMS and its affiliates have established certain information barriers and other policies to address the sharing of information between different businesses within JPMS and its affiliates, including with respect to personnel responsible for coordinating the development and governance of the indices and those involved in decision- making for the J.P. Morgan ETFs. 33816_COL 11-05-2025 Page 17 of 20  designed to appropriately prevent, limit or mitigate conflicts of interest. In addition, many of the activities that create these conflicts of interest are limited and/or prohibited by law and are conducted under an available exception. J.P. Morgan or JPMS’ related persons provide financial, consulting, investment banking, advisory, brokerage (including prime brokerage) and other services to, and receive customary compensation from, an issuer of equity or debt securities held by client Accounts. Any fees or other compensation received by J.P. Morgan in connection with such activities will not be shared with the Program clients or used to offset fees charged to Program clients. Such compensation could include financial advisory fees, monitoring fees, adviser fees or fees in connection with restructurings or mergers and acquisitions, as well as underwriting or placement fees, financing or commitment fees, trustee fees and brokerage fees. to or otherwise elects to become subject to investment policies on a firm- wide basis, including policies relating to environmental, social and corporate governance. JPMS may also limit transactions and activities for reputational or other reasons, including (i) when J.P. Morgan provides or may provide advice or services to an entity involved in such activity or transaction; (ii) when J.P. Morgan or a client is or may be engaged in the same or a related activity or transaction to that being considered on behalf of the client account; (iii) when J.P. Morgan or a client account has an interest in an entity involved in such activity or transaction; or (iv) when such activity or transaction on behalf of or in respect of the advisory account could affect J.P. Morgan, JPMPI, their clients or their activities. J.P. Morgan may also become subject to additional restrictions on its business activities that could have an impact on Program clients Accounts’ activities. In addition, JPMPI may restrict its investment decisions and activities on behalf of particular client accounts and not other accounts. Recommendation or Investments in Securities that the Adviser or Its Related Persons Also Purchase or Sell Additionally, from time to time, directors, officers and employees of JPMC serve on the board of directors or hold another senior position with a corporation, investment fund manager or other institution which may desire to sell an investment to, acquire an investment from or otherwise engage in a transaction with, JPMS clients. The presence of such persons in such circumstances may require the relevant person to recuse themselves from participating in a transaction or cause JPMS, a corporation, investment fund manager or other institution to determine that it (or its client) is unable to pursue a transaction because of a potential conflict of interest. In such cases, the investment opportunities available to JPMS clients and the ability of such clients to engage in transactions or retain certain investments or assets will be limited. J.P. Morgan’s Policies and Regulatory Restrictions Affecting Client Accounts JPMS and its related persons recommend or invest securities on behalf of its clients that JPMS and its related persons also purchase or sell. As a result, positions taken by JPMS and its related persons may be the same as or different from, or made contemporaneously or at different times than, positions taken for clients of JPMS. As these situations involve actual or potential conflicts of interest, JPMS has adopted policies and procedures relating to personal securities transactions, insider trading and other ethical considerations. These policies and procedures are intended to identify and mitigate actual and perceived conflicts of interest with clients and to resolve such conflicts appropriately if they do occur. The policies and procedures contain provisions regarding pre-clearance of employee trading, reporting requirements and supervisory procedures that are designed to address potential conflicts of interest with respect to the activities and relationships of related persons that might interfere or appear to interfere with making decisions in the best interest of clients, In addition, JPMS has including the prevention of front-running. implemented monitoring systems designed to ensure compliance with these policies and procedures. J.P. Morgan’s Proprietary Investments As part of a global financial services firm, JPMS will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by J.P. Morgan, J.P. Morgan’s roles in connection with other clients and in the capital markets, J.P. Morgan’s internal policies and/or potential reputational risk. As a result, client accounts managed by JPMS may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by J.P. Morgan. JPMS, J.P. Morgan and any of their directors, partners, officers, agents or employees also buy, sell or trade securities for their own accounts or the proprietary accounts of JPMS and/or J.P. Morgan. JPMS and/or J.P. Morgan, within their discretion, can make different investment decisions and take other actions with respect to their proprietary accounts than those made for client accounts, including the timing or nature of such investment decisions or actions. Further, JPMS is not required to purchase or sell for any client account securities that it, J.P. Morgan and any of their employees, principals or agents may purchase or sell for their own accounts or the proprietary accounts of JPMS or J.P. Morgan. JPMS, J.P. Morgan and their respective directors, officers and employees face a conflict of interest as they will have income or other incentives to favor their own accounts or the proprietary accounts of JPMS or J.P. Morgan. Conflicts of Interest Created by Contemporaneous Trading Potential conflicts of interest may also arise as a result of JPMS’ current policy to seek to manage its clients’ accounts so that the various requirements and liabilities imposed pursuant to Section 16 of the Securities Exchange Act of 1934 (Section 16 and the Exchange Act, respectively) are not triggered. Section 16 applies to, among other things, “beneficial owners” of 10% or more of any security subject to reporting under the Exchange Act. In addition to certain reporting requirements, Section 16 also imposes on such “beneficial owner” a requirement to disgorge of “short-swing” profits derived from the purchase and sale or sale and purchase of the security, executed within a 6-month period. JPMPI may be deemed to be a “beneficial owner” of securities held by its advisory clients. Consequently, and given the potential ownership level of the various accounts and funds managed for its clients, JPMS may limit the amount, or alter the timing, of purchases of securities in order not to trigger the foregoing requirements. As a result, certain contemplated transactions that otherwise would be consummated by JPMS on behalf of its clients will not take place, will be limited in their size, or will be delayed. Furthermore, J.P. Morgan has adopted policies and procedures reasonably designed to ensure compliance with economic and trade sanctions-related obligations applicable to its activities (although such obligations are not necessarily the same obligations that its clients are subject to). Such economic and trade sanctions prohibit, among other things, transactions with and the provision of services to, directly or indirectly, certain countries, territories, entities and individuals. These economic and trade sanctions, and the application by JPMS of its compliance policies and procedures in respect thereof, may restrict or limit a client’s account’s investment activities. In addition, J.P. Morgan from time to time subscribes Positions taken by a certain client account may also dilute or otherwise negatively affect the values, prices or investment strategies associated with positions held by a different client account. For example, this can occur when investment decisions for one client are based on research or other information that is also used to support portfolio decisions by JPMS or an affiliate for a different client following the same, similar or different investment strategies or by an affiliate of JPMS in managing its clients’ accounts. When a portfolio decision or strategy is implemented for an Account ahead of, or contemporaneously with, similar portfolio decisions or strategies for JPMS or an affiliate's other client (whether or not the portfolio decisions emanate from the same research analysis or other information), market impact, liquidity constraints or other factors could result in one account being disadvantaged or receiving less favorable investment results than the other Account, and the costs of implementing such portfolio decisions or strategies could be increased. 33816_COL 11-05-2025 Page 18 of 20  the Program and provide clients with essential component of nondiscretionary advisory services and Account maintenance support. JPMS contacts clients at least annually to determine whether there have been any changes in the client’s financial situation, investment objectives or investment restrictions that would require changes to the client’s Program Account. To ensure that the Program and the selected Investment Strategy remain suitable for the client, clients are instructed to promptly notify JPMS or their IAR(s) of any material changes to their investment objectives and/or financial situation. Clients are solely responsible for notifying JPMS in the event that any information that JPMS maintains about them is inaccurate or becomes inaccurate. In addition, it is perceived as a conflict of interest when the activity in one account closely correlates with the activity in a similar account, such as when a purchase by one account increases the value of the same securities previously purchased by another account, or when a sale in one account lowers the sale price received in a sale by a second account. Furthermore, if JPMS or an affiliate manages accounts that engage in short sales of securities in which other accounts invest, JPMS or an affiliate could be seen as harming the performance of one account for the benefit of the account engaging in short sales if the short sales cause the market value of the securities to fall. Also, certain private funds managed by JPMS or its affiliates hold exclusivity rights to certain investments and therefore, other clients are prohibited from pursuing such investment opportunities. D. Code of Ethics As most Program Accounts are managed in a similar manner according to the Investment Strategy selected by the client, JPMS does not review individual trades or individual Program Accounts. As described in this Brochure, JPMS periodically reviews the Funds and Investment Strategies available in the Program as well as the Sub-Adviser to ensure that the Funds, Investment Strategies and Sub-Adviser continue to meet the Program requirements. For Program Accounts that have requested investment restrictions, JPMS periodically monitors the Accounts to ensure compliance with the accepted investment restrictions. JPMS has adopted a Code of Ethics (the Code of Ethics) pursuant to Rule 204A-1 under the Advisers Act. The Code of Ethics is designed to ensure that JPMS and its supervised persons comply with applicable federal securities laws and place the interests of clients first in conducting personal securities transactions. The Code of Ethics imposes certain restrictions on securities transactions in the personal accounts of supervised persons to help avoid or mitigate conflicts of interest, as described more fully below. A copy of the Code of Ethics is available free of charge to any client or prospective client upon request by contacting a client service representative or IAR. General The Code of Ethics contains policies and procedures relating to: The information in this Brochure does not include all the specific review features associated with each Fund and Investment Strategy. Clients are urged to ask questions regarding JPMS’ or JPMPI’s review process applicable to a particular Fund or Investment Strategy, to read all product- specific disclosures, and to determine whether a particular Fund, Investment Strategy or type of security is suitable for their Account in light of their circumstances, investment objectives and financial situation. • Account holding reports and personal trading, including reporting and pre-clearance requirements for all personnel of JPMS; Reports to Program Clients • Confidentiality obligations to clients set forth in the J.P. Morgan privacy notices; • Conflicts of interest, which include guidance relating to restrictions on Clients receive Account statements from the custodian at least quarterly and also receive quarterly performance reports. Refer to “Trade Confirmations, Statements and Performance Reporting” above. trading on material non-public information (MNPI). JPMS does not provide tax advice, and the performance reports should not be construed as tax advice. Account reviews are not a substitute for careful review of Account statements or tax reporting forms. Performance reports are not a substitute for regular monthly or quarterly brokerage account statements or IRS Forms 1099 and should not be used to calculate the fees or to complete income tax returns. JPMS and its affiliates are entitled to rely on the financial and other information that clients or any third party provides to JPMS. The client is solely responsible for any information that the client provides to JPMS, and JPMS shall not be liable in connection with its use of any information provided by the client or a third party in the periodic review. Subject to JPMS’ policies and procedures and applicable law, the periodic written performance review provided to Program clients can include information about assets in other accounts. By including such assets in the written performance review, JPMS is not undertaking to provide or be responsible for providing any services with respect to those assets. In general, the personal trading rules under the Code of Ethics require that accounts of JPMS employees and associated persons be maintained with an approved broker and that certain trades in reportable securities for such accounts be precleared and monitored by compliance personnel. The Code of Ethics also prohibits certain types of trading activity, such as short-term and speculative trades. JPMS personnel must obtain approval prior to engaging in all covered security transactions, including those issued in private placements. In addition, JPMS personnel are not permitted to buy or sell securities issued by J.P. Morgan during certain periods throughout the year. Certain Access Persons (defined as persons with access to nonpublic information regarding JPMS’ recommendations to clients, purchases, or sales of securities for client accounts and advised funds) are prohibited from executing personal trades in a security at certain times. In addition, Access Persons are required to disclose household members’ personal security transactions and holdings information. These disclosure obligations and restrictions are designed to mitigate conflicts of interest that arise if Access Persons transact in the same securities as advisory clients. In preparing Account statements and performance reviews, JPMS may use multiple valuation sources that provide different values for a single asset. As a result, the determination of an Account's asset values may differ for different purposes and different statements, reviews and reports. Client Account asset values are available from JPMS upon request. regarding confidential and proprietary Account Errors and Resolutions Additionally, all JPMS and JPMPI personnel are subject to the J.P. Morgan firm-wide policies and procedures, including those found in the J.P. Morgan Code of Conduct (the Code of Conduct). The Code of Conduct sets forth information, restrictions information barriers, private investments, outside business activities and personal trading. All J.P. Morgan employees, including JPMS personnel, are required to familiarize themselves with, comply with, and attest annually to their compliance with the provisions of the Code of Conduct’s terms as a condition of continued employment. Where appropriate, JPMS and its affiliates generally address the conflicts disclosed in this Brochure through policies and procedures. E. Review of Accounts Account errors, trade errors and other operational mistakes occasionally occur in connection with the management of Funds and client Accounts. JPMS has developed policies and procedures that address the identification and correction of such errors and generally require that errors caused by JPMS and affecting a client's account be resolved promptly and fairly. Errors can result from a variety of situations, including portfolio management (e.g., inadvertent violation of investment restrictions) trading, processing or other functions (e.g., miscommunication of Clients have the ability, during normal business hours, to schedule an appointment with an IAR to discuss their Program Account. IARs are an 33816_COL 11-05-2025 Page 19 of 20  information, such as wrong number of shares, wrong price, wrong account, executing the order as a buy rather than a sell and vice versa). The intent of the policies and procedures is to restore a client account to the appropriate financial position as determined in good faith by the Adviser based on what it considers reasonable in light of all relevant facts and circumstances surrounding the error. JPMS makes its determinations pursuant to its error policies and procedures on a case-by-case basis, in its discretion, based on factors it considers reasonable. Under certain circumstances, JPMS may consider whether it is possible to adequately address an error through cancellation, correction, reallocation of losses and gains or other means. F. Testimonials and Endorsements Program Accounts are offered and sold only through IARs associated with JPMS. In addition to compensating IARs for their provision of investment advisory services to clients on behalf of JPMS, and/or for their referral or introduction of investors who become advisory clients of JPMS, JPMS has entered into agreements with certain unaffiliated third parties (sometimes also called a “finder,” “referrer” or “promoter”) for their referral of prospective investment advisory clients to JPMS in accordance with the Advisers Act. Under these arrangements, JPMS agrees to pay each finder when a referred prospective client is either referred or becomes an investment advisory client of JPMS. JPMS either pays the finder a flat amount or a specified portion of the fee it receives and retains relating to each such client’s advisory account. In addition to the third-party referral agreements described above, pursuant to an agreement between JPMS and JPMCB, an affiliate, JPMCB can compensate its employees for referring clients to JPMS for various products and services, including the Program and other advisory products and services. G. Financial Information JPMS is not aware of any financial condition that is reasonably likely to impair JPMS’ ability to meet its contractual commitments to its clients, nor has JPMS been the subject of a bankruptcy petition at any time during the past 10 years. 33816_COL 11-05-2025 Page 20 of 20 

ITEM 9 — ADDITIONAL INFORMATION .............................................. 11 A. Disciplinary Information .......................................................... 11 B. Other Financial Industry Activities and Affiliations .................. 13 C. Material Relationships with Related Persons and Potential Conflicts of Interest.................................................................. 13 D. Participation or Interest in Client Transactions and Other FORM ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE J.P. MORGAN GUIDED ANNUITY PROGRAM J.P. Morgan Securities LLC November 5, 2025 Conflicts of Interest.................................................................. 14 E. Account Errors and Resolutions ............................................... 15 F. Code of Ethics .......................................................................... 15 G. Review of Program Assets ....................................................... 15 H. Testimonials and Endorsements .............................................. 16 Financial Information............................................................... 16 I. 383 Madison Avenue New York, NY 10179 (800) 392-5749 ITEM 4 — SERVICES, FEES AND COMPENSATION A. Description of Firm and Advisory Services chase.com/managed-account-disclosures jpmorgan.com/adv This wrap fee disclosure brochure (Brochure) provides information about the qualifications and business practices of J.P. Morgan Securities LLC (JPMS or the Firm) and the J.P. Morgan Guided Annuity Program (JPMGAP or the Program) that you should consider before investing in the Program. If you have any questions about the contents of this Brochure, contact us at 1-800-392-5749. 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. 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. 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 Financial Industry Regulatory Authority (FINRA). JPMS’ investment advisory services include sponsoring a variety of advisory programs. JPMS offers investment advisory services through several separate sales channels. Wrap fee programs that offer similar investment strategies are offered in the different sales channels and at different fee levels with different features. The investment adviser fee(s) you pay for investment advisory services will vary depending on the program you select. Annually we will provide you with a copy of our updated Form ADV wrap fee disclosure brochure relating to the Program or a summary of material changes from the brochure previously provided to you. Retain this document for future reference as it contains important information regarding your program assets with JPMS. You can obtain a copy of the current Brochure at any time by contacting your individual account representative. ITEM 2 — MATERIAL CHANGES This section describes the material and other changes to the Brochure since the Brochure dated March 28, 2025. for JPMS Many of the tools and analytics that are used to support services provided through the JPMS advisory programs are also available through JPMS without enrolling in an advisory program and paying a fee. Further, you could purchase these services separately from JPMS. However, while you can obtain similar products and services from JPMS without enrolling in an advisory program, you would not receive the same discretionary or non- discretionary investment advisory services offered through the advisory programs, the mutual funds share classes available to you could be more expensive, and you would generally not be able to obtain the same combination of financial planning and investment advisory services offered in certain advisory programs. The overall cost of purchasing the products and services separately will most likely differ from each advisory program’s advisory fees. You should consider the value of these advisory services when making such comparisons. The Form ADV Part 2A Brochure is available at chase.com/managed-account-disclosures or by contacting your JPMS financial advisor. ITEM 3 — TABLE OF CONTENTS for Private Client Advisor clients This Brochure provides information about JPMS and JPMGAP which is sponsored by JPMS and made available through a JPMS “Private Client Advisor,” “Wealth Advisor” or J.P. Morgan Private Bank “Investment Specialist” (collectively referred to herein as Financial Advisors and each, a Financial Advisor), each an investment advisory representative of JPMS. Information about other advisory programs sponsored by JPMS are contained in separate brochures, which can be obtained upon request from your Financial Advisor or at the SEC’s website at adviserinfo.sec.gov. JPMS also maintains separate websites, available at chase.com/managed- account-disclosures and jpmorgan.com/adv for Wealth Advisor and Investment Specialists’ clients, that contain the wrap fee Program brochure for the Program and other important disclosures as well as the advisory brochures for J.P. Morgan Private Investments Inc. (JPMPI) and J.P. Morgan Investment Management Inc. (JPMIM). ITEM 2 — MATERIAL CHANGES ............................................................ 1 ITEM 3 — TABLE OF CONTENTS ........................................................... 1 ITEM 4 — SERVICES, FEES AND COMPENSATION ................................ 1 A. Description of Firm and Advisory Services ............................. 1 B. J.P. Morgan Guided Annuity Program .................................... 2 C. Program Description .............................................................. 2 D. Client Profile and Investing in the Program ........................... 2 E. Confirmations, Statements and Reporting ............................. 3 F. Proxy Voting, Corporate Actions and Other Legal Matters..... 3 G. Program Advisory Fees .......................................................... 3 ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........... 5 A. Program Minimums ................................................................ 6 ITEM 6 — PORTFOLIO MANAGER SELECTION AND EVALUATION ..... 6 A. Use of J.P. Morgan Funds and Potential Conflicts of Interest ..... 7 ITEM 7 — CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .................................................................................. 11 ITEM 8 — CLIENT CONTACT WITH PORTFOLIO MANAGERS .............. 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 33814_COL 11-05-2025 Page 1 of 16  from those Funds made available in the Annuity Contract, including third- party Funds and J.P. Morgan Funds. J.P. Morgan Personal Advisors: JPMS sponsors an advisory program that is not described in this Brochure. It offers investment strategies that are similar to investment strategies available in the Program Accounts, at lower fees and features including financial planning and tax harvesting not available in the Program Accounts. J.P. Morgan Personal Advisors is offered through JPMS Financial Advisors. It does not provide the same level of services and does not offer the same range of investment strategies, options or customization available in the Program Accounts. J.P. Morgan Guided Annuity Program B. JPMGAP is an advisory program designed to address different investment needs and that offers a variety of strategies and asset allocations. Clients invest in the Program by establishing a brokerage or brokerage with custody account (Funding Account) with J.P. Morgan. JPMS has retained its affiliate, JPMPI, as non-discretionary sub-adviser (the Sub-Adviser) for the Program. The Sub-Adviser approves Funds eligible for investment through the Program, defines target asset allocation, and provides asset allocation ranges for the Models offered through the Program. The asset allocation and Fund approvals are subject to the oversight of, and pursuant to, an investment policy statement established by JPMS. JPMPI does not manage JPMGAP Program assets on a discretionary basis. Instead, each client directs the investment of the client’s JPMGAP Program assets across each selected asset class into one or more Funds. Each Model consists of Funds in a number of asset classes. Depending on the Model selected, clients choose one or more Funds in each asset class. Each asset class in a Model has a specific allocation range, and the client designates the specific asset allocation percentage desired for each asset class. JPMS is responsible for determining whether a JPMGAP Model, the allowable ranges in each JPMGAP Model, and the individual Funds in JPMGAP are suitable for each client. Funds available through JPMGAP include both J.P. Morgan Funds and non- J.P. Morgan Funds. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. Clients of JPMGAP should review the applicable prospectuses for Funds for additional information. D. Client Profile and Investing in the Program The Program is made available in conjunction with the J.P. Morgan Multi- Asset Choice Individual Flexible Premium Deferred Variable Annuity Contract and J.P. Morgan Multi-Asset Choice New York Individual Flexible Premium Deferred Variable Annuity Contract (the Annuity Contract) issued by a third-party insurance company (the Insurance Company). To purchase the Annuity Contract, a purchaser must be an investment advisory client of JPMS and pay a fee to JPMS or its affiliates for investment advisory services. The Insurance Company has established a separate account (the Variable Account) to hold assets allocated to variable investment options by owners of the Annuity Contracts (the Contract Owners). The Variable Account is divided into separate sub-accounts (each, a Sub-Account), each of which invests in a separate mutual fund (each, a Fund and collectively, the Funds). The Insurance Company uses the assets of each Sub-Account to buy shares of the Funds based on Contract Owner instructions. A Contract Owner may allocate their investments among a variety of Sub- Accounts. A Contract Owner is not a shareholder of the Funds in which the Sub-Accounts invest. Prior to investing in the Program, the Financial Advisor consults with the client or prospective client to create a “Client Profile” based upon the client’s responses to questions regarding their financial situation, investment experience, investment objectives, time horizon and risk tolerance. The information is evaluated and incorporated into the SIP. The client is provided with a recommendation of one or more Models, with the specific Funds that are included in the Model. The recommendation is the result of an objective scoring system based on the client’s responses to questions used to create the Client Profile referenced above. Based on the information in the Client Profile and SIP, the Financial Advisor will assist the client in selecting a Model and will discuss the recommendation with the client to ensure that it is appropriate for their specific investment needs and risk tolerance. The client agrees to the terms of applicable advisory service agreement. The client’s selection of a Model is reflected in the SIP. In conjunction with the purchase of the Annuity Contract, JPMS offers the Program which provides investment advisory services with respect to the Funds available under the Annuity Contract. Under the Program, as Contract Owner, the client will invest any Annuity Contract assets across each selected asset class into one or more Funds made available under the Annuity Contract with the advice of JPMS. JPMS or an affiliate acts as investment adviser, sub-adviser, administrator or distributor to some of the Funds in the Program (J.P. Morgan Funds). The Program is not a part of the Annuity Contract and is not endorsed or affiliated with the Insurance Company. important information about each Fund, including investment For objectives, risks, charges and expenses, clients can read each Fund’s prospectus carefully and consider all the information in it before investing. JPMGAP Model Selection The Program enables clients to receive ongoing investment advice and related services, including performance and transaction reporting, in connection with your Annuity Contract for an asset-based fee (Program Fee). Participation in the Program may cost more or less than purchasing these services separately. Benchmarks Once the client selects a Model, the client will select the specific Funds in each asset class of the client’s Model. A Model can contain no more than thirty funds. The selected Funds and their percentage allocation will be entered on the SIP. Clients can change the selected Funds and the percentage allocation of any asset class within the ranges for the applicable Model after giving instructions to the Financial Advisor. important information about each Fund, including Some investment strategies and Funds manage to a benchmark or index. Client portfolio holdings may differ significantly from the securities in the benchmark or index and may also hold far fewer securities than the benchmark or index. As a result, client portfolios can have higher or lower levels of risk and volatility than that of the benchmark or index. C. Program Description For investment objectives, risks, charges, and expenses, clients can read each Fund’s prospectus carefully and consider all the information in it before investing. Implementation of Model by JPMS JPMGAP is a mutual fund asset allocation program managed and offered by JPMS in conjunction with the purchase by clients of an Annuity Contract issued by Insurance Company. In JPMGAP, clients invest Program assets across asset classes based on a recommended asset allocation model into one or more Funds offered under the Annuity Contract and available in the Program. Based upon information the client provides in the Selected Investment Portfolio (the SIP) concerning the client’s assets, investment objectives, earnings and financial needs and other pertinent information, JPMS will assist the client in determining the suitability of the Program and will recommend an asset allocation model (Model) utilizing Funds selected After the client invests in the Program, JPMS will implement the selected Model. JPMS is responsible for directing the Insurance Company to invest the client’s Annuity Contract assets in Sub-Accounts in accordance with the client-selected portfolio under the client’s Annuity Contract. Subject to the SIP, at the direction of JPMS, the Insurance Company will invest and reinvest the Program assets from time to time in the applicable Funds, including Funds to which JPMS or an affiliate or an outside broker, investment manager, or other bank or financial institution is providing investment management, custodial, transfer agency, or other products or 33814_COL 11-05-2025 Page 2 of 16  services. The Insurance Company uses the assets of each Sub-Account to buy shares of the Funds selected in JPMGAP by the client. Shares of the Funds are purchased by the Insurance Company at net asset value. Program accounts will be rebalanced only if the percentage variance at the asset class level exceeds a threshold amount that has been established as effective for rebalancing to the SIP. Funding the Program To rebalance the Program investments, at the direction of JPMS, the Insurance Company will transfer assets out of individual Sub-Accounts that are over weighted under the Annuity Contract into other Sub-Accounts that are underweighted until the holdings are consistent with the Fund percentage holdings in the most recent SIP. Over time, the Funds will appreciate (or depreciate) in value at different rates. Without rebalancing, the change in the percentages of each asset class held will change the level of risk from the risk level that is associated with the original Model. Changes in the sale of Fund shares or securities may generate taxable gains or losses in a client’s Program assets. The Annuity Contract can be funded from the client’s JPMS Funding Account and/or an annuity exchange (1035 exchange). Clients direct JPMS to debit the Funding Account and the funds are transferred to the Insurance Company to purchase the Annuity Contract. Clients funding the Annuity Contract with 1035 exchanges will meet the minimum initial purchase payment requirement if purchase payments equal to the required minimum are made over the course of the first year the contract is in force. The Annuity Contract will be issued in accordance with the Insurance Company’s processing standards. Custodian JPMS will not have custody of any funds held under the Annuity Contract, which are solely held by the Insurance Company’s Variable Account. The Variable Account of the Insurance Company, and not JPMS, is obligated to pay all amounts promised to Contract Owners under the Annuity Contracts. E. Confirmations, Statements and Reporting Generally, initial purchase payments are allocated according to the instructions on the application. However, in some states, the Insurance Company will allocate initial purchase payments to the Money Market Sub- Account during the free look period, a period of time during which you may terminate your contract without paying any surrender charges and receive a refund for the contract. After the free look period, the Insurance Company will reallocate the value of the Annuity Contract among the Sub-Accounts based on the instructions contained on the application. In other states, the Insurance Company will allocate initial purchase payments to the investment options based on the instructions contained on the application. Clients should contact their Financial Advisor or refer to the client’s Annuity Contract for state specific information on the allocation of purchase payments. For Variable Annuity positions, clients will receive periodic statements directly from the Insurance Company showing all transactions under the Annuity Contract during the preceding period, including beginning and ending balances and the Advisory Fee paid. Clients will also receive confirmations of each transfer or other transaction made under the Annuity Contract. Clients will also receive quarterly reports from JPMS containing general market commentary and analysis F. Proxy Voting, Corporate Actions and Other Legal Matters Beginning in December 2024, both the twelve and six month Dollar Cost Averaging Accounts (DCAs) will be available to initial purchase payments for new contracts. Dollar cost averaging is a service for a long-term transfer program that allows the Annuity Contract Owner to make regular, level investments over time. Dollar cost averaging involves the automatic transfer of a specific amount from the DCA to investment options. With this service, the Contract Owner benefits from the ability to invest in the investment options over a period of time, thereby smoothing out the effects of market volatility. Assets in the DCA will be credited an interest rate specified in the Annuity Contract at issuance. Assets in the DCA will not be charged a fee. Only cash can be used to fund the Annuity Contract from a Funding Account. Investment management will begin after JPMS has accepted the Annuity Contract into the Program and the Insurance Company accepts the client’s annuity application and funds the Annuity Contract. In the event that a client seeks to sell securities in a Funding Account in order to fund the Annuity Contract, clients should review the potential tax consequences of these liquidations with their tax professional before funding the Program by selling securities. JPMS does not provide tax advice. When liquidating securities for purposes of raising cash for the funding of the Program, we will be acting as your broker, not your investment adviser. Liquidations will be effected promptly as part of the purchase of the Annuity Contract and separate from acceptance in the Program. If a particular security cannot be liquidated, it will not be used to raise cash to fund Program assets and will be remain in the Funding Account. Rebalancing Clients, as Contract Owners of the Annuity Contract, are not shareholders of the Funds in which the Sub-Accounts invest; however, each client with assets invested in a Sub-Account is entitled to certain voting rights. The Insurance Company will vote Fund shares at Fund shareholder meetings based on voting instructions from clients, as Contract Owners, and will vote shares for which no instructions are received in the same proportion as those that are received. JPMS and JPMPI will not vote or instruct the Insurance Company on proxies (or give clients advice about how to vote proxies) relating to Program assets currently or formerly held. JPMS and its affiliates will not be responsible or liable for: (1) failing to notify a client of proxies; or (2) failing to send to a client, as applicable, proxy materials or annual reports where JPMS or its affiliates have not received proxies or related client communications on a timely basis or at all. Each client has the right and responsibility to take any actions with respect to any legal proceedings, including, without limitation, bankruptcies and contract owner litigation, and the right to initiate or pursue any legal proceedings, including, without limitation, contract owner litigation, including, with respect to transactions, Funds, securities or other investments held or the issuers thereof. Neither JPMS nor JPMPI is obligated to render any advice or take any action on a client’s behalf with respect to the Funds, securities or other property, or the issuers thereof, which become the subject of any legal proceedings, including, without limitation, bankruptcies and contract owner litigation, to which any Funds, securities or other investments held or previously held as Program assets, or the issuers thereof, become subject. In addition, neither JPMS nor JPMPI is obligated to initiate or pursue any legal proceedings, including, without limitation, contract owner litigation, with regard to Program assets, including, with respect to transactions, Funds, securities or other investments held or previously held, or the issuers thereof. Clients can choose to have their Program investments automatically reviewed for rebalancing, quarterly, semi-annually or annually. JPMS will also direct the Insurance Company to rebalance Program assets upon the adoption of a new SIP or upon client’s direction. G. Program Advisory Fees Program Advisory Fee In between reviews for rebalancing, a client’s Program assets will drift from the initial asset allocations selected by the client and can even drift outside of recommended thresholds of a Model. Clients pay an annual asset-based Advisory Fee for the Program (Program Advisory Fee) to JPMS pursuant to the applicable fee schedule and subject to any applicable discounts or adjustments. The fee schedule for the 33814_COL 11-05-2025 Page 3 of 16  Reimbursement of JPMPI as the Sub-Adviser JPMS reimburses JPMPI for its costs for providing investment services, including certain investment advisory and research services. Waivers, Reductions and Negotiated Fees Program is set forth below and expressed as annual percentages. Generally, all values used to determine the Advisory Fee described herein are based on the market value of the Program assets each business day. The Firm charges fees that it believes are reasonable, but these fees are not always the lowest available from other firms. Advisory Fees for partial billing periods upon inception or termination will be prorated. Fees and expenses withdrawn from Sub-Accounts, including Advisory Fees, will be displayed on client statements issued by the Insurance Company In its discretion, JPMS can negotiate, reduce or completely waive the Program Advisory Fee. Program Advisory Fees are discounted for employees of JPMS and its affiliates. From time to time, Advisory Fees can be increased. JPMS will promptly notify the client whenever a fee increase is made to the client’s Program assets. The Program Advisory Fee will be calculated beginning after JPMS has accepted the Program assets into the Program and the Insurance Company accepts the client’s annuity application and funds the Annuity Contract. The Program Fees can be more or less than the cost of paying for investment advice, administrative and reporting services separately, depending on the cost of these services if provided separately and the level of trading activity in the client’s Program assets. The Program Advisory Fee is an annualized asset-based fee that covers all advisory, administrative and related services provided by JPMS related to the Annuity Contract. The Program Advisory Fee will be payable monthly in arrears and is calculated based on the daily average value of the Annuity Contract during the month. The Program Advisory Fee for the first and last calendar months will be prorated over the number of days the Program Advisory services are in effect. Assets in the DCA will not be charged an Advisory Fee. Because the Program Advisory Fee is charged on all assets in the Program, in a low interest rate environment, a client can earn less interest on Program assets as cash or cash alternatives, such as money market funds, than the amount of the Fee the client is paying JPMS with respect to such assets, and therefore the client’s net yield with respect to such assets can be negative. Relationship Pricing Groups Clients provide written instructions to the Insurance Company to withdraw investment Advisory Fees from the Annuity Contract. To take withdrawals from the contract to pay Advisory Fees, JPMS and clients complete an authorization form specified by the Insurance Company. Once the authorization form is completed, JPMS may request a withdrawal(s) of the Advisory Fee via the Insurance Company’s Service Center without further approval from the client. A client may revoke the authorization form at any time by contacting the Insurance Company. JPMGAP account assets can be combined with other eligible programs (together, a Relationship Pricing Group) to determine the applicable fee percentage for each account in the Relationship Pricing Group unless prohibited by the terms of a Program or by rules or regulations such as ERISA. Because the accounts are subject to the same fee schedule, clients can qualify for a lower fee than the fee rate each account would be charged individually. Assets in the DCA will not be included in relationship pricing groups. Private Client Advisor Clients As described in the Prospectus for the Annuity Contract, the Insurance Company has received an Internal Revenue Service (IRS) private letter ruling that the payment of investment advisory fees directly from the Annuity Contract will not be taxable to the client as distributions from the Annuity Contract nor subject to the 10% penalty for early withdrawal, if the advisory fee payment meets certain specific requirements. If the ruling requirements, as stated in the Annuity Contract Prospectus are not met fully, certain payments of investment Advisory Fees from the Annuity Contract could be taxable. Clients should consult a tax professional for more information on tax treatment. 1 ADVISORY FEE SCHEDULE0F Asset Size Annual Fee 0–$249,999.99 1.45% Program accounts subject to the same fee schedule, fee calculation methodology, and under the same tax identification number are automatically linked for Advisory Fee calculations. Clients can request certain family member Program accounts be added to a Relationship Pricing Group. When the combined assets in the linked accounts are sufficient to reach the next Advisory Fee breakpoint, the client(s) will benefit from a lower overall fee. The combined Advisory Fee is then divided ratably and assessed over all of the related program account. All linked accounts within the same Relationship Pricing Group will have the same Advisory Fee rate applied, subject to applicable discounts. $250,000.00–$499,999.99 1.30% $500,000.00–$999,999.99 1.15% Wealth Advisor Clients $1,000,000.00–$1,999,999.99 1.00% $2,000,000.00–$4,999,999.99 0.75% $5,000,000.00–$9,999,999.99 0.65% $10,000,000.00–$14,999,999.99 0.55% At its discretion, JPMS negotiates the amount and calculation of the Fee based on a number of factors, including the type and size of the account, anticipated level of trading activity, services provided to the account, historical factors and/or the scope of the client’s relationship with JPMS, subject to certain internal guidelines. $15,000,000.00–$24,999,999.99 0.50% J.P. Morgan Private Bank Investment Specialist Clients $25,000,000.00–$49,999,999.99 0.40% > $50,000,000 0.30% No Minimum Fee No minimum fee requirement is applied to the Program assets. Program assets will be charged the appropriate fee percentage based on the asset value. J.P. Morgan may group more than one account together to determine the managed assets used to calculate the fee rate. When we do so, your fee rate for an account could be lower than if we considered the assets in only that account. The accounts we group together to determine the fee rate for one account might not be the same as the accounts we group together to determine another account’s fee rate. From time to time, we may change our policies on what accounts we group together. Method of Payment The Advisory Fee does not include various additional fees that can be incurred within a client’s Program assets, including, but not limited to, Fund fees and expenses, transfer taxes, and electronic fund and wire fees. The Program Advisory Fee will be deducted pro rata from all Sub-Accounts in which the client is then invested, unless other instructions are timely received prior to the deduction of such fees. 1 The applicable annual fee applies to the entire Annuity Contract value. 33814_COL 11-05-2025 Page 4 of 16  Annuity Contract Charges. The Annuity Contract will be subject to additional fees and charges including mortality, expense and administrative charges, and fees for selected riders as may become available under the Annuity Contract. Further information about charges under the Annuity Contract are available in the Prospectus for the Annuity Contract. as Contract Owners, will receive notice of any such changes that affect their contract. The Funds, which sell their shares to the Sub-Accounts pursuant to participation agreements, also may terminate these agreements and discontinue offering their shares to the Sub-Accounts. Refer to the Annuity Contract Prospectus for the list of available investment options for the Annuity Contract. Once a particular share class is made available for a particular Fund in a Program, only that share class can be purchased for that Fund. JPMS periodically reviews the share classes offered by Funds in the Programs but also relies on the Fund families to inform JPMS when and if these share classes will be made available. If JPMS identifies and makes available a class of shares for a Fund more appropriate than the class of shares previously made available for the Fund, to the extent allowed, JPMS will work with the Insurance Company to make that share class available through the Annuity Contract and instruct the Insurance Company to move client investments under the Annuity Contract to the appropriate share class of the same Fund. Operational and other considerations can affect the timing of the conversion of shares and can cause the timing or implementation of such conversions to differ between clients. Refer to the Annuity Contract Prospectus for the list of available Funds for the Annuity Contract. In addition, the Funds available under the Annuity Contract pay fees and expenses that are ultimately borne by clients (including, but not limited to, brokerage costs and management, administration and custody fees). Additionally, Funds held in the Program have annual investment advisory expenses, so clients actually incur two levels of investment management fees: indirect Fund investment advisory fees to the investment adviser of each Fund, and direct Program investment advisory fees to JPMS. If any of the foregoing Fund fees are for services performed by JPMS or its affiliates, JPMS or its affiliates will receive some or all of the revenue from the fee. These Fund fees and expenses are in addition to any Advisory Fees paid to JPMS and any fees received by the Sub-Adviser. Clients can review the applicable prospectuses for Funds in the Annuity Contract for additional information about these fees and expenses, including conflicts the Insurance Company may have regarding Funds offered under the Annuity Contract. JPMS and its affiliates collectively receive greater revenue if J.P. Morgan Funds are included in the Program, and therefore, JPMS and its affiliates have a conflict of interest in including J.P. Morgan Funds in the Program. Refer to "The Use of J.P. Morgan Funds and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. Fund Share Classes available in JPMGAP Some of the fund share classes available through the Program are not necessarily available to clients outside of the Programs. To the extent a client terminates participation in the Program, clients who terminate their Annuity Contract will not be eligible to continue to hold or purchase the share classes offered in the Program. Financial Advisor Compensation Mutual funds typically offer different ways to buy shares with different share classes that may assess different fees and expenses. JPMS strives to make available the most appropriate share class for each Fund, with the goal of generally obtaining the lowest cost share class. For certain Funds, the share classes with the lowest fee structures are not available in a particular Program (e.g., (1) the Fund family restricts access to these share classes or (2) the Insurance Company does not have an agreement with the Fund to distribute the share class in the Program). The Program is recommended to clients by Financial Advisors associated with JPMS who do not receive compensation for the sale of the variable annuity contract. Certain Financial Advisors are salaried employees, whereas other Financial Advisors receive a portion of the Advisory Fee paid to JPMS. For those Financial Advisors that receive a portion of the Advisory Fee, the exact portion of the fee paid to the Financial Advisor varies among Financial Advisors and can also depend upon each Financial Advisor’s overall revenue production. The type of compensation paid to Financial Advisors will not result in a change to a client’s Advisory Fee. Financial Advisors may discount the Program Advisory Fee, which, depending on a number of factors, could cause the Financial Advisor to earn reduced compensation associated with the discount. Financial Advisors subject to this reduction in compensation are incentivized to price Program assets at the stated fee schedule. Clients should be aware that the share class of a Fund available through the Annuity Contract may differ from the share class available to similar accounts managed by or held at JPMS or its affiliates and that certain lower cost Fund share classes may be available outside of the Program. Clients should contact their Financial Advisor(s) for information about any limitations on share classes available through the Program. JPMS, through its brokerage accounts or other programs, has arrangements with Fund companies that are described in the documents relevant to those brokerage accounts or other programs. Those documents include disclosure of conflicts associated with arrangements with the Funds or their affiliates with respect to those other accounts or programs. Financial Advisors have a number of opportunities for selling products or services in their capacity as JPMS broker-dealer registered representatives or insurance agents. Depending on a number of factors (e.g., the size of the Program investment, changes in its value over time, the number of transactions, and the ability to negotiate fees and commissions), the amount of compensation received by certain Financial Advisors and the Firm from Program assets can be more or less than JPMS and the Financial Advisor would receive if the client paid separately for investment advice, and administrative and other services. Financial Advisors, for themselves and the Firm, have a financial incentive to recommend the Program, especially when the Advisory Fee would be more than if the services were provided separately or if the client had purchased a different advisory program sponsored by JPMS. In certain cases, other annuity contract options (i.e., investing in a commissioned-based variable annuity) may be more economically advantageous for clients. ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Depending on the Fund and Fund share class, Funds and/or Fund affiliates pay financial intermediaries such as the Insurance Company for various purposes, including payments for the services provided and expenses incurred in shareholder servicing, recordkeeping, promoting, marketing and administering the Annuity Contracts and the Funds. These payments could include fund fees pursuant to Rule 12b-1 of the Investment Company Act of 1940 allowing funds to pay the costs of marketing and distribution (12b-1 Distribution Fees), other shareholder servicing or recordkeeping fees, and payments made by Fund affiliates from their revenues for certain services (Servicing Fees). Currently, none of the Funds available through the Annuity Contract pay 12b-1 Distribution Fees, and JPMS and its affiliates do not receive Servicing Fees from the Funds or their affiliates in connection with the Program. To the extent JPMS would receive 12b-1 Distribution fees from any Fund, it will rebate these fees to the client. Refer to the Annuity Contract prospectus for information on types of payments the Insurance Company receives from the Funds. JPMS has established minimum requirements for client’s Program assets. JPMS offers and sells the Program to individuals and trusts. Private Client Advisor Clients whose Program assets address becomes a non-U.S. address will generally have their Program Advisory Services terminated from the Program. The Insurance Company has additional client information The particular Funds available under the Annuity Contract may change from time to time. Specifically, Funds or Fund share classes that are currently available may be removed or closed off to future investment or Funds or share classes of currently available Funds may be added. Clients, 33814_COL 11-05-2025 Page 5 of 16  requirements for non-U.S. addresses. The Program is not available to IRAs or to qualified retirement plans subject to ERISA. subject to the oversight of and pursuant to an investment policy statement approved by JPMS. the Sub-Adviser reviews with JPMS The Program is not intended for investors who have a short-term time horizon (or expect ongoing and significant withdrawals) or who expect or desire to maintain consistently high levels of cash or money market funds. Periodically, their Fund recommendations for the Program. JPMS determines the number of Funds in an asset class and the overall design of the Program. Program Minimums Asset Allocation Process Program minimums are subject to waiver in JPMS’ discretion and are waived from time to time. If a client’s Program assets falls below the Program minimum, JPMS can terminate the Program Advisory Service at its discretion. In the event that the Program Advisory Service is terminated, the Annuity Contract will remain in effect. The minimum initial purchase payment for the Annuity Contract is $50,000. Clients funding the Annuity Contract with 1035 exchanges, will meet the minimum initial purchase payment requirement if purchase payments equal to the required minimum are made over the course of the first year the contract is in force. The minimum subsequent purchase payment for the Annuity Contract is $5,000. Some states have different initial and subsequent purchase payment amounts, and minimum subsequent purchase payments may not be permitted in all states. Consult the Annuity Contract Prospectus for more information. The Sub-Adviser is responsible for establishing and updating the overall strategic and tactical asset allocations for the Models. Asset allocations are based on the firm’s long-term capital market assumptions as well as correlation between asset classes. Each Model’s asset allocation mix is selected to have the appropriate level of risk and return for such Model. This process includes several internal forums. These asset allocations generally are the overall basis for the process described below. The JPMPI personnel who perform these functions are shared with JPMorgan Chase Bank, N.A. (JPMCB), an affiliate of JPMS, and perform substantially similar services for other clients. The Sub-Adviser periodically reviews the Program composition and asset allocation and performance of the Models with JPMS. The Sub-Adviser periodically reviews the Sub-Adviser’s investment activities in the Program. After the effective date of any material changes to the target asset allocation or approved asset allocation ranges for a Model, JPMS notifies affected clients of the changes and whether clients need to rebalance to the updated asset allocation. If a client wishes to conform the SIP to the revised Model, the client should contact the Financial Advisor to effect any necessary changes. Research Process If withdrawals from the Annuity Contract cause the contract value to fall below the required minimum, JPMS may terminate the client’s participation in the Program and will be under no obligation to recommend or take any further actions as to the Annuity Contract. JPMS’ termination of the advisory agreement will not terminate the Annuity Contract. If the Program Advisory Service is terminated, JPMS will no longer be broker of record for that client and the client’s Annuity Contract will become an account maintained directly with the Insurance Company. ITEM 6 — PORTFOLIO MANAGER SELECTION AND EVALUATION Sub-Adviser Method of Analysis Set forth below is a general description of the primary methods of analysis that the Sub-Adviser utilizes for the Program. This description is not intended to serve as Fund or Program guidelines. 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, the Sub-Adviser and the manager solutions team of JPMPI or any of its affiliates are not responsible for the performance of any Fund (including any J.P. Morgan 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, the Sub-Adviser and the Manager Solution Team cannot ensure that a given Model’s investment objective will be attained. The Sub-Adviser uses research from the JPMPI manager solutions team of JPMPI or any of its affiliates to research, select and monitor Funds for the Program. The manager solutions team of JPMPI or any of its affiliates is comprised of employees of JPMCB and other affiliates. Specialists on the manager solutions team 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 and 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 both J.P. Morgan and non-J.P. Morgan 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 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 managed strategies, which typically will include J.P. Morgan managed strategies when there is one in the desired asset class. The manager solutions team of JPMPI or any of its affiliates utilizes both quantitative and/or 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 for the Program. 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. For information on how the Insurance Company makes Funds available under the Annuity, refer to the Annuity Contract Prospectus. Centralized Due Diligence Sub-Advisory Responsibility The Sub-Adviser’s Manager Solutions and operational due diligence teams provide two types of research to research, select and monitor Funds. An operational due diligence review is performed on Funds identified through both the Qualitative Research Process and Systematic Research Process. The Sub-Adviser does not engage portfolio managers to manage Program assets. Rather, clients select Funds and designate the specific asset allocation percentage desired for each asset class (within the approved asset allocation ranges). The Sub-Adviser is responsible for creating target strategic asset allocations and approved asset allocation ranges for each Model as well as for selecting Funds in each asset class to be made available to clients in JPMGAP, which are selected from Funds that are made available for use in JPMGAP by an internal governance forum. Clients designate the specific asset allocation percentage desired for each asset class (within the approved asset allocation ranges). Clients also select one or more Funds in each asset class they select for their own Accounts from those Funds available in the Program. JPMPI’s investment activities in JPMGAP are The first type, the “Qualitative Research Process,” approves Funds that are available for JPMGAP. An operational due diligence review is performed on Funds identified through the Qualitative Research Process. In the Qualitative Research Process, the manager solutions team of JPMPI or any of its affiliates conducts a qualitative analysis of Funds on an ongoing basis. The team reviews the portfolio manager’s organization, investment process, investment philosophy and performance. As part of the due diligence process, the Sub-Adviser also 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, and 33814_COL 11-05-2025 Page 6 of 16  Removal and Replacement of Funds conducts a periodic review to confirm the ongoing applicability of the designation of such funds and strategies as ESG strategies. JPMS determines the number of Funds in an asset class and the overall design of JPMGAP. Periodically, the Sub-Adviser reviews with JPMS changes to the JPMGAP composition, such as Fund additions, terminations, replacement funds and probations. The Sub- Adviser will make a new Fund available to Program clients upon JPMS’ request, if the Sub-Adviser seeks to fill a gap in the Funds available in the Program, or if a Fund is terminated and no Fund available in the Program is an appropriate replacement. Refer to the Annuity Contract Prospectus for the list of available Funds for the Annuity Contract. The second type, the “Systematic Research Process,” is used for JPMGAP. In the Systematic Research Process, Funds are evaluated using an internally developed quantitative screening process on an ongoing basis. This evaluation reviews the portfolio manager’s organization, investment process, investment philosophy and performance using only quantitative criteria. Funds may be removed from (or no longer be eligible for additional allocations) in the Program if they do not continue to meet these criteria. Funds subject to the Systematic Research Process may also go through the Qualitative Research Process. To the extent that Fund is reviewed through both processes, the results of the Qualitative Research Process will override the results of the Systematic Research Process. For example, if a Fund Manager does not meet the required quantitative criteria of the Systematic Research Process, the manager solutions team of JPMPI or any of its affiliates may alternatively review and approve it using the Qualitative Research Process and the Fund would then be available in the programs relying on the Systematic Research Process; also, if a Fund is terminated under the Qualitative Research Process, it will also be terminated in programs relying on the Systematic Research Process. Initial Fund Review and Approval The manager solutions team of JPMPI or any of its affiliates will determine, when appropriate, that a Fund be put on probation. A Fund in the Program that is on probation can be held by a client, but generally the Sub-Adviser will not recommend new allocations to the Fund in the Models until it is removed from probation. During the probation period, the Manager Solutions and operation due diligence teams will continue to review the Fund. Generally, if a Fund is terminated from the Program, JPMS shall, in its discretion, select another Fund in the same asset class as a replacement for the terminated Fund and shall instruct the Insurance Company to (i) transfer client’s investment in the terminated Fund to the replacement Fund, and ii) allocate future client purchases and rebalances that would have been allocated to the terminated Fund to the replacement Fund. JPMS will notify affected clients of the termination of a Fund from the Model and the applicable replacement Fund. Clients can choose to select another Fund available in the Program other than the replacement Fund to replace the terminated Fund. If the client selects another replacement Fund, JPMS will direct the Insurance Company to transfer Annuity Contract assets invested in the terminated Fund to the client-selected replacement Fund. If a rebalance or addition occurs before affected clients select a replacement fund, the JPMS-selected replacement fund will be used to allocate. Assets will remain in the JPMS selected replacement fund unless otherwise directed by the client. The internal governance forum approves or rejects new Funds to be made available for the Sub-Adviser to use in the Program. There can be Funds that are not available in the Program but that are available in other programs advised by JPMPI or its affiliates. The Manager Solutions and operational due diligence teams provide a formal presentation on prospective managed strategies to the governance forum for review. The internal governance forum is expected to consider the same factors in its review and approval process for J.P. Morgan and non–J.P. Morgan managed strategies. These factors include, 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. Program Information, Reports and Disclosures Model Portfolio Construction From the pool of strategies, the Sub-Adviser selects the combination of Funds that, in its view, fit each Model’s asset allocation goals and investment objectives. In making model portfolio construction decisions, the Sub-Adviser will consider and is permitted to prefer J.P. Morgan Funds if available under the Annuity Contract. Clients select one or more Funds in each asset class they select for their own Accounts from the Funds available in the Program. Information and reports provided by JPMS are not a substitute for regular annuity account statements and should not be used to calculate the fees or to complete income tax returns. JPMS relies on the Insurance Company to provide values of the applicable Funds available under the Annuity Contract. JPMS and its affiliates are entitled to rely on the financial and other information that clients, the Insurance Company or any other third party provides to JPMS. The client is solely responsible for any information that the client provides to JPMS, and JPMS shall not be liable in connection with its use of any information provided by the client, the Insurance Company or another third party in the periodic review. Portfolio Implementation JPMS and its Financial Advisors do not provide tax advice, and information and reports provided by JPMS should not be construed as advice concerning any tax matter. A. Use of J.P. Morgan Funds and Potential Conflicts of Interest JPMS is responsible for directing the Insurance Company to invest the client’s Annuity Contract assets in Sub-Accounts in accordance with the client-selected portfolio under the client’s Annuity Contract. Subject to the SIP chosen by the client, at the direction of JPMS, the Insurance Company will invest and reinvest the Program assets from time to time in the applicable Funds. Investment Principles and Potential Conflicts of Interest Ongoing Review of Approved Funds Another internal governance forum is responsible for the ongoing monitoring and oversight of Funds as approved and available for the Program. From time to time, this internal governance forum may place a Fund on probation or terminate a Fund from the Program as part of its ongoing monitoring and oversight responsibilities. The factors considered by the forum are expected to be the same for J.P. Morgan and non– J.P. Morgan managed strategies, as further described above under “Research Process” above. The Sub-Adviser also can, for portfolio construction reasons, remove a Fund from the Programs. Refer to the Annuity Contract Prospectus for the list of available Funds for the Annuity Contract. Conflicts of interest will arise whenever J.P. Morgan has an actual or perceived economic or other incentive in its management of our clients’ accounts to act in a way that benefits J.P. Morgan. Conflicts will result, for example (to the extent the following activities are permitted in the Program): (1) when J.P. Morgan invests in an investment product, such as a mutual fund, issued or managed by a J.P. Morgan affiliate, such as JPMPI; (2) when a J.P. Morgan entity obtains services, including trade execution and trade clearing, from a J.P. Morgan affiliate; (3) when J.P. Morgan receives payment as a result of purchasing an investment product for a client Program assets; or (4) when J.P. Morgan receives payment for providing services (including shareholder servicing, recordkeeping or custody) with respect to investment products purchased for a client Program assets. Other conflicts will result because of relationships that J.P. Morgan has with other clients or when J.P. Morgan acts for its own account. 33814_COL 11-05-2025 Page 7 of 16  Depending on the investments available in the Program, investment strategies are selected from both J.P. Morgan Funds and third-party asset managers and are subject to a review process by J.P. Morgan manager research teams. From this pool of investment strategies, J.P. Morgan portfolio construction teams select those investment strategies J.P. Morgan believes fit its asset allocation goals and forward-looking views in order to meet the investment objective of the investment strategy or portfolio. J.P. Morgan may allocate a portion of Program assets to J.P. Morgan Affiliated Funds. That portion varies depending on market or other conditions and the availability of Funds under the Annuity Contract. 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, embargoes, tariffs, sanctions and other trade barriers, regulatory events, other governmental trade or market control programs, and related geopolitical events. 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, pandemics or endemics. When J.P. Morgan selects J.P. Morgan Funds for client Program assets, J.P. Morgan receives a fee for managing the J.P. Morgan Funds. As such, J.P. Morgan will receive more total revenue when cash in a client’s Program assets is invested in J.P. Morgan Funds than if it was invested in third-party funds. JPMS and JPMPI address this conflict through disclosure to clients and through the investment process described in Item 6 herein. For important information about each J.P. Morgan Fund, including investment objectives, risks, charges and expenses, clients can read each Fund’s prospectus carefully and consider all the information in it before investing. J.P. Morgan Funds and Third-Party Funds – Other Fees and Expenses Infectious Disease Risk. The effects of any future pandemic or other global events to business and market conditions may have a significant negative impact on the performance of the separately managed accounts and JPMorgan Affiliated Fund investments; increase separately managed account and fund volatility; exacerbate pre-existing political, social and economic risks to separately managed accounts and JPMorgan Affiliated impact broad segments of businesses and Funds; and negatively populations. In addition, governments, their regulatory agencies or self- regulatory organizations, have taken or may take actions in response to a pandemic or other global events that affect the instruments in which a separately managed account or JPMorgan Affiliated Fund invest, 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 pandemic or other global events and the extent to which the associated conditions and government responses impact a separately managed account or JPMorgan Affiliated Fund will also depend on future developments, which are highly uncertain, difficult to accurately predict and subject to frequent changes. All Funds have various internal fees and other expenses that are paid by managers or issuers of the Funds or by the Funds themselves but that ultimately are borne by the investor. These fees and expenses are in addition to any fees paid to JPMS or received by an affiliate for acting as investment adviser. J.P. Morgan may receive administrative and servicing fees for providing services to both J.P. Morgan Funds and third-party Funds that are held as a client’s Program assets. Refer to the discussion of “Share Classes” in Item 4 above for more information on the receipt of administrative and servicing fees. Clients can review the applicable prospectuses for Funds (including Liquid Alternative Funds, as applicable) for more information about these fees and expenses. These payments may be made by sponsors of the Funds (including affiliates of J.P. Morgan), or by the Funds themselves, and may be based on the value of the Funds held by the client. Funds or their sponsors may have other business relationships with J.P. Morgan outside of its portfolio management role or with its broker-dealer affiliates of J.P. Morgan, which may provide brokerage or other services that pay commissions, fees and other compensation. J.P. Morgan Funds – Management Fees Regulatory Risk. There have been legislative, tax, and regulatory changes and proposed changes that may apply to the activities of JPMS that may require legal, tax and regulatory changes, including requirements to provide additional information pertaining to a client account to the Internal Revenue Service (IRS) or other taxing authorities. Regulatory changes and restrictions imposed by regulators, self-regulatory organizations and exchanges vary from country to country and may affect the value of client investments and their ability to pursue their investment strategies. Any such rules, regulations and other changes, and any uncertainty in respect of their implementation, may result in increased costs, reduced profit margins and reduced investment and trading opportunities, all of which would negatively impact performance. JPMPI or its affiliates may be sponsors or managers of Funds that are purchased in the program. In such case, JPMPI or its affiliates may receive a fee for managing such Funds. As such, JPMPI and its affiliates will receive more total revenue when the client’s portfolio is invested in such Funds than when it is invested in third-party funds. Risk of Loss 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. 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, or be otherwise harmful. J.P. Morgan typically incorporates human oversight to reduce the risk of acting on potentially defective outputs. AI Tools present Data Sources Risk, Cybersecurity Risk and Model Risk (as further 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. Further, J.P. Morgan uses on AI Tools developed by third parties, and J.P. Morgan may have limited visibility over the accuracy and completeness of such AI Tools. Set forth below are certain material risk factors that are associated with the Program. There are certain other risk factors described elsewhere in this Brochure. For a more complete summary of material risk factors and conflicts of interest associated with the Program, refer to the Sub- Adviser’s Form ADV Part 2A and/or any applicable prospectuses or other relevant disclosure documents. GENERAL RISKS 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 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 accuracy 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 the data to J.P. Morgan in compliance with applicable laws. J.P. Morgan does not make any express or implied warranties of any kind with respect to such 33814_COL 11-05-2025 Page 8 of 16  third-party data. J.P. Morgan shall not have any liability for any errors or omissions in connection with any data provided by third-party sources. AI Tools often use data feeds from a number of sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool will be unable to properly function or their operation may be adversely impacted. The 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. 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. 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, improper release, corruption and destruction of, or unauthorized access to, confidential 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 which 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 cybersecurity defenses or plans of its service providers, financial intermediaries and companies in which they invest or with which they do business. Use of AI Tools may lead to increased risks of cyber attacks or data breaches and the ability to launch more automated, targeted and coordinated attacks due to the vulnerability of AI technology to cybersecurity threats. Model Risk. Some Investment Strategies can include the use of various proprietary quantitative or investment models. Investments selected using models may perform differently than expected as a result of changes from the factors’ historical — and predicted future — trends, and technical issues in the implementation of the models, including, for example, issues with data feeds. Moreover, the effectiveness of a model may diminish over time, including as a result of changes in the market and/or changes in the behavior of other market participants. The operation of a model, similar to other fundamental, active investment processes, may result in negative performance, including returns that deviate materially from historical performance, both actual and pro-forma. For a model-driven investment process – and again similar to other, fundamental and active investment processes, there is no guarantee that the use of models will result in effective investment outcomes for clients. Additionally, client accounts with lower asset levels can experience some dispersion from the established models. Risks That Apply Primarily to ESG/Sustainable Investing Strategies 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. LIBOR Discontinuance Risk regulatory burdens. Because investing on 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 Investment approaches that incorporate environmental, social and governance (ESG) considerations or sustainable investing can include additional risks. ESG or sustainable investing strategies (together, ESG Strategies), including SMAs, 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 may invest in securities or industry sectors that underperform the market as a whole or underperform other strategies screened for ESG standards. 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 the basis of ESG/sustainability criteria can involve qualitative and subjective analysis, there can be no assurance that the methodology utilized 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. In addition to the ESG Strategies, J.P. Morgan also offers investment products that utilize ESG criteria in developing the product while seeking to maximize financial return. 33814_COL 11-05-2025 Page 9 of 16  When evaluating investments, an investment manager or investment adviser 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 or programs 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 judgement of a data provider that might not reflect subjective J.P. Morgan’s views or values and/or the views or values of the client. Further, 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. JPMS and its affiliates do 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 could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations, that could result in 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. 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 practices and the Advisor’s assessment of such practices can change over time. The application of category restrictions vary by asset class. Restrictions are not available for all strategies, and JPMS can reject a restriction if it deems the restriction to be unreasonable or not in line with the strategy. The number of restrictions that a client can select are limited based on the potential impact to the applicable investment strategy and potential deviation from the investment strategy. Only those restrictions that can be applied by JPMS will be applied. 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. J.P. Morgan takes a global approach to ESG and sustainable investing, and the solutions offered through our sustainable investing platform meet our internally developed criteria for inclusion in our sustainable investing platform and, where applicable, take into account ESG or sustainable investing regulations. As part of the due diligence process, the manager solutions team of JPMPI or any of its affiliates applies an eligibility framework that establishes minimum criteria for determining the universe of funds and strategies to be considered for inclusion in the ESG Strategies offered to our clients. Variable Annuity Risk. A variable annuity is a deferred annuity that provides investment returns based on the performance of Sub-Accounts. Variable annuities can lose value based on market performance. Before purchasing a variable annuity, review the annuity contract’s prospectus in detail for all the features, risks and benefits. Annuities are not FDIC insured and all guarantees are subject to the claims-paying ability of the insurance company. Annuity contracts are subject to federal income tax penalties for withdrawals prior to age 59½. 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 difference in 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 an investment to be classified as a “sustainable investment.” Unless otherwise specified and where permitted by applicable law, 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 Investments in Funds Risk. An investment in Funds is subject to the risks associated with the investment strategy of the particular Fund, as outlined in the Funds’ prospectuses. The investment performance of client program assets is directly related to the performance of the Funds chosen by clients for their Annuity Contract. There is no assurance that the Funds will achieve their investment objectives. Clients will bear their proportionate share of the Funds’ expenses. Funds could experience the following additional risks, including: 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. 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 may rely on information about a company, industry classification, industry grouping and/or issuer screening provided by J.P. Morgan, an affiliate service provider or a third party. Fund Liquidity Risk. A Fund may make investments that are illiquid or that may become less liquid in response to market developments or adverse investor perceptions. Illiquid investments may be more difficult to value. The liquidity of portfolio securities can deteriorate rapidly due to credit events affecting issuers or guarantors such as a credit rating downgrade or due to general market conditions or a lack of willing buyers. An inability to sell one or more portfolio positions, or selling such positions at an unfavorable time and/or under unfavorable conditions, can increase the volatility of a Fund’s net asset value (NAV) per share. Liquidity risk may also refer to the risk that the Fund will not be able to pay redemption proceeds within the allowable time period because of unusual market conditions, an unusually high volume of redemption requests, or other reasons. Liquidity risk may be the result of, among other things, the reduced number and capacity of traditional market participants to make a market in fixed income securities or the lack of an active market. The potential for liquidity risk may be magnified by a rising interest rate Category restrictions aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category; however, they do not exclude all companies with any tie or revenue derived from such restricted category. If a client holds an investment that is perceived to belong to the restricted category, such security will be sold and could result in a taxable event for the client. 33814_COL 11-05-2025 Page 10 of 16  ITEM 9 — ADDITIONAL INFORMATION A. Disciplinary Information environment or other circumstances where investor redemptions from money market and other fixed income mutual funds may be higher than normal, potentially causing increased supply in the market due to selling activity. JPMS has been involved in the following material legal or disciplinary events during the last ten years. Fund Management Risk. A Fund is subject to management risk if it is actively managed because it does not seek to replicate the performance of a specified index. Each Fund manager and its portfolio managers will utilize proprietary investment processes, techniques and risk analyses in making investment decisions, but there can be no guarantee that these decisions will produce the desired results. In addition, legislative, regulatory or tax developments may affect the investment techniques available to the fund managers in connection with managing a Fund and may also adversely affect the ability of a Fund to achieve its investment objective. Non-Diversified Fund Risk. If a Fund is non-diversified, it may invest a greater percentage of its assets in a particular issuer or group of issuers than a diversified Fund would. This increased investment in fewer issuers may result in the Fund’s shares being more sensitive to economic results among those issuing the securities. 1) On December 18, 2015, JPMS and JPMCB (together, Respondents) entered into a settlement with the SEC resulting in the SEC issuing an order (Order). The Respondents consented to the entry of the order that finds that JPMS violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 and Rule 206(4)-7, and JPMCB violated Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The Order finds that JPMCB negligently failed to adequately disclose (a) from February 2011 to January 2014, a preference for affiliated mutual funds in certain discretionary investment portfolios (the Discretionary Portfolios) managed by JPMCB and offered through J.P. Morgan’s U.S. Private Bank (the U.S. Private Bank) and the Chase Private Client lines of business; (b) from 2008 to 2014, a preference for affiliated hedge funds in certain of those portfolios offered through the U.S. Private Bank; and (c) from 2008 to August 2015, a preference for retrocession-paying third-party hedge funds in certain of those portfolios offered through the U.S. Private Bank. With respect to JPMS, the Order finds that from May 2008 to 2013, JPMS negligently failed to adequately disclose, including in documents filed with the SEC, conflicts of interest associated with its use of affiliated mutual funds in the Chase Strategic Portfolio (CSP) program, specifically, a preference for affiliated mutual funds, the relationship between the discounted pricing of certain services provided by an affiliate and the amount of CSP assets invested in affiliated products, and that certain affiliated mutual funds offered a lower-cost share class than the share class purchased for CSP. In addition, the Order finds that JPMS failed to implement written policies and procedures adequate to ensure disclosure of these conflicts of interest. Solely for the purpose of settling these proceedings, the Respondents consented to the Order, admitted to the certain facts set forth in the Order, and acknowledged that certain conduct set forth in the Order violated the federal securities laws. The Order censures JPMS and directs the Respondents to cease-and-desist from committing or causing any violations and any future violations of the above- enumerated statutory provisions. Additionally, the Order requires the Respondents to pay a total of $266,815,000 in disgorgement, interest and civil penalty. Liquid Alternative Funds Risk. Liquid Alternative Funds typically can invest in assets such as global real estate, commodities, derivatives, leveraged loans, start-up companies and unlisted securities that offer exposure beyond traditional stocks, bonds and cash. These funds provide a source of returns with a low correlation with the performance of traditional asset classes, such as equities and bonds. Liquid Alternative Funds utilize strategies similar to hedge funds, but are subject to regulatory limits on illiquid investments, leveraging and amounts that may be invested in any one issuer. However, Liquid Alternative Funds can trade more frequently and generally will hold more non-traditional investments and employ more complex trading strategies than traditional mutual funds. Liquid Alternative Funds often have higher total expense ratios compared to traditional mutual funds plus higher annual operating expenses. Higher fees will negatively impact performance compared to traditional mutual funds. The risk characteristics of Liquid Alternative Funds can be similar to those generally associated with other alternative investments. In addition to the usual market and investment-specific risks of traditional mutual funds, Liquid Alternative Funds may carry additional risks based on the strategies they use and the underlying investments made by the Liquid Alternative Funds. These strategies may target specific returns or benchmarks and seek to mitigate or provide exposure to alternative asset classes. In general, Liquid Alternative Funds are speculative investments that have the potential for significant loss of principal. Investments in Liquid Alternative Funds are only available to certain clients who meet applicable eligibility and suitability requirements and in circumstances approved by JPMS. Because Liquid Alternative Funds involve speculative strategies, clients should fully understand the terms, investment strategy and risk associated with such Funds. For example, the use of aggressive investment techniques, such as futures, forward contracts, swap agreements, derivatives and options, can increase a Liquid Alternative Funds’ volatility and carries a high risk of substantial loss. ITEM 7 — CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS This Item is not applicable to the Program as it does not involve the engagement of Portfolio Managers. ITEM 8 — CLIENT CONTACT WITH PORTFOLIO MANAGERS Concurrently, on December 18, 2015, JPMCB reached a settlement agreement with the Commodity Futures Trading Commission (CFTC) to resolve its investigation of JPMCB’s disclosure of certain conflicts of interest to discretionary account clients of J.P. Morgan Private Bank’s U.S.-based wealth management business. In connection with the settlement, the CFTC issued an order (CFTC Order) finding that JPMCB violated Section 4o(1)(B) of the Commodity Exchange Act (CEA) and Regulation 4.41(a)(2) by failing to fully disclose to certain clients its preferences for investing certain discretionary portfolio assets in certain commodity pools or exempt pools, namely (a) investment funds operated by J.P. Morgan Asset Management and (b) third-party managed hedge funds that shared management and/or performance fees with an affiliate of JPMCB. The CFTC Order directs JPMCB to cease- and-desist from violating Section 4o(1)(B) of the CEA and Regulation 4.41(a)(2). Additionally, JPMCB shall pay $40 million as a civil penalty to the CFTC and disgorgement of $60 million satisfied by disgorgement to be paid to the SEC by JPMCB and an affiliate in a related and concurrent settlement with the SEC. a of the Order, go to sec.gov/litigation/ For copy admin/2015/33-9992.pdf. The JPMGAP Program does not engage portfolio managers to manage Program assets; clients select Funds for their Program assets. Clients will generally have no contact with the investment advisers of the Funds. JPMS personnel knowledgeable about the management of the JPMGAP Program are available for client consultation upon reasonable request. Financial Advisors can assist clients in contacting such personnel. 2) On or about July 28, 2016, JPMS and JPMCB entered into a Consent Agreement (Agreement) with the 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 33814_COL 11-05-2025 Page 11 of 16  5) 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 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 J.P. Morgan Funds; (ii) there was an economic incentive to invest CSP assets in J.P. Morgan 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 J.P. Morgan Fund share classes. Solely for the purpose of settling these proceedings, JPMS consented to the March 2020 Order, with no admissions as to liability. JPMS agreed to pay a total of $325,000 to resolve the KDFI investigation. 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. 3) In October 2018, JPMS submitted an 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) reasonably 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 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. 6) 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. 4) 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 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. 7) 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 33814_COL 11-05-2025 Page 12 of 16  the flow of information between JPMS and certain other affiliates, as more fully described below. 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. The use of affiliates to provide services to clients creates certain conflicts of interest for JPMS, JPMIM and JPMPI. Among other things, there are financial incentives for JPMS, JPMIM and JPMPI (and their affiliates), including its parent company, JPMC, to favor affiliated service providers over non-affiliated service providers, and compensation of supervised persons of JPMS, JPMIM and JPMPI generally is directly or indirectly related to the financial performance of JPMC. Affiliated Funds Funds, including money market funds, pay fees and expenses that are ultimately borne by clients. Clients can review the applicable prospectuses for Funds in the Program for additional information about these fees and expenses. These fees and expenses are in addition to the Advisory Fee. Refer to “Other Fees and Expenses” in Item 4 above for more information. Affiliates of JPMS provide investment advisory and other services to the J.P. Morgan Funds for compensation. Therefore, because JPMS and its affiliates will in the aggregate receive more revenue when Program assets are invested in J.P. Morgan Funds than they would receive if the Program assets were invested in non–J.P. Morgan Funds, JPMS has a conflict of interest when Program assets are invested in J.P. Morgan Funds. JPMS addresses this conflict through disclosure and subjecting the J.P. Morgan Funds and non-J.P. Morgan Funds to the investment process described in Item 6 above. Refer to “Use of J.P. Morgan Funds and Potential Conflicts of Interest” in Item 6 above for more information on the use of J.P. Morgan Funds. 8) 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. Distribution and Other Fees and Revenue Sharing B. Other Financial Industry Activities and Affiliations JPMS’ primary business is providing brokerage products and services as a bank-affiliated broker-dealer and making available to its customers, in addition to investment advisory services, a variety of bank, securities and insurance products through its affiliates. JPMS’ officers, managers and Financial Advisors spend the majority of their time in administrative or supervisory duties with broker-dealer activities rather than investment adviser activities. information about these arrangements JPMS receives distribution fees from certain mutual funds pursuant to Rule 12b-1 under the Investment Company Act of 1940. If JPMS receives 12b-1 fees on load-waived Class A shares, it will credit these fees to the client’s Program assets. JPMS, directly or indirectly, receives servicing or administrative fees for certain Funds that are held in a client’s Program assets. Refer to the discussion of “Share Classes” in Item 4 above for more information on the receipt of administrative and servicing fees. In addition, JPMS’ affiliates receive licensing fees for their indices used by unaffiliated ETFs or other product sponsors. JPMS has negotiated revenue sharing arrangements with a number of mutual funds and mutual fund families. Some of these mutual funds are available in the Program, and JPMS will receive additional revenue on either the mutual funds in the Program or on the initial purchase of these mutual funds. Some of the mutual funds make revenue sharing payments to JPMS for mutual funds held in brokerage accounts for which JPMS does not provide investment advisory services. Additional is available at jpmorgan.com/TheGuide. Financial Advisors are not compensated from JPMS’ receipt of shared revenues received from mutual funds. Ownership Interest in J.P. Morgan Stock JPMS is affiliated with several other SEC registered broker-dealers, investment companies, investment advisers, insurance agencies, mortgage companies and JPMCB. Other registered investment advisers, collectively referred to as “J.P. Morgan Asset Management,” are affiliated with JPMS under the common ownership by JPMC. One or more of these affiliated investment advisers, including, but not limited to JPMIM, an affiliated investment adviser, serve(s) as the investment adviser to various J.P. Morgan Funds. Program clients, by investing in J.P. Morgan Funds, should note that J.P. Morgan receives more overall fees. JPMS affiliates will benefit from such selection and/or purchase as the result of receipt of the investment Advisory Fees. JPMS addresses this conflict through disclosure to clients. JPMS can receive as additional compensation distribution (Rule 12b-1) fees on money market fund assets held in Program assets. If a client selects a money market fund for which an affiliate of JPMS serves as investment advisor, the client will pay both its pro rata share of the money market funds Advisory Fees paid to JPMS or an affiliate as well as the Advisory Fee on the assets invested in the money market fund. However, any 12b-1 fees received by JPMS will be credited to the client’s Program assets. C. Material Relationships with Related Persons and Potential Conflicts of Interest Certain asset management firms (each, an asset manager) through their funds currently hold a 5% or more ownership interest in J.P. Morgan publicly traded stock. This ownership interest presents a conflict of interest when J.P. Morgan recommends the funds that are managed or advised by the asset manager. J.P. Morgan addresses this conflict by disclosing the ownership interest of the asset manager and by subjecting the asset manager’s funds to a research process. Additionally, the Financial Advisors and portfolio managers that may recommend 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 February 26, 2025, the Vanguard Group, Inc. and BlackRock, Inc. hold more than a 5% interest in J.P. Morgan. JPMS has several relationships or arrangements with related persons that are material to its investment advisory business or to its clients in the Program. Below is a description of such relationships and some of the conflicts of interest that arise from them. JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest that may arise between JPMS and its affiliates. These policies and procedures include information barriers designed to prevent 33814_COL 11-05-2025 Page 13 of 16  J.P. Morgan’s Use of Index Products from providing JPMS’ clients from engaging in certain transactions and can also restrict investment opportunities that would otherwise be available to JPMS clients. For example, J.P. Morgan is often engaged by companies as a financial adviser, or to provide financing or other services, in connection with commercial transactions that are potential investment opportunities for JPMS’ clients. There are circumstances in which advisory accounts are precluded from participating in such transactions as a result of J.P. Morgan’s engagement by such companies. J.P. Morgan reserves the right to act for these companies in such circumstances, notwithstanding the potential adverse effect on JPMS’ clients. In addition, J.P. Morgan derives investment advisory, custody, ancillary benefits administration, prime brokerage, transfer agency, fund accounting and shareholder servicing and other services to JPMS’ clients, and providing such services to JPMS’ clients enhances J.P. Morgan’s relationships with various parties, facilitates additional business development, and enables J.P. Morgan to obtain additional business and generate additional revenue. The following are descriptions of certain additional conflicts of interest and potential conflicts of interest that are associated with the financial or other interests that JPMS and J.P. Morgan have in transactions effected by, with or on behalf of its clients. In addition to the specific mitigants described further below, JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest. In addition, many of the activities that create these conflicts of interest are limited and/or prohibited by law and are conducted under an available exception. JPMS or one of its affiliates develop or own and operate stock market and other indexes based on investment and trading strategies developed by JPMS or its affiliates or assist unaffiliated entities in creating indexes that are tracked by certain ETFs utilized by JPMS or an affiliate. Some of the ETFs for which an affiliate of JPMS acts as investment adviser (the JPM ETFs) seek to track the performance of these indexes. JPMS and its affiliates from time to time manage client accounts that invest in these JPM ETFs. In addition, JPMS and its affiliates manage client accounts which track the same indexes used by the JPM ETFs or which are based on the same, or substantially similar, strategies that are used in the operation of the indexes and the JPM ETFs. The operation of the indexes, the JPM ETFs and the client accounts in this manner gives rise to potential conflicts of interest. For example, client accounts that track the same indexes used by the JPM ETFs may engage in purchases and sales of securities relating to index changes prior to the implementation of index updates or the time as of which the JPM ETFs engage in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the JPM ETFs’ portfolios are only rebalanced on a periodic basis corresponding with the rebalancing of an index. These differences can result in the client accounts having more favorable performance relative to that of the index and the JPM ETFs or other client accounts that track the index. Other 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 JPM ETFs. JPMS and its affiliates have established certain information barriers and other policies to address the sharing of information between different businesses within JPMS and its affiliates, including with respect to personnel responsible for maintaining the indexes and those involved in decision-making for the JPM ETFs. JPMorgan Chase Bank, N.A. J.P. Morgan or JPMS’ related persons provide financial, consulting, investment banking, advisory, brokerage (including prime brokerage) and other services to, and receive customary compensation from, an issuer of equity or debt securities held by clients. Any fees or other compensation received by J.P. Morgan in connection with such activities will not be shared with the Program clients or used to offset fees charged to Program clients. Such compensation could include financial advisory fees, monitoring fees, adviser fees or fees in connection with restructurings or mergers and acquisitions, as well as underwriting or placement fees, financing or commitment fees, trustee fees and brokerage fees. JPMCB is a national banking association affiliated with JPMS and is subject to supervision and regulation by the U.S. Department of Treasury's Office of the Comptroller of the Currency. JPMCB provides investment management, trustee, custody and other services to both institutional and non-institutional clients. All (or substantially all) Financial Advisors are employees of JPMCB. In their capacities as employees of JPMCB and outside of the Program, Financial Advisors may market and sell to clients products and services of JPMCB and be compensated in connection with such sales. D. Participation or Interest in Client Transactions and Other Conflicts of Interest J.P. Morgan Acting in Multiple Commercial Capacities Additionally, from time to time, directors, officers and employees of JPMC serve on the board of directors or hold another senior position with a corporation, investment fund manager or other institution which may desire to sell an investment to, acquire an investment from or otherwise engage in a transaction with, JPMS clients. The presence of such persons in such circumstances may require the relevant person to recuse themselves from participating in a transaction or cause JPMS, a corporation, investment fund manager or other institution to determine that it (or its client) is unable to pursue a transaction because of a potential conflict of interest. In such cases, the investment opportunities available to JPMS clients and the ability of such clients to engage in transactions or retain certain investments or assets will be limited. Investing in Securities which JPMS or a Related Person Has a Material Financial Interest Recommendation or Investments in Securities that the Adviser or Its Related Persons Also Purchase or Sell JPMS and its related persons recommend or invest securities on behalf of its clients that JPMS and its related persons also purchase or sell. As a result, positions taken by JPMS and its related persons may be the same as or different from, or made contemporaneously or at different times than, positions taken for clients of JPMS. As these situations involve actual or potential conflicts of interest, JPMS has adopted policies and procedures relating to personal securities transactions, insider trading and other ethical considerations. These policies and procedures are intended to identify and mitigate actual and perceived conflicts of interest with clients and to resolve such conflicts appropriately if they do occur. The policies and procedures contain provisions regarding pre-clearance of employee trading, reporting requirements and supervisory procedures that are designed to address potential conflicts of interest with respect to the J.P. Morgan is a diversified financial services firm that provides a broad range of services and products to its clients and is a major participant in the global currency, equity, commodity, fixed income and other markets in which JPMS clients invest. J.P. Morgan is typically entitled to compensation in connection with these activities, and the Program clients will not be entitled to any such compensation. In providing services and products to clients other than JPMS’ clients, J.P. Morgan from time to time faces conflicts of interest with respect to activities recommended to or performed for JPMS clients on one hand and for J.P. Morgan’s other clients on the other hand. For example, J.P. Morgan has, and continues to seek to develop, banking and other financial and advisory relationships with numerous U.S. and non-U.S. persons and governments. J.P. Morgan also advises and represents potential buyers and sellers of businesses worldwide. JPMS clients have invested in, and in the future may invest in, such entities represented by J.P. Morgan or with which J.P. Morgan has a banking, advisory or other financial relationship. In addition, certain clients of J.P. Morgan, including JPMS clients, invest in entities in which J.P. Morgan holds an interest, including a J.P. Morgan Fund or J.P. Morgan ETF. In providing services to its clients and as a participant in global markets, J.P. Morgan from time to time recommends or engages in activities that compete with or otherwise adversely affect a JPMS client account or its investments. It should be recognized that such relationships can preclude 33814_COL 11-05-2025 Page 14 of 16  activities and relationships of related persons that might interfere or appear to interfere with making decisions in the best interest of clients, including the prevention of front-running. In addition, JPMS has implemented monitoring systems designed to ensure compliance with these policies and procedures. J.P. Morgan’s Proprietary Investments JPMS personnel must obtain approval prior to engaging in all covered security transactions, including those issued in private placements. In addition, JPMS personnel are not permitted to buy or sell securities issued by J.P. Morgan during certain periods throughout the year. Certain “Access Persons” (defined as persons with access to nonpublic information regarding JPMS recommendations to clients, purchases or sales of securities for client accounts) are prohibited from executing personal trades in a security at certain times. In addition, Access Persons are required to disclose household members’ personal security transactions and holdings information. These disclosure obligations and restrictions are designed to mitigate conflicts of interest that arise if Access Persons transact in the same securities as advisory clients. J.P. Morgan and any of its directors, partners, officers, agents or employees also buy, sell or trade securities for their own accounts or the proprietary accounts of J.P. Morgan. J.P. Morgan, within its discretion, can make different investment decisions and take other actions with respect to its proprietary accounts than those made for client accounts, including the timing or nature of such investment decisions or actions. Further, J.P. Morgan is not required to purchase or sell for any client account securities that it and any of its employees, principals or agents may purchase or sell for their own accounts or the proprietary accounts of J.P. Morgan. J.P. Morgan and its respective directors, officers and employees face a conflict of interest as they will have income or other incentives to favor their own accounts or the proprietary accounts of J.P. Morgan. Additionally, all JPMS personnel are subject to the J.P. Morgan firm-wide policies and procedures including those found in the J.P. Morgan Code of Conduct (the Code of Conduct). The Code of Conduct sets forth restrictions regarding confidential and proprietary information, information barriers, private investments, outside business activities and personal trading. All J.P. Morgan employees, including JPMS personnel, are required to familiarize themselves with, comply with and attest annually to their compliance with the provisions of the Code of Conduct’s terms as a condition of continued employment. E. Account Errors and Resolutions Where appropriate, JPMS and its affiliates generally address the conflicts disclosed in this Brochure through policies and procedures. G. Review of Program Assets Account errors, transactional errors and other operational mistakes occasionally occur in connection with the management of client Program assets. JPMS has developed policies and procedures that address the identification and correction of such errors and generally require that errors caused by JPMS and affecting a client's account be resolved promptly and fairly. Errors can result from a variety of situations, including processing or other functions (e.g., miscommunication of information such as incorrect rebalancing instructions). Clients have ongoing reasonable access, during normal business hours, to a Financial Advisor who are available for consultation regarding clients’ Program assets. Financial Advisors are an essential component of the Programs and provide clients with nondiscretionary advisory services and Program maintenance support. JPMS contacts clients at least annually to determine whether there have been any changes in the client’s financial situation, investment objectives or investment restrictions that would require changes to the client’s Program investments. To ensure that the Program and the selected Model remain suitable for the client, clients are instructed to promptly notify their Financial Advisor or JPMS of any material changes to their investment objectives and/or financial situation. The intent of the policies and procedures is to restore a client’s Program assets to the appropriate financial position as determined in good faith by JPMS based on what it considers reasonable in light of all relevant facts and circumstances surrounding the error. JPMS makes its determinations pursuant to its error policies and procedures on a case-by-case basis, in its discretion, based on factors it considers reasonable. Under certain circumstances, JPMS may consider whether it is possible to adequately address an error through cancellation, correction, reallocation of losses and gains or other means. F. Code of Ethics As most Program assets are managed in a similar manner according to the Model selected by the client, JPMS does not review individual trades or individual Program assets. As described in this Brochure, JPMS periodically reviews Model composition and the Funds available in the Program to ensure that the Models and Funds continue to meet the Program requirements. JPMS and JPMPI personnel who are knowledgeable about the management of client Program assets are available for client consultation upon reasonable request. JPMS has adopted a Code of Ethics (the Code of Ethics) pursuant to Rule 204A-1 under the Advisers Act. The Code of Ethics is designed to ensure that JPMS and its supervised persons comply with applicable federal securities laws and place the interests of clients first in conducting personal securities transactions. The Code of Ethics imposes certain restrictions on securities transactions in the personal accounts of covered persons to help avoid or mitigate conflicts of interest, as described more fully below. 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. General The Code of Ethics contains policies and procedures relating to: The information in this Brochure does not include all the specific review features associated with each Model and Fund. Clients are urged to ask questions regarding JPMS’ or JPMPI’s review process applicable to a particular Model or Fund, to read all product-specific disclosures, and to determine whether a particular Model or Fund is suitable for them in light of their circumstances, investment objectives and financial situation. • Account holding reports and personal trading, including reporting and pre-clearance requirements for all personnel of JPMS; • Confidentiality obligations to clients set forth in the J.P. Morgan privacy notices; • Clients will receive periodic statements directly from the Insurance Company showing all transactions under the Annuity Contract during the preceding period including beginning and ending balances and the Advisory Fee paid. Clients will also receive confirmations of each transfer or other transaction made under the Annuity. Refer to “Confirmations, Statements and Reporting” above. Conflicts of interest, which include guidance relating to restrictions on trading on material non-public information (MNPI). JPMS does not provide tax advice, and discussions with Financial Advisors and quarterly performance reports should not be construed as tax advice and are not a substitute for the careful review of tax reporting forms by clients. In general, the personal trading rules under the Code of Ethics require that accounts of JPMS personnel be maintained with an approved broker and that certain trades in reportable securities for such accounts be precleared and monitored by compliance personnel. The Code of Ethics also prohibits certain types of trading activity, such as short-term and speculative trades. 33814_COL 11-05-2025 Page 15 of 16  H. Testimonials and Endorsements The Program is offered and sold only through Financial Advisors associated with JPMS. Private Client Advisor Clients JPMS does not engage any unaffiliated third-party cash solicitation or referral arrangements to refer prospective new Program clients to JPMS for clients of Private Client Advisors. However, pursuant to an affiliate agreement between JPMS and JPMCB, JPMCB can compensate its employees for referring clients to JPMS Private Client Advisors for various products and services, including the Program and other advisory products and services. Any such payments to JPMCB employees shall not increase the total Advisory Fees paid by the client. JPMS Wealth Advisor Clients In addition to compensating certain supervised persons (including Wealth Partners and Wealth Advisors) for their provision of investment advisory services to clients on behalf of JPMS and/or for their referral or introduction of investors who become advisory clients of JPMS, JPMS has entered into agreements with certain unaffiliated third-party solicitors (sometimes also called “finders,” “referrers” or “promoters”) for their referral of prospective investment advisory clients to JPMS in accordance with Rule 206(4)-1 of the Advisers Act. Under these solicitation arrangements, JPMS agrees to pay each finder when a referred prospective client is either referred or becomes an investment advisory client of JPMS. JPMS either pays the finder a flat amount or a specified portion of the Fee it receives and retains relating to each such client’s advisory account. I. Financial Information JPMS is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to its clients, nor has JPMS been the subject of a bankruptcy petition at any time during the past 10 years. 33814_COL 11-05-2025 Page 16 of 16 

FORM ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE J.P. Morgan Securities LLC November 5, 2025 383 Madison Avenue New York, NY 10179 1-(800) 392-5749 chase.com/managed-account-disclosures D. Client Profile and Account Opening ............................................ 6 E. Trade Confirmations, Statements and Performance Reporting .. 8 F. Proxy Voting, Corporate Actions and Other Legal Matters ......... 8 G. Wrap Account Fees ..................................................................... 9 ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........... 14 A. Program Minimums ................................................................. 14 MFAP...................................................................................... 14 CSP ......................................................................................... 14 JPMCAP .................................................................................. 14 Advisory Program .................................................................. 14 FIAP ....................................................................................... 14 B. Cash Balances in Program Accounts ........................................ 14 ITEM 6 — PORTFOLIO MANAGER SELECTION AND EVALUATION ....... 14 A. MFAP, CSP and JPMCAP ........................................................... 14 B. Advisory Program and FIAP ..................................................... 16 C. Use of J.P. Morgan Funds and Investment Strategies and Potential Conflicts of Interest .................................................. 19 Client-Directed Advisory Programs Mutual Fund Advisory Portfolio ITEM 7 — CLIENT INFORMATION PROVIDED TO PORTFOLIO Unified Managed Account Programs Chase Strategic Portfolio J.P. Morgan Core Advisory Portfolio MANAGERS ...................................................................................... 27 ITEM 8 — CLIENT CONTACT WITH PORTFOLIO MANAGERS ................ 27 ITEM 9 — ADDITIONAL INFORMATION ................................................ 28 A. Disciplinary Information .......................................................... 28 B. Other Financial Industry Activities and Affiliations .................. 29 C. Material Relationships with Related Persons and Potential Separately Managed Account Programs Advisory Program Fixed Income Advisory Program Conflicts of Interest.................................................................. 30 D. Participation or Interest in Client Transactions and Other Conflicts of Interest.................................................................. 32 E. Account Errors and Resolutions ............................................... 33 F. Code of Ethics .......................................................................... 34 G. Review of Accounts .................................................................. 34 H. Testimonials and Endorsements .............................................. 35 Financial Information............................................................... 35 I. This wrap fee disclosure brochure (Brochure) provides information about the qualifications and business practices of J.P. Morgan Securities LLC (JPMS or the Firm) and our wrap fee investment advisory programs that you should consider before investing in any of the programs. If you have any questions about the contents of this Brochure, contact us at 1-800-392-5749. 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 — SERVICES, FEES AND COMPENSATION A. Description of Firm and Advisory Services 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. This wrap fee program ADV disclosure brochure applies to all of your JPMS wrap fee program advisory accounts, including any advisory accounts you open in the future with your J.P. Morgan Private Client Advisor or J.P. Morgan Financial Advisor referred to as an investment advisory representative (IAR). Annually we will provide you with a copy of our updated wrap fee program ADV disclosure brochure or a summary of material changes from the brochure previously provided to you. Retain this document for future reference as it contains important information if you decide to open new wrap fee program accounts with your IAR. You can obtain a copy of the current Brochure at any time by contacting your IAR. ITEM 2 — MATERIAL CHANGES This section describes the material and other changes to the Brochure since the last amendment dated September 11, 2025. for JPMS 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 wrap fee programs and providing certain consulting services to defined contribution plan sponsors. JPMS offers investment advisory services through several separate sales channels. Similar wrap fee programs that offer the same and similar investment strategies are offered in the different sales channels and at different fee levels with different features and with different execution experiences. For example, certain traditionally traded investment strategies available in the Advisory Program (as defined below) are available in the Managed Investment Services Program as a model at a lower manager fee, and the Liquidity Management Strategy is available in a different sales channel at a lower fee. The investment adviser fee(s) you pay will vary, depending on the Program you select. The Form ADV Part 2A Brochure is available at chase.com/managed-account-disclosures or by contacting your JPMS IAR. ITEM 3 — TABLE OF CONTENTS ITEM 2 — MATERIAL CHANGES .............................................................. 1 ITEM 3 — TABLE OF CONTENTS ............................................................. 1 ITEM 4 — SERVICES, FEES AND COMPENSATION .................................. 1 A. Description of Firm and Advisory Services ................................. 1 B. Wrap Fee Programs ................................................................... 2 C. Program Descriptions ................................................................ 3 Many of the tools and analytics that are used to support services provided through the JPMS advisory programs are also available through JPMS without enrolling in an advisory program and paying an advisory program fee. However, while you can obtain similar products and services from JPMS without enrolling in an advisory program, you would not receive the same discretionary or non-discretionary investment advisory services offered through the advisory programs; the mutual funds share classes available to you generally will be more expensive and you would generally not be able 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 33813_COL 11-05-2025 Page 1 of 35  Trade Execution to obtain the same investment advisory services offered in advisory programs. The overall cost will most likely differ from each advisory program’s advisory fees. You should consider the value of these advisory services when making such comparisons. Clients direct brokerage to JPMS. JPMS can designate another broker or dealer if it believes the other broker or dealer will provide better execution than JPMS or its clearing broker. Although JPMS has discretion to select brokers or dealers other than JPMS or its affiliates, JPMS generally places such trades through JPMS because the Advisory Fee (defined below), paid by each client Account, only covers execution costs on trades executed through JPMS or its affiliates. Execution costs include fees we pay to exchanges and/or regulatory agencies on certain transactions. Certain securities included in portfolios can be less liquid or are traded infrequently. To fulfill its duty to seek best execution of transactions for client Accounts, JPMS can select broker-dealers other than JPMS or its affiliates to affect a trade for a client Account, and any execution costs charged by non-JPMS broker-dealers will be paid by the client Account. Refer to “Trading Away and Associated Costs” for more detail. This Brochure provides information about JPMS and the wrap fee programs sponsored by JPMS that are available through IARs (these wrap fee programs are referred to herein as a Program or collectively as Programs). Information about other wrap fee programs sponsored by JPMS are contained in separate brochures, which can be obtained upon request from your IAR or at the SEC’s website at adviserinfo.sec.gov. JPMS also maintains a separate website, available at chase.com/managed-account-disclosures, that contains the wrap fee Program brochure for the Programs and other important disclosures as well as the advisory brochures for J.P. Morgan Private Investments Inc. (JPMPI) and J.P. Morgan Investment Management Inc. (JPMIM). JPMS’ primary objective in broker-dealer selection is to comply with its duty to seek best execution of orders for clients. Best execution does not necessarily mean the lowest commission or price, but instead involves consideration of a number of factors. In evaluating whether another broker or dealer will provide better execution, JPMS will take various criteria into consideration in assessing the provider including, but not limited to, its market making ability, net cost or net realization from trade, price per unit of security, reliability and financial stability. J.P. Morgan Personal Advisors: JPMS sponsors an advisory program that is not described in this Brochure. It offers investment strategies that are similar to investment strategies available in the Program Accounts, at lower fees and features including financial planning and tax harvesting not available in the Program Accounts. J.P. Morgan Personal Advisors is offered through JPMS Financial Advisors. It does not provide the same level of services and does not offer the same range of investment strategies, options or customization available in Program Accounts. B. Wrap Fee Programs In order to comply with principal trade restrictions, orders for the Programs are routed for agency execution. In connection with transactions executed for Program Accounts, when permitted by applicable law and JPMS policy, JPMS, acting on behalf of client Accounts, enters into transactions in securities and other instruments with or through JPMC, and causes Accounts to engage in principal transactions. A “principal transaction” occurs if JPMS, acting on behalf of client Accounts, knowingly buys a security from, or sells a security to, JPMS or its Affiliate's own account. Fractional Share Trading The Programs are wrap fee programs designed to address different investment needs and that offer, depending on the Program, a variety of investment strategies, including separately managed account (SMA) managers and asset allocations. Clients invest in one or more Programs by establishing one or more Program accounts (Account). Clients pay asset- based fees that cover investment management, execution, custody and reporting services. Comparable services may be available at lower aggregate costs on an “unbundled” basis through other firms. Advisory Program Model Manager Investment Strategies and Multi- Manager Investment Strategies utilize fractional share trading. Fractional share trading allows for the purchase and sale of fractional share positions of equity securities, closed-end funds, ETFs and other eligible securities which reduces tracking error relative to Investment Strategies by allowing accounts to invest closer to Investment Strategy allocations by not having to round security positions to whole shares. Fractional share trading is not available for the same Investment Strategies in other JPMS channels. Orders that include a fractional share quantity cannot be routed to an exchange or other market makers for execution. Therefore, the fractional share component of an order will need to be combined with an order from a JPMS facilitation account to make a whole share, which can then be routed for execution. This means that JPMS will be trading alongside the customer fractional share trade to facilitate the order, which will be routed out for execution in an agency capacity. JPMS will not act as a principal or counterparty to the customer account when executing these orders. In this Brochure, we refer to: mutual funds that hold more non-traditional investments and employ more complex strategies than traditional mutual funds as “Liquid Alternative Funds;” mutual funds, exchange traded funds, and Liquid Alternative Funds collectively as “Funds;” a single- or multi- asset class investment strategy(ies) as “Investment Strategy(ies);” asset allocation models as “Models;” investment advisers that act as non- discretionary model managers and provide a model portfolio to JPMS or JPMPI to implement as “Model Managers;” the Funds managed by affiliates of JPMS (currently, the affiliates that sponsor or manage J.P. Morgan Funds include JPMPI and JPMIM) as “J.P. Morgan Funds;” Funds managed by third parties as “non-J.P. Morgan Funds;” and affiliated or unaffiliated investment advisers that provide discretionary investment management in SMAs, and brokerage and reporting services in connection with the Accounts as “Portfolio Managers” (JPMIM and JPMPI, affiliates of JPMS, each act separately as a Portfolio Manager in certain of the programs, as described below). Overlay Manager and Sub-Adviser for MFAP, CSP and JPMCAP JPMS has retained an affiliate, JPMPI, as overlay manager (Overlay Manager) and discretionary sub-adviser (the Sub-Adviser) for the J.P. Morgan Core Advisory Portfolio (JPMCAP) and Chase Strategic Portfolio (CSP) Programs to provide portfolio implementation and coordination services for Program Accounts; and as non-discretionary sub- adviser for the Mutual Fund Advisory Portfolio (MFAP) Program. As part of the fractional share process, JPMS maintains a facilitation account that holds a small number of shares of eligible securities in inventory for sell orders and keeps cash on hand for buy orders. JPMS adds a fractional share to aggregated buy or sell orders so that the order is rounded up to whole shares, and the additional fractional share is purchased or sold by JPMS. Due to a variety of factors — such as the number of trades executed, allocating fractional shares to multiple clients at one time, and market price volatility — JPMS could accrue a net profit or loss in its fractional share facilitation account. Implementation Manager for Advisory Program Model Manager Investment Strategies JPMS acts as implementation manager (Implementation Manager) to provide portfolio implementation services for Model Manager Investment Strategies in the Advisory Program. JPMS is under no obligation to continue to offer fractional share trading in the future and, in its discretion, may discontinue fractional share trading at any time. Upon termination of a client account, fractional share positions will be sold and the proceeds placed in the sweep option applicable to the account. 33813_COL 11-05-2025 Page 2 of 35  certain Investment Strategies, tax-harvesting services may not be available. The availability of tax-harvesting functionality may be limited, depending on trading platform. For more information, refer to “Tax Risks and Risks That Apply to Tax-Aware, Tax-Harvesting and Tax-Managed Strategies” under Item 5. Fractional share trades where a “sell” order is submitted and JPMS does not hold any shares will require JPMS to purchase one share in the market before submitting the sell order to be able to round the fractional share up to a whole share before the order can be sent for execution. As such, there could be a delay in execution of such “sell” order while JPMS obtains a share to be able to submit the fractional share trade order. C. Program Descriptions Mutual Fund Advisory Portfolio (MFAP) As applicable, dividends are paid on fractional share positions. The dividend payable will be an amount proportionate to the fractional interest. Corporate Actions and Proxy Voting: Fractional shares participate in both mandatory corporate actions (e.g., stock splits, mergers) as well as voluntary corporate actions (e.g., tender offers). Refer to “JPMS as Implementation Manager of Model Manager Investment Strategies” for more detail. Fractional share positions are not eligible for proxy voting. Therefore, you will not have voting rights for any of the fractional shares held in your account. Clients will only be allowed to participate in proxy voting with respect to whole share positions. For additional information about fractional share trading, please contact your IAR. Benchmarks MFAP is a mutual fund and exchange-traded fund (ETF) managed account program managed and offered by JPMS. In MFAP, the client invests Program Account assets across each selected asset class into one or more open-end mutual funds or ETFs available in the Program. JPMS has retained JPMPI as the Program’s non-discretionary Sub-Adviser. The Sub-Adviser approves Funds eligible for investment through the Program, defines target asset allocation, and provides asset allocation ranges for the Models offered through the Program. The asset allocation and Fund approvals are subject to the oversight of, and pursuant to, an investment policy statement established by JPMS. JPMPI does not manage MFAP account assets on a discretionary basis. Instead, each client directs the investment of the client’s MFAP Account assets across each selected asset class into one or more Funds. Each Model provides an asset allocation across a number of asset classes. Each asset class in a Model has a specific allocation range, and the client designates the specific Fund allocation percentages desired for each asset class. JPMS is responsible for determining whether an MFAP Model, the allowable ranges in each MFAP Model and the individual Funds in MFAP are suitable for each client. Some Investment Strategies and Funds manage to a benchmark or index. Client portfolio holdings may differ significantly from the securities in the benchmark or index and may also hold far fewer securities than the benchmark or index. As a result, client portfolios can have higher or lower levels of risk and volatility than that of the benchmark or index. Liquid Alternative Funds Funds available through MFAP include both J.P. Morgan Funds and non- J.P. Morgan Funds. Refer to “Use of J.P. Morgan Funds and Investment Strategies and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. Clients of MFAP should review the applicable prospectuses for Funds for additional information. Some Programs that make Liquid Alternative Funds available do so subject to asset threshold requirements. Liquid Alternative Funds refer to Funds that have one or more of the following characteristics: (1) hold non- traditional investments, (2) trade more frequently, and (3) employ more complex trading strategies and that have higher total expense ratios (plus higher annual operating expenses) than traditional mutual funds. Chase Strategic Portfolio (CSP) and J.P. Morgan Core Advisory Portfolio (JPMCAP) Retirement Accounts CSP and JPMCAP are unified managed account programs that are managed and offered by JPMS. Under CSP and JPMCAP, you establish a discretionary managed account that is invested in a manner consistent with one of the single or multi-asset class Investment Strategies JPMS makes available to clients. In addition, U.S.-focused Investment Strategies for Conservative, Balanced and Growth are offered in JPMCAP. For Program Accounts established for retirement plans subject to the Employee Retirement Income Security Act of 1974, as amended (ERISA) and for Individual Retirement Accounts (IRAs) (collectively, retirement accounts), when providing services under the Program, JPMS is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the Internal Revenue Code of 1986, as amended (IRC) with respect to the assets of the retirement accounts invested in the Program. Additionally, for retirement accounts that invest in Programs where JPMPI acts as Sub-Adviser or Portfolio Manager, JPMPI is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the IRC with respect to the assets that it manages in those Programs. Assets within an Investment Strategy are generally invested in each asset class through one or more funds and, depending on the Program, through a Model Manager or SMA that includes individual securities. Depending on the Program and the strategy selected, clients have the option to make certain elections, including municipal fixed income (for taxable Accounts), Liquid Alternative Funds, Model Managers, or non-J.P. Morgan Funds and unaffiliated Model Managers, as described further below. Overlay Manager Retirement accounts can be restricted from investing in Funds that have a certain relationship with J.P. Morgan. As a result, performance of retirement accounts can differ from non-retirement accounts invested in the same strategy. Tax Consequences and Tax Harvesting When client elections result in the sale of securities, when Accounts are funded with securities, or when Funds are removed or replaced in a client portfolio, clients may incur redemption charges and taxable gains or losses. Clients should consult their own tax professional when making these decisions. JPMS and its affiliates do not provide tax advice. JPMS has retained JPMPI as the Program’s Overlay Manager for CSP and JPMCAP. JPMPI, as the Program Overlay Manager for the programs, provides services including: (1) managing the Accounts on a discretionary basis by implementing instructions to purchase, hold, or sell securities or shares of Funds; (2) continuously monitoring the Account holdings and coordinating the trading activity; (3) implementing specific reasonable restrictions requested by the client that are placed on the client Account; and (4) generally rebalancing the Program Account to the allocation in a chosen Investment Strategy when the asset allocation percentages deviate from established parameters. JPMPI does not have any responsibility or liability for JPMS’ determinations that the Investment Strategy selected by the client is suitable in light of the client’s investment objectives and financial situation. If a client requests tax harvesting, the Implementation Manager, the Overlay Manager or the Portfolio Manager can sell certain investments at a gain or loss to offset the client’s tax liability. If utilizing tax harvesting, the client’s account holdings can differ from those accounts that do not utilize such election; therefore, performance will likely differ. The Implementation Manager, the Overlay Manager or the Portfolio Manager may reject a client’s request for tax harvesting in whole or in part, at its discretion. For 33813_COL 11-05-2025 Page 3 of 35  CSP In providing services to JPMS, JPMPI can rely on affiliated and unaffiliated third parties to fulfill its services as Overlay Manager. On January 9, 2016, CSP was closed to new investors; however, existing CSP clients can continue to hold their Accounts and add new assets. On the same date, JPMS commenced offering a similar unified managed account, J.P. Morgan Core Advisory Portfolio. JPMS, in its discretion, may allow for existing CSP client assets to be retitled in certain limited circumstances. JPMCAP J.P. Morgan Funds and non-J.P. Morgan Funds are available in the programs. Currently, a substantial portion of the assets in the programs are invested, or expected to be invested, in J.P. Morgan Funds. For CSP, JPMIM is the only SMA or Model Manager, and no unaffiliated Model Managers have been evaluated or selected for inclusion in CSP. For JPMCAP, unaffiliated and affiliated Model Managers can be evaluated and selected for JPMCAP Accounts. Refer to “Use of J.P. Morgan Funds and Investment Strategies and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds and affiliated SMAs and Model Managers. The Form ADV Part 2A for JPMIM is available at the SEC’s website at adviserinfo.sec.gov. Municipal Fixed income (for taxable Accounts) For taxable (non-retirement) Accounts, clients can elect to substitute tax- aware investments for certain equities or municipal investment for some fixed income options. SMAs and Model Managers When a client elects to use Model Managers or SMAs, the opportunities available to such client differs from the opportunities available to clients who do not use Model Managers or SMAs. As a result, performance of an Account with this election can differ from the performance of other Accounts without this election. Due to this election, the asset allocation in these Models may be different from the asset allocation in those Models without this election. The Investment Strategy for a particular client is based on the client’s discussion with their IAR and the client’s risk tolerance. The Investment Strategies available in JPMCAP are Conservative, Balanced, Growth, Aggressive Growth, Managed Fixed Income and Managed Equities. In addition, U.S.-focused investment strategies for Conservative, Balanced and Growth are offered in JPMCAP. The Balanced ESG Investment Strategy primarily consists of Funds or other investments that consider ESG factors and/or focus on sustainable themes. The Conservative, Balanced and Growth Investment Strategies are generally available for clients regardless of whether they are eligible to include or have elected to include Liquid Alternative Funds or other securities through Model Managers in their Accounts. The Aggressive Growth Investment Strategies are only available to those clients who are eligible for and have elected to include Liquid Alternative Funds, or to include Liquid Alternative Funds and other securities through Model Managers, in their Account. Liquid Alternatives are not available in Managed Equities or Managed Fixed Income strategies. For more information on these Investment Strategies and related risks, clients should review the Sub-Adviser’s advisory brochure, which can be obtained upon request from their IAR, at chase.com/managed-account- disclosures, or at the SEC’s website at adviserinfo.sec.gov. The Investment Strategy for a particular client is based on the client’s discussion with their IAR and the client’s risk tolerance. For more information on Investment Strategies and related risks, clients should review the Sub-Adviser’s advisory brochure, which can be obtained upon request from their IAR, at chase.com/managed-account-disclosures, or a the SEC’s website at advisorinfo.sec.gov. The US Endowments & Foundations (E&F) Investment Strategy is designed to primarily service the investment goals of nonprofit entities (i.e., endowments and foundations). This Investment Strategy is made available to clients of IARs and is appropriate for a Growth investment strategy. The endowment investing approach is generally characterized by a longer-term investment horizon. A long-term investment mindset can allow a client to look through the short-term volatility and focus on the potential of enhancing long-term returns. 1 Available Investments0F F 1 Client Program Assets i 2 s d n u F l a u t u M 2 s F T E d u q i L e v i t a n r e t l A s d n u F r e h t O s e i t i r u c e S l e d o M h g u o r h t s r e g a n a M 3 Yes Yes No No $10,000 and over2F $250,000 and over Yes Yes No Yes, on client election JPMS and JPMPI (as Sub-Adviser) have full discretionary authority, to be exercised in their exclusive judgment and consistent with the Investment Strategy selected by the client; to determine the allocation of assets among Funds and, at appropriate asset levels, Liquid Alternative Funds (only available in JPMCAP), one or more SMA (only available in CSP) or Model Managers; to select, add, remove, or replace Funds or SMAs (only available in CSP) or Model Managers; and to purchase and sell Funds and other securities for the Account. JPMS has delegated this discretionary authority to JPMPI as the Program’s Sub-Adviser. JPMPI is an affiliate of JPMS and JPMIM. JPMPI as Sub-adviser determines strategic and tactical assets allocations, is responsible for security selection (i.e., selects the Funds, SMAs and Model Managers for investment), and determines portfolio construction. JPMPI, as sub-adviser of JPMCAP, from time to time may close investment strategies to new investments. JPMS oversees the selections using an investment policy statement and remains responsible for overseeing JPMPI’s performance. $750,000 and over Yes Yes Yes, on client election Yes, on client election Index-Oriented Vehicles The investment policy statement specifies investment guidelines designed by JPMS to address operational considerations. These operational considerations, such as Fund concentration and capacity issues, can affect the timing of certain tactical trades and can result in the timing or implementation of trades for a client’s Account differing from that of another client or group of clients of JPMS or its affiliates. JPMS and the Sub-Adviser prefer to follow an investment process that maintains the option of using a range of active and passive vehicles, some of which are Index-Oriented Vehicles (as defined below) and some of which are not. JPMCAP in the past offered certain clients, as described below, the 1 Does not include Legacy Models/Strategies (refer to “Transition and Legacy Accounts” above). 2 Clients that elected to have their Program accounts include Index- Oriented Vehicles (as defined below) so long as they had not elected to have their Program Accounts include Liquid Alternative Funds or other securities through Model Managers. 3 Certain Program Accounts with lower asset levels can experience some dispersion from the established Models. 33813_COL 11-05-2025 Page 4 of 35  option to implement certain Account Investment Strategies using an Index- Oriented Vehicle election. Currently, the Non-Proprietary Strategy Election is available for all JPMCAP Investment Strategies, including where clients are eligible for and have elected to include Liquid Alternative Funds or other securities through Model Managers in their Accounts. It is possible that the availability of this election will change in the future. When a client elects to exclude J.P. Morgan managed strategies, it can affect the ability to make investments, access asset classes, or take advantage of opportunities that are available to clients who do not make the Non-Proprietary Strategy Election. As a result, performance of an Account with an election can differ from the performance of other Accounts without an election. To the extent a client holds J.P. Morgan managed investments in an existing JPMCAP Account at the time of making the Non-Proprietary Strategy Election, sales of Funds can be subject to redemption fees. Transition Models JPMCAP Index-Oriented Vehicles (Passively Managed Vehicles) include ETFs and index mutual funds, and “Actively Managed Vehicles” include mutual funds, SMAs and investments in other securities through Model Managers. Actively managed vehicles typically charge higher management fees than passively managed vehicles. In determining whether a particular Actively Managed Vehicle or Passively Managed Vehicle can be considered an “Index-Oriented Vehicle,” the Sub-Adviser will, using due diligence and vehicle evaluation from its affiliates, consider, among other things, how closely the vehicle’s historical returns track the index the Sub-Adviser is targeting for the relevant asset class as well as the cost, liquidity and complexity of the vehicle’s strategy. The determination of whether a vehicle is an Index-Oriented Vehicle is in the Sub-Adviser’s sole discretion, is subject to change, and does not guarantee that an Index-Oriented Vehicle will perform in line with, or in excess of, the underlying index. The election does not apply to cash and liquidity Funds. reduce certain Certain affiliated investment accounts at JPMorgan Chase Bank, N.A. (JPMCB) that transferred into JPMS retained their asset allocation models tax (Legacy Models/Investment Strategies). To consequences, JPMS made additional models available to clients with Legacy Models/Investment Strategies (Transition Models) for clients requesting to change their Legacy Models/Investment Strategies. Transition Models are based on similar Investment Strategies as other JPMCAP Models. Certain portfolio holdings for Transition Models differ from the corresponding JPMCAP Models. Transition Models are not available to new Program accounts. When Accounts in Transition Models align with core JPMCAP Models, they may be moved to the corresponding core JPMCAP model. Advisory Program Clients who selected the Conservative, Balanced, or Growth Investment Strategies and who did not elect to include Liquid Alternative Funds or other securities through Model Managers, could have elected to use Index- Oriented Vehicles in their Accounts for asset classes other than cash and liquidity Funds. The election to have an Account implemented using Index- Oriented Vehicles was not available for Accounts invested in Aggressive Growth, Managed Fixed Income or Managed Equities Investment Strategies. This election directs the Sub-Adviser to use Passively Managed Vehicles except when, in JPMPI’s judgment, active management is expected to closely reflect an underlying index and either (i) to better reflect the overall characteristics of the underlying asset class or market segment, or (ii) is necessary to implement the client’s instructions. Clients who elected to have their Accounts implemented using Index-Oriented Vehicles had to also elect having their Accounts implemented using non-J.P. Morgan Funds and unaffiliated Model Managers, as defined and further described below. Currently, clients that selected the Index-Oriented Vehicle election will not be invested in any J.P. Morgan Funds (except for J.P. Morgan sweep vehicles; refer to “Cash Allocations and the Sweep Feature” below for more detail) or affiliated Model Managers. The Advisory Program provides JPMS clients with access to affiliated and unaffiliated Portfolio Managers and Model Managers, each of whom offers a specific Investment Strategy (equity and fixed income) and market sector expertise. Currently, the only affiliated Portfolio Managers and Model Managers are JPMIM and JPMPI. Clients select the Portfolio Manager or Model Manager and Investment Strategy from among the Portfolio Managers, Model Managers and Investment Strategies made available by JPMS. If the client made an election for Index-Oriented Vehicles for an existing JPMCAP Account, sales of Funds could be subject to redemption fees. There can be a period of time during which non–Index-Oriented Vehicles remain in a client’s Account. Portfolio Managers provide discretionary investment management in SMAs. Model Managers provide nondiscretionary Model Portfolios to JPMS to implement. The Form ADV Part 2A for each model manager selected for a client’s account is available at the SEC’s website at adviserinfo.sec.gov. When clients elected to implement their JPMCAP Accounts using Index- Oriented Vehicles, it could affect JPMPI’s ability to make investments, access asset classes, or take advantage of opportunities that are available to clients who do not make that election. As a result, performance of an Account with an election will differ from the performance of other Accounts without an election. Liquid Alternative Funds Liquid Alternative Funds are available to Accounts depending on the Investment Strategy and assets available in the Account (generally Accounts with an investment balance of at least $250,000). JPMPI manages multi-manager portfolios that seek to invest in one or more Funds available through JPMS, and/or in individual securities following one or more model portfolios that may be provided by affiliated and/or unaffiliated model managers (Multi-Manager Strategies). The Multi- Manager Strategies seek to address specific investment objectives, provide exposure to targeted asset classes, capture timely market opportunities and/or address specific client objectives through actively managed portfolios. These Investment Strategies may include a variety of marketable securities, such as stocks, bonds, ETFs, and mutual funds, and may leverage the expertise of Model Managers who provide models of securities for certain Investment Strategies. Non–J.P. Morgan Funds and Unaffiliated Model Managers income The Liquidity Management Strategy (LMS) is a subgroup of Multi-Manager Strategies and seeks to address specific fixed investment objectives. As described below in “Use of J.P. Morgan Funds and Investment Strategies and Potential Conflicts of Interest,” the Sub-Adviser prefers J.P. Morgan Funds and affiliated Model Managers. Clients can elect to exclude from their JPMCAP Accounts J.P. Morgan managed strategies (except for J.P. Morgan sweep vehicles; refer to “Cash Allocations and the Sweep Feature” below for more detail), including J.P. Morgan managed strategies where a party other than J.P. Morgan is appointed investment adviser (Non-Proprietary Strategy Election). The Non-Proprietary Strategy Election excludes from JPMCAP Accounts J.P. Morgan Funds (except J.P. Morgan sweep vehicles) and affiliated Model Managers. Funds available through Multi-Manager Strategies include both J.P. Morgan Funds and non–J.P. Morgan Funds. Affiliates that sponsor or manage J.P. Morgan Funds may include JPMPI and JPMIM. A substantial portion of the assets in the Multi-Manager Strategies are expected to be invested in J.P. Morgan Funds. In addition, unaffiliated and affiliated model managers will be evaluated and selected for these accounts. Refer to “Important Information About Your Investments and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds and affiliated 33813_COL 11-05-2025 Page 5 of 35  MFAP Model Selection Once the client selects a Model, the client will select the specific Funds in each asset class of the client’s Model. The selected Funds and their percentage allocation will be entered on the Investment Proposal. Clients can change the selected Funds and the percentage allocation of any asset class within the ranges for the applicable Model after the Program Account is opened by giving instructions to the IAR. Investment Strategies. In the case of Dynamic Multi-Asset Strategy (DMAS), a Multi-Manager Investment Strategy, clients can select an Investment Strategy that excludes J.P. Morgan Funds or one that may include J.P. Morgan Funds. JPMS has a conflict in recommending the DMAS Investment Strategy that may include J.P. Morgan Funds. Refer to “Use of J.P. Morgan Funds and Investment Strategies and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds in Multi-Manager Strategies. Fixed Income Advisory Program (FIAP) Funds that have an environmental, social and governance (ESG) or sustainable investing objective or strategy (ESG Funds) can be selected by clients to satisfy asset class allocations in the MFAP Program, to the extent available. However, the MFAP Program is not designated by J.P. Morgan as an ESG or sustainable investing program, nor does JPMS monitor this allocation or guarantee the availability or any minimum or maximum investment in ESG Funds. There is no guarantee that an ESG Fund will continue to reflect ESG characteristics, objective or philosophy or be considered by J.P. Morgan as an ESG or sustainable investment. important information about each Fund, including The Program provides JPMS clients with access to an affiliated portfolio manager, JPMIM, to manage client assets subject to the investment guidelines and risk tolerance of the client. The Program is designed as a solution for investors with the specific asset class needs or desire to invest in taxable and tax-aware fixed income portfolios (Customized Bond Portfolios) consisting of laddered bonds within the risk tolerance of the client’s investor profile. In bond ladder portfolios, the Portfolio Manager buys bonds that have maturities spanning over a designated period of years and which are intended to be held until maturity. For investment objectives, risks, charges, and expenses, clients can read each Fund’s prospectus carefully and consider all the information in it before investing. Multiple Program Accounts Customized Bond Portfolios are designed by a team of portfolio managers in JPMIM and are available with different average maturities to fit different needs and risk tolerances. The portfolio management team constructs the portfolios using fundamental credit and relative value analysis combined with ongoing credit and security oversight. The team focuses on identifying and monitoring attractive risk/reward investments within client-specified criteria. The Customized Bond Portfolios are SMAs that give clients direct ownership of securities and that have several additional features, including that portfolio managers can choose to hold bonds to maturity and can choose to reinvest or withdraw coupon interest income. Clients can open multiple Program Accounts as part of their overall strategy. As applicable to their Program Account(s), clients will receive the Portfolio Manager’s Form ADV Part 2A and Part 2B (Portfolio Manager Disclosure Document) from JPMS. Clients should review the Portfolio Manager’s Disclosure Document carefully for important information about the Portfolio Manager. The Form ADV Part 2A for each Model Manager selected for a client’s Program account is available at the SEC’s website at adviserinfo.sec.gov. Restrictions on Management of Accounts state of residence, credit quality, sector, tax Customizations subject to acceptance by the Portfolio Manager are available to meet a client’s investment criteria, including, but not limited to, treatment, dividend/coupon type, duration preferences and instructions to not reinvest maturing bond proceeds and income. Certain Customized Bond Portfolios are not available for retirement accounts. in their sole discretion. JPMS, the Overlay Manager, For more information on these Investment Strategies, refer to the Form ADV Part 2A for JPMIM which is available at the SEC’s website at adviserinfo.sec.gov. D. Client Profile and Account Opening Clients can request reasonable restrictions on management of their Account including, depending on the Program, particular securities or categories of securities related to a sector or industry (e.g., weapons or tobacco), that will be implemented subject to acceptance by JPMS, the Overlay Manager, the Implementation Manager or the Portfolio Manager the and Implementation Manager or the Portfolio Manager may rely on the information about a company, industry classification, industry grouping, and issuer screening provided by J.P. Morgan or a third party to implement the investment restrictions. Category restrictions aim to screen companies with revenue derived from the restricted category, but they do not exclude all companies with any tie or revenue derived from such restricted category. JPMS does not review, guarantee or validate third-party screenings or processes. Issuer screenings and processes to implement category investment restrictions are not absolute and may change at any time and could result in the portfolio holding investments in companies that derive revenue from the restricted category. If a client’s investment is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event to the client. Any restrictions a client imposes on the management of the Account can limit the ability to make investments or take advantage of opportunities and can cause the Account to perform differently than similar unrestricted Accounts. Neither JPMS nor the Portfolio Manager is required to accept investment restrictions that they deem unreasonable and may decline an Account when they deem any client-requested restriction unreasonable. Prior to opening a Program Account, the IAR consults with the client or prospective client to create a “Client Profile” based upon the client’s responses to questions regarding their financial situation, investment experience, investment objectives, time horizon, and risk tolerance. The information is evaluated and incorporated into an “Investment Proposal.” Depending on the Program, the Investment Proposal provides a recommendation of one or more Portfolio Managers, Model Managers, Models or Investment Strategies, and specifies Funds and, if appropriate, Model Managers that are included in the Model or Investment Strategy. The recommendation is the result of an objective scoring system based on the client’s responses to questions used to create the Client Profile referenced above. Based on the information in the Client Profile and Investment Proposal, the IAR will assist the client in selecting an Investment Strategy, Model, Model Manager or Portfolio Manager and will discuss the recommendation with the client to ensure that it is appropriate for their specific investment needs and risk tolerance. You will inform JPMS of any reasonable restrictions you wish to impose on the management of your Account, including specific securities or types of securities not to be purchased for your Account. Clients agree to the terms of applicable advisory and brokerage service agreements. The client’s selection of an Investment Strategy or Model is reflected in the Investment Proposal. Category and security restrictions will not be applied to strategies that invest only in mutual funds, ETFs and other pooled investments, nor will they be applied to investments made by mutual funds, ETFs and pooled investments, so it is possible that client restrictions would not have any practical effect on an Account comprised primarily of mutual fund and ETF investments. Additionally, client restrictions may have no practical effect on a new strategy selected by the client, particularly when moving from an equity to a fixed income strategy. 33813_COL 11-05-2025 Page 6 of 35  Implementation of Investment Strategy by JPMS, Overlay Manager, Implementation Manager or Portfolio Manager Liquidations will be effected promptly after funding your Account at the then prevailing market prices, separately from the acceptance of the Account by the Overlay Manager, Implementation Manager or Portfolio Manager. If a particular security cannot be liquidated or is not eligible for the particular Program, it will not be used to fund an Account and your IAR will work with you regarding disposition of the securities. After JPMS opens a Program Account for the client, JPMS, the Overlay Manager, Implementation Manager or Portfolio Manager, as applicable, will implement the selected Investment Strategy or Model taking into account any reasonable restrictions the client has placed on management of the Account. The Overlay Manager, Implementation Manager or Portfolio Manager manages client Accounts in the Programs in accordance with each client's specific investment guidelines, objectives and any reasonable restrictions on investing in certain securities or types of securities that the client provides to JPMS in writing and JPMS has accepted. The MLCD SMA has a monthly investment window. Investment management of the Program Account will begin when the investment window opens after JPMS has accepted the Account. You will not be charged an advisory fee or investment management begins. Subsequent a manager fee until investments of cash awaiting investment will be charged both the advisory fee and manager fee. Asset Allocation among Managers and Programs Rebalancing MFAP, CSP and JPMCAP Accounts Program Accounts will be rebalanced only if the percentage variance at the asset class level exceeds a threshold amount that has been established as effective for rebalancing to the Investment Strategy. To rebalance the Account, shares of Funds in the client’s Account that are underweight or overweight compared to their asset class percentage in the Model are bought or sold, as applicable, until the Account holdings are consistent with the client’s selected Model. Over time, the Funds will appreciate (or depreciate) in value at different rates. Rebalancing has tax implications for most clients, unless the Account is an IRA or qualified retirement plan. At the client’s request, JPMS will assist the client in developing one or more asset allocations among Portfolio Managers and/or Model Managers and/or Programs based upon information that the client has provided to JPMS. The client is solely responsible for making all decisions regarding the adoption and implementation of any investment objectives or policies and any such asset allocation. Such asset allocation can change over time due to fluctuations in market value of assets and/or additions or withdrawals by the client. The client is solely responsible for monitoring its investment objectives and policies, including whether the management of the assets among managers and Programs conforms to those investment objectives and policies. The client is also solely responsible for monitoring any asset allocation on an ongoing basis and determining whether to rebalance and/or reallocate assets among managers and Programs. JPMS is not obligated to review, update, rebalance or provide any other ongoing advice with respect to any such asset allocation or the client’s investment objectives and policies. The client retains final decision-making authority and responsibility for the selection of, and any changes made to, such an asset allocation among managers and Programs. Funding Program Accounts MFAP clients can choose to have their Accounts automatically reviewed for rebalancing quarterly, semi-annually, or annually. JPMS also will facilitate the rebalancing of a Program Account upon the client’s direction. Client directed activity (e.g., contributions and withdrawals) as well as model changes will also result in the rebalancing of a Program Account. In between reviews for rebalancing, a client’s Account will drift from the initial asset allocations selected by the client for the Account and can even drift outside of recommended thresholds of a Model. Cash or securities can be used to fund Program Accounts. Investment management will begin after JPMS has accepted the Account into the Program. Account acceptance may be delayed or rejected if the Account is overfunded or underfunded relative to the amount stated in the Investment Proposal. Cash to fund an Account will be placed in the sweep option selected by the client. For CSP and JPMCAP clients, JPMPI will continuously review client asset allocations relative to the selected Investment Strategy and will generally rebalance the Program account to the allocation in the chosen Investment Strategy when the asset allocation percentages deviate from established parameters. To rebalance the account, shares of Funds and/or securities held in the models advised by Model Managers that are underweight or overweight compared to their asset class percentages in the Investment Strategy will be bought or sold, as applicable, until the account holdings are consistent with the Investment Strategy. Over time, the Funds and/or individual securities in the Account will appreciate (or depreciate) in value at different rates. Without rebalancing, the change in the percentages of each asset class held will change the level of risk from the risk level that is associated with the original model and/or allocations in the selected Investment Strategy. Custodian Clients funding Program Accounts with securities direct JPMS, the Implementation Manager, the Overlay Manager or the Portfolio Manager, as applicable, to liquidate the securities on behalf of the client and allocate the proceeds in accordance with the Investment Strategy selected in the Investment Proposal. JPMS, the Implementation Manager, the Overlay Manager, or the Portfolio Manager, on a best efforts basis, will sell a portion or all of any securities that are not consistent with the Investment Strategy stated in the Investment Proposal. Neither JPMS, the Implementation Manager, the Overlay Manager nor the Portfolio Manager, will advise clients regarding the liquidation of these securities. Liquidation will be done free of commission charges or spread on fixed income trades unless the trade is placed away from JPMS. Refer to “Trading Away and Associated Costs” below for more detail. JPMS, in its capacity as an SEC-registered broker-dealer, provides clearing and trade execution services for and serves as the custodian for the Program Accounts. JPMS is a “qualified custodian” as defined in Rule 206(4)-2 under the Investment Advisers Act of 1940 (the Advisers Act). Implementation Manager for Advisory Program JPMS, as the Implementation Manager for Model Manager Strategies, provides portfolio implementation services to Program Accounts. Implementation services include: (1) managing the Accounts on a discretionary basis by implementing instructions to purchase, hold or sell securities or shares of Funds; (2) continuously monitoring the Account holdings; and (3) implementing specific reasonable restrictions requested by the client that are placed on the client Account. Depending on the type of security involved, liquidation may result in redemption charges and taxable gains or losses. Before contributing mutual fund shares, clients should consider if they paid a front-end sales charge, will incur a contingent deferred sales charge or a redemption fee in the event the mutual fund shares are liquidated in accordance with the Investment Strategy selected. These mutual fund fees and charges are the responsibility of the client and are in addition to the wrap fee. Clients should review the potential tax consequences of these liquidations with their tax professional before funding their Program Account with securities. JPMS does not provide tax advice. If non-U.S. denominated securities are sold, the client will incur currency conversion charges. Model Managers When liquidating these securities for purposes of establishing your Account, JPMS will be acting as your broker, not your investment adviser. JPMS has engaged Model Managers to provide non-discretionary investment advice and recommendations through the provision of model 33813_COL 11-05-2025 Page 7 of 35  portfolios that include individual securities. Depending on the Program, JPMS or JPMPI retains investment discretion over Program Account investments. JPMS can add or remove Model Managers to the Programs from time to time. Refer to “Selection and Ongoing Review of Funds and Model Managers” for more information on the selection and removal of Model Managers in the Programs. The Form ADV Part 2A for each Model Manager selected for a client’s Program account is available at the SEC’s website at adviserinfo.sec.gov. 0291, PO Box 1762, Chicago, IL 60690. If a client revokes their appointment of the Proxy Service, the client will receive all proxy materials and annual reports related to securities and other property in the client’s Account, and they will be responsible for voting such proxies directly or instructing any custodian that holds such securities and other property. JPMS can, in its discretion, change the Proxy Service. JPMS will not be deemed to have or exercise proxy voting responsibility or authority by virtue of any authority to hire or change the Proxy Service. In the Advisory Program, as Portfolio Manager of Multi-Manager Investment Strategies, JPMPI can engage Model Managers to provide non- discretionary investment advice and recommendations through the provision of model portfolios that include Funds or individual securities. The Portfolio Manager retains investment discretion over Program Account investments. The Portfolio Manager can add or remove Model Managers from time to time. E. Trade Confirmations, Statements and Performance Reporting including without In CSP and JPMCAP, JPMPI will receive and respond to corporate actions with respect to securities in a client’s Account, such as: any conversion option; execution of waivers; consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation, or similar plan. Each client has the right and responsibility to take any actions with respect to any legal proceedings, including without limitation, bankruptcies and shareholder litigation, and the right to initiate or pursue any legal proceedings, including without limitation, shareholder litigation, including, with respect to transactions, securities or other investments held in the client’s account or the issuers thereof. Neither JPMS nor the Sub-Adviser is obligated to render any advice or take any action on a client’s behalf with respect to securities or other property held in the client’s Account or the issuers thereof, which become the subject of any legal proceedings, limitation, bankruptcies and shareholder litigation, to which any securities or other investments held or previously held in the Account, or the issuers thereof, become subject. In addition, neither JPMS nor the Sub-Adviser is obligated to initiate or pursue any legal proceedings, including, without limitation, shareholder litigation, on behalf of a client’s Account, including with respect to transactions, securities or other investments held or previously held, in the client’s Account or the issuers thereof. In MFAP, the client retains the discretion to vote and cannot designate the Proxy service to vote on their behalf. Clients will receive trade confirmations of all transactions unless they waive receipt of individual confirmations and instead receive a periodic statement of all transactions that will contain the information required to be in a confirmation. Clients in certain Programs can elect to receive a periodic statement in lieu of individual confirmations and can later choose to receive from JPMS, at no additional cost, transaction confirmations for any prior transactions effected during the period in which the client previously elected not to receive separate transaction confirmations. Clients will not pay a different fee based upon this election and can rescind this election at any time upon written notice to JPMS. Clients will receive Program Account statements from the custodian of the Programs at least quarterly (monthly for months when there is activity in their Account). Clients generally will also receive quarterly performance reports containing general market commentary and analysis, charts and graphs detailing the quarterly performance of the Program Account versus relevant industry benchmarks and indices for Program Accounts during the quarter. Client Designation of Portfolio Manager in Advisory Program and FIAP F. Proxy Voting, Corporate Actions and Other Legal Matters JPMS and JPMPI will not vote proxies (or give advice about how to vote proxies) relating to securities and other property currently or formerly held in a client’s Account. JPMS and its affiliates will not be responsible or liable for: (1) failing to notify a client of proxies; or (2) failing to send to the Proxy Service (defined below) or a client, as applicable, proxy materials or annual reports where JPMS or its affiliates have not received proxies or related shareholder communications on a timely basis or at all. MFAP, CSP and JPMCAP Each client has the right to vote, and is responsible for voting, proxies for any securities and other property in the client’s Account. The Portfolio Manager (or its agent) to a client’s Account is designated to receive, and act on client’s behalf, all shareholder communications (including, but not limited to, proxy statements and other proxy solicitation materials; annual reports and semi-annual reports; corporate actions with respect to securities in a client’s Account, such as any conversion option, execution of waivers, consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan) distributed by the issuers of securities held in client’s Account and not required by law to be sent to client. Client can revoke this consent at any time upon written notice to JPMS at J.P. Morgan Securities LLC, Attn: Document Services, Mail Code: IL1-0291, PO Box 1762, Chicago, IL 60690. Such revocation will not affect any other authority given to the Portfolio Manager to provide discretionary portfolio management for client’s Account. The Portfolio Manager will not be obligated to take action or render any advice involving legal action on the client’s behalf with respect to securities or other investments, which become the subject of legal notices or proceedings, including bankruptcies. JPMPI as Portfolio Manager and Model Manager Investment Strategies In CSP and JPMCAP, clients can appoint an independent services provider designated by JPMS for purposes of voting proxies (Proxy Service) as the client’s agent and attorney-in-fact, and clients can authorize the Proxy Service, in its discretion, to vote proxies for any securities and other property in the client’s Account in accordance with the Proxy Service’s proxy voting guidelines in effect from time to time (or other guidelines that the Proxy Service has been instructed to use for particular Investment Strategies), copies of which are available on request. The Proxy Service is currently Institutional Shareholder Services Inc. (ISS). Information relating to ISS services is available on the ISS website at issgovernance.com. The ISS advisory brochure the SEC’s website at is available at adviserinfo.sec.gov. The Proxy Service’s role as the agent of clients applies only to proxies that the Proxy Service generally votes and does not apply to proxies with respect to which the Proxy Service declines to vote. A client who appoints the Proxy Service will not receive proxy materials or annual reports relating to securities and other property for which the Proxy Service has accepted responsibility for voting related proxies. In limited circumstances, the Proxy Service will not vote proxies. A client can revoke its appointment of the Proxy Service upon written notice to JPMS at J.P. Morgan Securities LLC, Attn: Proxy Voting Opt Out, Mail Code: IL1- For the Investment Strategies for which JPMPI acts as Portfolio Manager and for Model Manager Investment Strategies, each client has the right to vote, and is responsible for voting, proxies for any securities and other property in the client’s Account. A client can appoint an independent services provider designated by JPMS for purposes of Proxy Service as the client’s agent and attorney-in-fact, and authorize the Proxy Service, in its discretion, to vote proxies for any securities and other property in the client’s Account in accordance with the Proxy Service’s proxy voting guidelines in effect from time to time (or other guidelines that the Proxy Service has been instructed to use for particular Investment Strategies), copies of which are available on request. The Proxy Service is currently ISS. Information relating to ISS’ services is available on ISS’ website at issgovernance.com. ISS’ advisory brochure is available at the SEC’s website at adviserinfo.sec.gov. The Proxy Service’s role as the client’s agent applies only to proxies that the Proxy Service generally votes and does not apply 33813_COL 11-05-2025 Page 8 of 35  prorated. The Advisory Fee will be reflected on the Account statement issued by the custodian for the Account. The Advisory Fee is an annualized asset-based fee that covers all advisory, administrative, custodial and brokerage services provided by JPMS. The Advisory Fee for Program Accounts will be computed and payable monthly in arrears based upon the market value of all assets held in the Program account (including cash) on the last business day of the prior month. to proxies with respect to which the Proxy Service declines to vote, which will not be voted. A client that appoints the Proxy Service will not receive proxy materials or annual reports relating to securities and other property for which the Proxy Service has accepted responsibility for voting related proxies. In limited circumstances, proxies will not be voted by Proxy Service. A client can revoke their appointment of the Proxy Service upon written notice to JPMS at J.P. Morgan Securities LLC, Attn: Proxy Voting Opt Out, Mail Code: IL1-0291, PO Box 1762, Chicago, IL 60690. If a client revokes their appointment of the Proxy Service, the client will receive all proxy materials and annual reports related to securities and other property in the client’s Account and will be responsible for voting such proxies directly or instructing any custodian that holds such securities and other property. JPMS may, in its discretion, change the Proxy Service. JPMS will not be deemed to have or exercise proxy voting responsibility or authority by virtue of any authority to hire or change the Proxy Service. The Advisory Fee does not cover any (i) brokerage commissions or other charges resulting from transactions not effected through JPMS or its affiliates; (ii) “mark-ups,” “markdowns” and “dealer spreads” that we or other broker-dealers may receive when acting as principal in certain transactions; (iii) certain costs or charges imposed by third parties, including odd-lot differentials, margin interest, transfer taxes, exchange fees, and other fees or taxes required by law; (iv) any retirement Account fee; (v) the cost of investment manager fees and other expenses charged by Funds; or (vi) any pass-through or other fees associated with investment in American Depositary Receipts. Program Fee For the Investment Strategies for which JPMPI acts as Portfolio Manager, JPMPI will receive and respond to corporate actions with respect to securities in a client’s Account, such as: any conversion option; execution of waivers, consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. JPMPI may, in its sole discretion, delegate this responsibility to a service provider. JPMS as Implementation Manager of Model Manager Investment Strategies The program fee includes the Advisory Fee and, if applicable, the fee charged by the Model Manager or Portfolio Manager (Manager Fee) (collectively, Program Fees). The Program Fees can be more or less than the cost of paying for investment advice, trade execution, custody and reporting services separately, depending on the cost of these services if provided separately and the level of trading activity in the client’s Account. Manager Fess may be more than fees for the same Portfolio Manager/Model Manager services outside the Program, including when offered by affiliates. For Model Manager Investment Strategies, JPMS will receive and respond to corporate actions with respect to securities in a client’s Account, such as: any conversion option; execution of waivers, consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. JPMS may, in its sole discretion, delegate this responsibility to a service provider. Client Right and Responsibility to Take Action Because the Program Fee is charged on assets in the Account, in a low interest rate environment, a client can earn less interest on assets held in the Account as cash or cash alternatives such as money market funds than the amount of the Fee the client is paying JPMS with respect to such assets, and therefore, the client’s net yield with respect to such assets can be negative. Advisory Fee for FIAP The Advisory Fee rate for assets invested in the FIAP is 0.70%. A portion of the Advisory Fee is paid by JPMS to JPMIM as the Portfolio Manager for portfolio management services, and to JPMPI to reimburse for the costs of research and other related services in support of the FIAP strategies. Advisory Fees for MFAP, CSP, JPMCAP, and the Advisory Program: The applicable annual Advisory Fee applies to the entire Advisory Account. Each client has the right and responsibility to take any actions with respect to any legal proceedings, including, without limitation, bankruptcies and shareholder litigation, and the right to initiate or pursue any legal proceedings, including, without limitation, shareholder litigation, including with respect to transactions, securities or other investments held in the client’s Account or the issuers thereof. Neither JPMS nor JPMPI is obligated to render any advice or take any action on a client’s behalf with respect to securities or other property held in the client’s Account, or the issuers thereof, which become the subject of any legal proceedings, including, without limitation, bankruptcies and shareholder litigation, to which any securities or other investments held or previously held in the Account, or the issuers thereof, become subject. In addition, neither JPMS nor JPMPI is obligated to initiate or pursue any legal proceedings, including, without limitation, shareholder litigation, on behalf of a client’s Account, including, with respect to transactions, securities or other investments held, or previously held in the client’s Account, or the issuers thereof. ADVISORY FEE SCHEDULE Account Assets Annual Fee G. Wrap Account Fees 0–$249,999.99 1.45% Program Advisory Fee $250,000.00–$499,999.99 1.30% $500,000.00–$999,999.99 1.15% $1,000,000.00–$1,999,999.99 1.00% $2,000,000.00–$4,999,999.99 0.75% $5,000,000.00–$9,999,999.99 0.65% $10,000,000.00–$14,999,999.99 0.55% $15,000,000.00–$24,999,999.99 0.50% $25,000,000.00–$49,999,999.99 0.40% 0.30% ≥ $50,000,000 Clients pay an annual asset-based account fee for the Program (Advisory Fee) to JPMS pursuant to (1) the applicable fee schedule and subject to any applicable discounts or adjustments; or (2) a maximum advisory fee rate (Maximum Rate), where the agreed upon Maximum Rate will be applied unless the applicable tier on the fee schedule gives the client a lower advisory fee rate. The fee schedules for the Programs are set forth below and expressed as annual percentages. Generally, all Account values used to determine the Advisory Fee described herein are based on the market value of the assets held in the Account on the last business day of the prior month or portion thereof, as determined by JPMS. The Firm charges fees that it believes are reasonable, but these fees are not always the lowest available from other firms, including affiliated ones. Advisory Fees for partial billing periods upon the inception or termination of a Program account will be 33813_COL 11-05-2025 Page 9 of 35  The Advisory Fee rate for assets invested in LMS is 0.40%. Effective November 10, 2025 the Advisory Fee rate for new LMS investors and LMS proposals dated on or after November 10, 2025 will be 0.60%. Fixed Income Advisory Fee Schedule for Advisory Program Fixed Income SMAs Certain Portfolio Managers are affiliated with JPMS. Portfolio Manager Fees of affiliated Portfolio Managers are waived or rebated to client Program Accounts that are IRAs or tax-qualified plans, including plans subject to ERISA. In this case, JPMS may share a portion of the Advisory Fee with the affiliated Portfolio Manager. This revenue sharing arrangement will not affect the total Account Fees due by the client. JPMS FIXED INCOME ADVISORY FEE No Minimum Fee Advisory Account Assets Annual Fee 0–$249,999.99 0.60% $250,000.00–$499,999.99 0.60% $500,000.00–$999,999.99 0.60% No minimum fee requirement is applied to Program Accounts. Program Accounts will be charged the appropriate fee percentage for the asset value in the Program Account or, if applicable, for the value of assets in managed accounts that have been combined for Advisory Fee calculation purposes (refer to “Waivers, Reductions and Negotiated Fees” below). $1,000,000.00–$1,999,999.99 0.60% $2,000,000.00–$4,999,999.99 0.60% $5,000,000.00–$9,999,999.99 0.60% If the market value of the Account falls below 10% of the minimum asset size required for the current applicable fee rate, the Advisory Fee rate will be determined based on the fee schedule, and the Account will be assessed the higher fee rate. $10,000,000.00–$14,999,999.99 0.55% Method of Payment $15,000,000.00–$24,999,999.99 0.50% $25,000,000.00–$49,999,999.99 0.40% 0.30% ≥ $50,000,000 Model Manager Fees for CSP, JPMCAP and the Advisory Program Subject to restrictions for retirement accounts and asset availability, clients can request, and JPMS may allow, that one of the related accounts (including a non-retirement Program Account or J.P. Morgan bank account) pay the entire Advisory Fee, Model Manager Fee, or Portfolio Manager Fee for the combined holdings. Additional fees are charged by Model Managers (Model Manager Fees). The Model Manager Fee is an annualized asset-based fee that covers the Model management services provided by Model Managers. These Model Manager Fees are in addition to the Advisory Fees and vary depending on the Model Manager and the asset class. The Model Manager Fee is not included in the Advisory Fee. JPMS collects the Model Manager Fee from clients and pays the Model Managers. The applicable Model Manager Fee rate for a specific Model will be stated in the Investment Proposal for the Account. The client’s actual Model Manager Fees will be reflected in the Account statement. Certain Model Managers are affiliated with JPMS. Model Manager Fees of affiliated Model Managers are waived or rebated to client Program Accounts that are IRAs or tax-qualified plans, including plans subject to ERISA. In this case, JPMS may share a portion of the Advisory Fee with the affiliated Model Manager. This revenue sharing arrangement will not affect the total Account Fees due by the client. CSP and JPMCAP Model Manager Fee Unless the client has elected to pay the Advisory Fee, Model Manager Fee, or Portfolio Manager Fee from a related JPMS managed account, if there are sufficient funds in the sweep fund to pay the entire amount, the Advisory Fee percentage for the Program Account value will be paid out of the sweep fund within the Program Account. If the sweep fund does not have sufficient funds to pay the fee in its entirety: in MFAP, CSP and JPMCAP, shares of the most overweight Fund(s) or securities in a model provided by a Model Manager; and in the Advisory Program and FIAP, at the discretion of the Portfolio Manager or Implementation Manager, securities in the portfolio Account, will be sold to pay the entire fee rather than paying any of the fee from the sweep fund. This could result in the client incurring a tax liability. If due to withdrawals, payment of fees, or otherwise, the value of the sweep fund falls to zero or below in MFAP, CSP, and JPMCAP, sufficient shares in the Fund(s) or securities in a model provided by a Model Manager that is currently most overweight in the Investment Strategy based on actual dollar value, and in the Advisory Program and FIAP, at the discretion of the Portfolio Manager or Implementation Manager, sufficient securities in the portfolio Account, will be sold to clear the debit and replenish the sweep fund to its current target amount. The Model Manager Fees range from 0.10% to 0.45% and only apply to that portion of the Account allocated to the Model and managed by the Model Manager. Reimbursement of JPMPI as the Portfolio Manager, Overlay Manager and Sub-Adviser Advisory Program Model Manager Fee JPMS reimburses the expenses of JPMPI when acting as Portfolio Manager, Overlay Manager and/or Sub-Adviser in return for its services. Model Manager Fees in the Advisory Program range from 0.25% to 0.425%. Portfolio Manager Fees For qualified retirement Accounts where fees to affiliates are waived, JPMS may share a portion of the Advisory Fee with the affiliated manager for the Account. Trading Away and Associated Costs The Advisory Program offers SMAs with additional fees charged by Portfolio Managers (Portfolio Manager Fees). The Portfolio Manager Fee is an annualized asset-based fee that covers the portfolio management services provided by Portfolio Managers. These Portfolio Manager Fees are in addition to the Advisory Fees and vary depending on the Portfolio Manager and the Investment Strategy. The Portfolio Manager Fee is not included in the Advisory Fee. JPMS collects the Portfolio Manager Fees from clients and pays the Portfolio Managers. Certain Portfolio Managers place all or substantially all of certain types of trades with a broker-dealer other than JPMS for execution, depending on the types of securities traded in an Investment Strategy. It is not uncommon for investment managers to trade away in fixed income, foreign security, and small-cap equity strategies. Investment Strategies with such types of securities could be more costly to you than Investment Strategies in which Portfolio Managers more commonly place trades with JPMS for execution. Portfolio Manager Fees range from approximately 0.10% to 1%. The specific Portfolio Manager Fee rate applicable to an Account will be stated in the Investment Proposal for the Account. The client’s actual Portfolio Manager Fees are reflected in the Account statement issued by the custodian for the Account. Portfolio Managers place orders in fixed income or debt securities with broker-dealers other than JPMS. For these fixed income trades, the client will incur a mark-up, mark-down or spread charged by the other broker- dealer that is not covered by the Advisory Fee. 33813_COL 11-05-2025 Page 10 of 35  clients will pay a different Advisory Fee. Reductions, rebates and waivers of the Advisory Fee, including discounts or adjustments, are not applicable to the Portfolio Manager or Model Manager Fee. Discounts may be subject to an expiration date. From time to time, the Advisory Fee can be increased (i.e., JPMS may increase the Advisory Fee; the Portfolio Manager or Model Manager may increase their fee). JPMS will promptly notify the client whenever a fee increase is made to the client’s Program Account(s). JPMS charges fees that it believes are reasonable in relation to the scope of services and nature of the investment advice provided, but these fees are not always the lowest available from other firms and/or our affiliates. Fixed income securities are primarily traded in dealer markets. These securities are directly purchased from or sold to a financial services firm acting as a dealer (or principal). A dealer executing such trades may include a commission, a markup (on securities it sells), a markdown (on securities it buys) or a spread (the difference between the price it will buy, or “bid,” for the security and the price at which it will sell, or “ask,” for the security) in the net price at which transactions are executed. The bid and ask are prices quoted by the dealer, so the client should understand that a dealer’s bid price would be the price at which a client is selling their security, and the dealer’s ask price would be the price at which a client is buying the security. Advisory Fees for partial billing periods upon the inception or termination of a Program account will be prorated. The Advisory Fee will be reflected on the Account statement issued by the custodian for the Account. Clients should review a Portfolio Manager’s Form ADV Part 2A Brochure, ask about a Portfolio Manager’s trading practices and consider that information carefully before selecting an investment manager and its investment strategy. In particular, clients should carefully consider any additional trading costs associated with a particular Portfolio Manager and investment strategy before selecting them for their Wrap Fee Program account. The Advisory Fee can be more or less than the cost of paying for investment advice, trade execution, custody and reporting services separately, depending on the cost of these services if provided separately and the level of trading activity in the client’s Account. Because the Advisory Fee is charged on all assets in the Account, in a low interest rate environment, a client can earn less interest on assets held in the Account as cash or cash alternatives, such as money market funds, than the amount of the Advisory Fee the client is paying JPMS with respect to such assets, and therefore, the client’s net yield with respect to such assets can be negative. Relationship Pricing When Portfolio Managers place orders with broker-dealers other than JPMS, clients that elect to receive trade confirmations will receive a trade confirmation issued by JPMS that will provide details of the trade as follows: (i) for equity trades, the trade confirmation and Account statement will generally indicate “traded away” and will list the commission you incurred as an additional cost in connection with trading away by a Portfolio Manager; and (ii) fixed income trades will generally indicate “traded away” and show a price for the traded security that is inclusive (i.e., net) of the commission, mark-up or mark-down paid by the client to the other broker- dealer, but it does not break out or otherwise show the amount of the commission, mark-up or mark-down separately. Some fixed income trades, due to operational factors, will not indicate “traded away”; however, all fixed income trades are “traded away” whether or not they are indicated as such. For more information on trades away from the Firm, refer to “Trading for Wrap Fee Programs” available at Practices Disclosures chase.com/managed-account-disclosures. ADR Fees in CSP, JPMCAP and the Advisory Program JPMS uses a Relationship Pricing Group to determine Advisory Fees for eligible Advisory Accounts by considering the value of assets in Program Accounts with the same fee schedule and fee calculation methodology. JPMS decides which Advisory Accounts are eligible to be linked in a Relationship Pricing Group. Relationship pricing applies prospectively after Advisory Accounts are linked in a Relationship Pricing Group. Assets in accounts in the Fixed Income Advisory Program and LMS are not eligible to be included in the Relationship Pricing Group for purposes of determining your Advisory Fee rate. ERISA, Irrevocable Trust and Entity accounts are generally prohibited from combining into a Relationship Pricing Group with the accounts for another person, entity or relationship. ERISA accounts cannot be in a Relationship Pricing Group with non-ERISA accounts. J.P. Morgan Managed Investment Services Program accounts cannot be in a Relationship Pricing Group with accounts in a different Program. When the combined assets in the Relationship Pricing Group are sufficient to reach the next tier on the advisory fee schedule, the client(s) will benefit from a lower overall fee. The combined Advisory Fee is then divided ratably and assessed over all of the Program Accounts in the Relationship Pricing Group. All accounts in the Relationship Pricing Group will have the same Advisory Fee rate applied. Automatic Linking Special tax rules may apply to investments in foreign issuers, including American Depositary Receipts (ADRs). For example, one or more issuers in the Portfolio may qualify as a passive foreign investment company or a controlled foreign corporation for U.S. tax purposes, and non-U.S. withholding tax may be imposed on distributions or gains. Also, in certain cases, additional U.S. tax reporting may be required. Shares of foreign companies on foreign exchanges can be purchased and the shares converted to ADRs for client Accounts if the total cost of the purchase and conversion is more advantageous than directly purchasing the ADRs. To the extent that a subsidiary of J.P. Morgan assists in the conversion of foreign stock, J.P. Morgan affiliates will receive additional compensation from the transaction but in no event should the total cost of the purchase and conversion costs exceed the cost if they had originally purchased the ADR in U.S. markets. Subject to the exceptions discussed above, JPMS automatically links eligible Program Accounts with the same primary tax identification number for purposes of determining the asset size and Advisory Fee rate according to the applicable tiered Advisory Fee schedule. JPMS will not automatically link accounts for Relationship Pricing Group purposes in any other way. Client-Requested Linking If the investment in the portfolio is made through an IRA, any foreign taxes incurred generally would not be creditable against your U.S. income tax liability. You are urged to consult your tax advisor regarding investment in non-U.S. entities, including whether you may be eligible for a credit against your U.S. income tax liability for any foreign taxes paid and whether you may be eligible for a lower rate or partial refund of non-U.S. withholding taxes pursuant to one or more applicable income tax treaties. For more information on foreign issuers, please refer to the Foreign Issuers Risk section. Subject to the exceptions discussed above and other than for accounts that are automatically linked by primary tax identification number, in order for clients to receive the potential benefits of a Relationship Pricing Group, clients must request that their eligible family member Program Accounts be combined in a Relationship Pricing Group. JPMS will not link family members in a Relationship Pricing Group unless the clients proposed to be in the Relationship Pricing Group request linking. Waivers, Reductions and Negotiated Fees IAR Compensation In its discretion, JPMS can negotiate, reduce or completely waive the Advisory Fee for any client or group of clients. Fees are discounted for employees of JPMS and its affiliates. It is possible that similarly situated The Program is recommended to clients by IARs associated with JPMS. For those IARs that receive a portion of the Advisory Fee: (i) the exact portion 33813_COL 11-05-2025 Page 11 of 35  of the fee paid to the IAR varies among IARs and can also depend upon each IAR’s overall revenue production; and (ii) no compensation is paid to the IAR for Accounts where the total client assets invested through the Firm (including brokerage, managed and annuities) is less than $100,000 (generally, such Accounts will be assigned to a team of IARs who are salaried employees). The type of compensation paid to IARs will not result in a change to a client’s Advisory Fee. performed by JPMS or its affiliates, JPMS or its affiliates will receive some or all of the revenue from the fee. These Fund fees and expenses are in addition to any fees paid to JPMS as the Program Sponsor and any fees paid to the Portfolio Managers and any fees and/or expenses or reimbursements paid to/or received by the Sub-Adviser or Model Managers. Clients can review the applicable prospectuses for Funds (including Liquid Alternative Funds) in the Programs for additional information about these fees and expenses. JPMS and its affiliates collectively receive greater revenue if J.P. Morgan Funds or affiliated Model Managers are included in the Programs, and therefore, JPMS and its affiliates have a conflict of interest in including J.P. Morgan Funds or affiliated Model Managers in the Programs. Refer to “Important Information About Your Investments and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. Share Classes available in MFAP, CSP, JPMCAP and Advisory Program JPMS or IARs may discount the Advisory Fee and/or provide a Maximum Rate. These IARs (other than those who are only compensated by salary and discretionary bonus) have a financial incentive to (1) price client Accounts at the stated fee schedule rather than providing a discount and/or a Maximum Rate and (2) limit discounts to the Advisory Fee and/or a Maximum Rate to be no more than a certain percentage below the stated fee schedule. The IAR will earn reduced compensation when IARs (1) discount the Advisory Fee more than a certain percentage below the stated advisory fee schedule and/or (2) provide a Maximum Rate that is more than a certain percentage below the applicable tier of the stated advisory fee schedule for the given billing period. Clients can and should ask their advisor for details on discounting practices and how those practices affect compensation. Discounts to the Advisory Fee and/or Maximum Rates that are more than a certain percentage below the stated fee schedule made after 01/01/25 will affect IAR compensation beginning 01/01/26. Clients may find their agreed upon discount percentage and/or Maximum Rate percentage in documents such as proposals, certain letters and/or statements. We address these conflicts of interest by maintaining policies and procedures requiring that Advisors act in your best interest, reasonably supervising their activities and disclosing these conflicts so that you can make informed decisions. Mutual funds typically offer different ways to buy shares with different share classes that may assess different fees and expenses. JPMS strives to make available the most appropriate share class on the platform for each Fund, with the goal of generally obtaining the lowest cost share class. However, for certain Funds, the share classes with the lowest fee structures are not available in a particular Program (e.g., (1) the Fund family restricts access to these share classes or (2) JPMS does not have an agreement with the Fund to distribute the share class in the Programs). Clients should be aware that the share class of a Fund available through the Programs may differ from the share class available to similar accounts managed by or held at JPMS or its affiliates, and that certain lower cost Fund share classes may be available outside of the Programs. Clients should contact their IAR(s) for information about any limitations on share classes available through the Programs. JPMS, through its brokerage accounts has other arrangements with Fund companies that are described in the relevant brokerage documents. Because Model Manager and Portfolio Manager Fees vary, and in some cases may be waived, this creates (i) an opportunity for the IAR to avoid discounting (or to limit the discount on) the JPMS Advisory Fee when recommending a Model Manager or Portfolio Manager that charges a lower or no additional fee; and thus (ii) a financial incentive to recommend Model Managers or Portfolio Managers with lower or waived fees. JPMS and its affiliates receive fees or other forms of compensation from the Funds (including money market funds) or their affiliates. JPMS believes that this conflict is addressed in the following ways: • JPMS also benefits more if an Advisory Fee is not subject to a discount. JPMS does not give the discretion to discount to IARs who are salaried employees. 12b-1 distribution fees: JPMS receives fees from certain funds pursuant to Rule 12b-1 under the Investment Company Act of 1940 (Investment Company Act) (12b-1 Distribution Fees). Rule 12b-1 allows funds to use fund assets to pay the costs of marketing and distribution of the fund’s shares. If JPMS receives 12b-1 Distribution Fees, it will rebate these fees to the client. • JPMS IARs have a number of opportunities for selling products or services in their capacity as JPMS broker-dealer registered representatives or insurance agents. Depending on a number of factors (e.g., the size of the Program Account, changes in its value over time, the number of transactions, and the ability to negotiate fees and commissions), the amount of compensation received by certain IARs and the Firm from a Program Account can be more or less than JPMS and the IAR would receive if the client paid separately for investment advice, brokerage and other services. IARs, for themselves and the Firm, have a financial incentive to recommend the Program, especially when the Advisory Fee would be more than if the services were provided separately, or if the client had purchased a different advisory program sponsored by JPMS. IARs receive less compensation for FIAP and the Liquidity Management Strategy than the other Programs described in this brochure. Other Fees and Expenses Other fees: JPMS enters into agreements with the funds, their investment managers, distributors, principal underwriters, shareholder servicing agents and/or other affiliates of the funds (Service Providers). The funds or their Service Providers pay J.P. Morgan fees for providing certain administrative services, which include maintaining and updating separate records for each client, preparing and delivering client statements, tax reporting, proxy voting and solicitation, processing purchase and redemption orders, processing dividends, distributing prospectuses and other fund reports, and responding to client inquiries. These fees for these services are typically called “shareholder servicing fees” when paid for by the fund; however, these fees can be referred to as “revenue sharing” when they are paid by the fund Service Provider from its own resources (together referred to as Servicing Fees). As of December 31, 2024, the Servicing Fees that JPMS received were up to 25 basis points annually of the fund assets, or a rate of up to $20 per year per fund position; however, these amounts can change. The receipt by JPMS of these fees creates a conflict of interest in the selection of funds for accounts because the fees are different among funds. Similarly, JPMS has a conflict to recommend mutual funds that pay Servicing Fees instead of ETFs or other securities or products that do not pay any Servicing Fee. The Portfolio Managers or IARs, who are responsible for managing or recommending investments for Program accounts do not receive any direct financial benefit from the Servicing Fees. To Funds pay fees and expenses that are ultimately borne by clients (including, but not limited to, management fees, brokerage costs, administration and custody fees). The Advisory Fee does not include various additional fees that can be incurred within a client’s Program Account, including, but not limited to, Fund fees and expenses, transfer taxes, electronic fund and wire fees, IRA and retirement plan account fees, margin interest, ADR related fees or any other fees that would reasonably be assessed to a brokerage account. If these fees are for services performed by JPMS or their affiliates, JPMS or an affiliate will receive all or a portion of the revenue from the fee. Additionally, Funds held in a Program Account have annual investment advisory expenses, so clients incur two levels of investment management fees: indirect Fund investment advisory fees to the investment adviser of each Fund and direct Program investment advisory fees to JPMS, the Model Managers and the Portfolio Managers. If these fees are for services 33813_COL 11-05-2025 Page 12 of 35  that extent, such Portfolio Managers or IARs are incentivized to invest in or recommend securities they believe will increase the value of the account. JPMS does not retain any portion of those fees for retirement advisory accounts. When evaluating the fees for, and cost of, a Program, clients should consider the Servicing Fees that JPMS receives in addition to the investment advisory fees. Clients can also request a fund prospectus for additional information regarding fund fees. Although there is no charge to clients with respect to the Deposit Account, JPMCB benefits from the Deposit Account because, through the Deposit Account, JPMCB receives a stable, cost-effective source of funding. JPMCB uses customer deposits in the Deposit Account to fund current and new businesses, including lending activities and investments. The profitability on such lending activities and investments is generally measured by the difference, or “spread,” between the interest rate paid on the deposits and other costs associated with the Deposit Account paid by JPMCB, and the interest rate and other income earned by JPMCB on the loans and investments made with the deposits. The income that JPMCB earns through its lending and investing activities is usually significantly greater than the interest earned by clients through the Deposit Account. It is typically also greater than the fee earned by all J.P. Morgan entities from managing and distributing money market mutual funds available to Program clients. Additionally, JPMCB has agreed to pay JPMS a monthly flat fee for each Account that uses the Deposit Account; however, JPMS is currently waiving receipt of this fee. Therefore, JPMS and JPMCB have a conflict of interest in offering or utilizing the Deposit Account and in making it the default “sweep” option. JPMS believes that the conflict is addressed through: Once a particular share class is made available for a particular Fund in a Program, only that share class can be purchased for that Fund. Mutual funds will be purchased in the Account at net asset value (no-load or load- waived) and ETFs at their market price. JPMS periodically reviews the share classes offered by Funds in the Programs but also relies on the Fund families to inform JPMS when and if these share classes will be made available. If JPMS identifies and makes available a class of shares for a Fund more appropriate than the class of shares previously made available for the Fund, to the extent allowed, JPMS will convert client shares of the Fund to that more appropriate share class of the same Fund. Operational and other considerations can affect the timing of the conversion of shares and can cause the timing or implementation of such conversions to differ between clients. • The fact that IARs do not receive any additional compensation for assets held in the Deposit Account as opposed to another cash alternative; Online disclosure of the available cash options and yields; • • The client’s ability to affirmatively select another available “sweep” option and to change the “sweep” option selection to an available alternative at any time; Some of the fund share classes available through the Programs are not necessarily available to clients outside of such Programs. To the extent a client funds an account with a share class that is not available in a Program, shares in the unavailable share class will be liquidated or, if in the MFAP Program, transferred to the share class available in the MFAP Program. If an Account is terminated, clients may not be eligible to continue to hold or purchase certain share classes offered in a Program outside of such Program, as well as outside the firm. • Cash Allocations and the Sweep Feature The JPMorgan Chase Deposit Account Disclosure provided to the client; and • The client’s ability to obtain the prospectus for each money market mutual fund that is an available alternative to the Deposit Account. Offset of Certain Fees to IRAs and Certain Other Retirement Plan Accounts Clients in the Programs authorize JPMS, to the extent permitted by applicable law, to invest (i.e., sweep) available cash balances in the JPMorgan Chase Deposit Account (the Deposit Account) or one or more money market mutual funds that are managed by affiliates of JPMS. The Deposit Account is the default “sweep” option for Program clients who do not select an available “sweep” alternative or if the sweep selected is no longer available. Investment in a non-proprietary model or a Non- Proprietary Strategy Election to exclude J.P. Morgan Funds does not apply to cash balances held in sweep options. If a Program Account owned by an IRA, or other client that is a qualified retirement account subject to the prohibited transaction provisions of Section 4975 of the IRC, holds any J.P. Morgan Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with Program Account assets will be offset to the Advisory Fee. The offset amount will be automatically applied against the Advisory Fee charged for the period and will appear as a separate line item on the client’s Program Account statement. This offset does not apply to Account investments in non–J.P. Morgan Funds. In addition, for those J.P. Morgan Funds that utilize unaffiliated investment sub-advisers for all or a portion of the Fund portfolio management, the amount of the Fund advisory fees paid to unaffiliated investment sub-advisers is not offset to the Advisory Fee. Margin Debit Balances Cash “swept” or allocated to the Deposit Account is remitted for deposit by JPMS, acting as the client’s agent, into a demand deposit account maintained at JPMCB. Balances in the Deposit Account are covered by FDIC insurance, subject to applicable limits, terms and conditions, but are not protected by the Securities Investor Protection Corporation. JPMS does not review or monitor FDIC insurance limits for clients. Clients are responsible for monitoring the total amount of deposits that they have with JPMCB to determine the extent of FDIC deposit insurance coverage available to them on their deposits. The JPMorgan Chase Deposit Account Disclosure (contained in your Terms & Conditions booklet) provides further information about the Deposit Account, including the limits, terms and conditions of FDIC insurance coverage. Margin debit balances held by a client cannot be held in a Program Account. This is significant because, for purposes of the calculation of the Advisory Fee, the net market value of the assets on which the fee is based will generally not be reduced by the amount of any margin debit balances held by the client in an account outside of the Program, even if some or all of the proceeds of the loan represented by the margin debit balances are held in the client’s Program Account, and even if some or all of the assets in the client’s Program Account are used to collateralize or secure the loan represented by the margin balances. JPMS has a financial incentive for the client to incur margin debt to buy securities in a Program Account because: (1) the client will be required to pay JPMS or its affiliates interest and fees on the debt; and (2) the net market value of the Program Account will be increased by the value of the additional securities purchased with the margin loan (and will not be offset by the amount of the margin debit held by the client in any account outside of the Program), resulting in a higher The interest rate on the Deposit Account will vary based on business and economic conditions and is reset periodically at JPMCB’s sole discretion. The interest rate on the Deposit Account may be higher or lower than yields on other available cash alternatives (e.g., money market mutual funds). From time to time, JPMS, the Sub-Adviser or the Portfolio Manager, may deem it in the client’s best interest to maintain a certain percentage of assets in cash or cash alternatives, especially when markets are volatile. However, because the Wrap Fee is charged on the value of all assets in the Account (including cash and cash alternatives), in a low interest rate environment, the net investment return on cash and cash alternatives, including the Deposit Account, will be negative. The current rates and yields for available cash options for Program accounts, including the Deposit Account, can be found online at chase.com/SweepYields. These rates and yields change regularly, so it is prudent to check this website periodically. 33813_COL 11-05-2025 Page 13 of 35  Model Managers. Refer to “Liquid Alternative Funds” above for more information. The US Endowments & Foundations investment strategy has a minimum investment of $1,000,000. fee. In addition, any interest and fees paid by the client in connection with any debit balances held outside the Program Account will not be taken into account in the computation of the net equity or performance of the client’s Program Account as reflected in Account statements, performance reports or otherwise. Advisory Program ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Participation in the Advisory Program generally requires a minimum $50,000 investment for Multi-Manager Strategies, and $100,000 for equity and fixed income Portfolio Manager and Model Manager Accounts. Portfolio Managers and Model Managers can require higher minimum amounts or change the initial Account minimums. JPMS has established minimum account requirements for client Accounts, which vary based on the investment vehicle (separate account or fund), investment strategy and asset class. JPMS offers and sells the Programs to individuals, trusts, estates, charitable organizations, corporations, and other business entities with U.S. addresses. Clients whose Account address becomes a non-U.S. address will generally have their Account terminated from the Program. The Programs are generally available to IRAs and to qualified retirement plans subject to ERISA. If a Program Account falls below the Portfolio Manager or Model Manager initial account minimum, the Account is subject to termination at the discretion of JPMS or the Portfolio Manager. FIAP Except for MFAP, the Programs are not intended for investors who seek to maintain control over trading in their Account. The Programs are not intended for investors who have a short-term time horizon (or expect ongoing and significant withdrawals), or who expect or desire to maintain consistently high levels of cash or money market funds. A. Program Minimums Participation in the FIAP generally requires a minimum investment of $250,000 for tax-aware Customized Bond Portfolio (CBP) strategies and a minimum investment of $100,000 for taxable CBP strategies. Certain corporate bond portfolios, customized preferred portfolios and a version of the tax-aware strategy that limits customization are available with a minimum investment of $500,000. Portfolio Managers can require higher minimum amounts or change the initial Account minimums. If a Program Account falls below the Portfolio Manager initial Account minimum, the Account is subject to termination at the discretion of JPMS or the Portfolio Manager. B. Cash Balances in Program Accounts Program Account minimums are subject to waiver in JPMS’ discretion and are waived for client Accounts from time to time. If a Program Account falls below the Program minimum, JPMS can terminate the Program Account at its discretion. The investment, sale or withdrawal of funds or securities from Program Accounts will be effected as soon as practicable subject to market conditions and other factors. Under normal market conditions, it can take 2-4 business days to process the investment (whether initial investments or additions), sale or withdrawal of funds in Program Accounts; however, timeframes can be longer due to market conditions and other factors. MFAP A portion of Program Accounts will be held in cash, cash equivalents or money market funds as part of the overall investment strategy for the Account and funds awaiting withdrawal by the client. Cash and cash equivalents, including money market funds, are subject to the Advisory Fee. For additional information, refer to “Cash Allocations and the Sweep Feature” in Item 4. Participation in the MFAP Program generally requires a minimum $50,000 investment. CSP Cash raised for withdrawal will be charged both an Advisory Fee and an applicable Model Manager or Portfolio Manager Fee until the cash is removed from the Account. Cash that is not removed from an Account in a timely manner will be reinvested pursuant to the selected asset allocation or Investment Strategy. ITEM 6 — PORTFOLIO MANAGER SELECTION AND EVALUATION A. MFAP, CSP and JPMCAP Sub-Adviser Method of Analysis in MFAP, CSP and JPMCAP Participation in the CSP Program generally requires a minimum $50,000 investment. Minimum Account values for eligibility to invest in securities in Models provided by Model Managers and SMAs are determined by JPMS from time to time. Currently, JPMS requires a minimum account value of $500,000 to invest in other securities through Model Managers or SMAs. An Account that falls below this minimum as a result of client withdrawals will be rebalanced by the trade implementation team to a Model without other securities through Model Managers or SMAs. JPMS can waive or alter the minimum to invest in Model Managers. JPMCAP is available at Set forth below is a general description of the primary methods of analysis that the Sub-Adviser utilizes for the Program. This description is not intended to serve as Fund, Model Manager, SMA or Account guidelines. In connection with investments in a Fund or other securities through a Model Manager or SMA, 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, SMA’s or Model Manager’s Form ADV disclosure brochures. The Form ADV Part 2A disclosure brochure for each Model Manager or SMA selected for a client’s Program Account the SEC’s website at adviserinfo.sec.gov. JPMS, the Sub-Adviser, and the manager solutions team of JPMPI or its affiliates are not responsible for the performance of any Fund, SMA or Model Manager (including any J.P. Morgan Fund or affiliated SMA or Model Manager), or its compliance with its prospectus, disclosures, laws or regulations, or other matters within the Fund’s or Model Manager’s control. Each Fund or SMA’s adviser is solely responsible for the management of the Fund or the SMA. JPMS, the Sub-Adviser and the Manager Solution Team cannot ensure that a given Model’s or Investment Strategy’s investment objective will be attained. Participation in the JPMCAP Program generally requires a minimum $10,000 investment. Minimum Account values for eligibility to invest in Liquid Alternative Funds and securities in Models provided by Model Managers are determined by JPMS from time to time. Currently, JPMS requires a minimum Account value of $250,000 for a client to elect to invest in Liquid Alternative Funds. Clients with at least $750,000 in their Program Accounts and that have elected to include Liquid Alternative Funds in their Accounts can also elect to have assets within an Investment Strategy invested in individual securities in accordance with one or more Models following Model portfolios provided by Model Managers. The Form ADV, Part 2A for each Model Manager selected for a client’s Program Account is available at the SEC’s website at adviserinfo.sec.gov. Accounts that fall below these minimums as a result of client withdrawals will be rebalanced by the trade implementation team to a Model without Alternative Funds or other securities through Model Managers. JPMS, at its sole discretion, can waive or alter the minimum Account values to be eligible to invest in Liquid Alternative Funds or in other securities through 33813_COL 11-05-2025 Page 14 of 35  Sub-Advisory Responsibility in MFAP The Sub-Adviser does not engage portfolio managers to manage Program Accounts. Rather, clients select Funds for their Accounts and designate the specific asset allocation percentage desired for each asset class (within the approved asset allocation ranges). who perform these functions are shared with JPMCB, an affiliate of JPMS and the Sub-Adviser, and perform substantially similar services for other clients. The Sub-Adviser periodically reviews the Program composition and asset allocation and performance of the Investment Strategies with JPMS. In MFAP, after the effective date of any changes to the target asset allocation or approved asset allocation ranges for a Model, JPMS notifies affected clients of the changes and whether clients need to rebalance to the updated asset allocation to continue the Program Account. Research Process The Sub-Adviser is responsible for creating target strategic asset allocations and approved asset allocation ranges for each Model, as well as for selecting Funds in each asset class to be made available to clients for their MFAP Accounts, which are selected from Funds that are made available for use in MFAP by an internal governance committee. Clients designate the specific asset allocation percentage desired for each asset class (within the approved asset allocation ranges). Clients also select one or more Funds in each asset class for their Accounts from those Funds available in the Program. JPMPI’s investment activities in MFAP are subject to the oversight of and pursuant to an investment policy statement approved by JPMS. Removal and Replacement of Funds in MFAP The Sub-Adviser uses research from the manager solutions team of JPMPI or any of its affiliates to research, select and monitor Funds and Model Managers. The manager solutions team of JPMPI or any of its affiliates is comprised of employees of 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, Models and Investment Strategies that are available for use in the relevant Programs and is responsible for researching and selecting Funds and Model Managers as well as for subjecting them to a review process. The due diligence process is designed to subject both JPMPI and non-J.P. Morgan Investment Strategies to the same process. However, JPMPI and its strategies are reviewed through different processes which are described below. JPMS determines the number of Funds in an asset class and the overall design of MFAP. The Sub-Adviser will make a new Fund available to Program clients upon JPMS’ request, if the Sub-Adviser seeks to fill a gap in the Funds available in the Program, or if a Fund is terminated and no Fund available in the Program is an appropriate replacement. If a Fund has been terminated from the Program, all new and additional purchases and rebalances allocated to the terminated Fund will be allocated to cash. The Fund shares held in Program Accounts will be sold and replaced with another Fund in the same asset class or the proceeds will be allocated to cash. When evaluating a replacement Fund, the Sub-Adviser is expected to consider the same factors described above and will notify JPMS of the replacement fund. JPMS will notify affected clients in writing of the Fund termination and the recommended replacement Fund for the Program Account assets invested in the terminated Fund. If clients do not select an alternative replacement Fund within the requested timeframe, the client’s assets will automatically be re-invested into the designated replacement Fund. A client who does not approve of the replacement Fund must select an alternative Fund. Removal and replacement of Funds can cause income tax consequences and/or penalties. At times, the alternative Fund will be a J.P. Morgan Fund. JPMIM and its strategies or Model Portfolios are subject to the same selection and review processes conducted by the manager solutions team as the unaffiliated Portfolio Managers and strategies or Model Portfolio Provider and Model Portfolios in the Program, though the manager solutions team applies its discretion and is not required to apply all factors equally to each Fund in the search universe. JPMPI’s strategies are subject to the separate though similar review process incorporating similar quantitative and qualitative assessments and implemented by an internal governance committee which provides ongoing oversight of the relevant programs to review compliance with strategy-specific guidelines and metrics. However, the JPMPI strategy review process does not include a search process to identify a universe and core peer set of strategies from which to select. From time to time, this governance committee may place the relevant programs on probation or terminate them as part of its ongoing monitoring and oversight responsibilities. This committee considers analysis and recommendations from an internal due diligence team separate from the manager solutions team. Refer to the JPMPI Form ADV Part 2A for more information about the applicable research process and its methods of analysis. The manager solutions team of JPMPI or any of its affiliates will determine, when appropriate, that a Fund be put on probation. A Fund on probation will not be available to new clients. Existing clients can continue to hold shares and purchase additional shares of a Fund on probation, or they can choose a different Fund in that asset class. If a Fund on probation is reactivated, clients will be notified. If a Fund on probation is terminated, it will be replaced as described above. Sub-Adviser’s Discretionary Investment Process Depending on the requirements of the Program, the Sub-Adviser is responsible for determining asset allocation, selecting Funds and Model Managers, determining portfolio construction and evaluating Investment Strategies on an ongoing basis subject to the oversight of, and pursuant to, an investment policy statement approved by JPMS. Refer to “Use of J.P. Morgan Funds and Investment Strategies and Potential Conflicts of Interest” below for important information on the use of J.P. Morgan Funds and affiliated Model Managers. Asset Allocation Process The manager solutions team of JPMPI or any of its affiliates applies its discretion and is not required to apply all factors equally to each Fund in the search universe. J.P. Morgan maintains certain capacity limitations on investment positions in non-J.P. Morgan Funds due to liquidity concerns, regulatory requirements, and related internal policies. In circumstances where these limitations mean that the Sub-Adviser would not be able to invest all desired client assets in a particular non-J.P. Morgan Fund, the manager solutions team of JPMPI or any of its affiliates will likely recommend a J.P. Morgan Fund. The manager solutions team of JPMPI or any of its affiliates will begin the search process by defining an applicable universe of managed strategies, which typically will include J.P. Morgan managed strategies when there is one in the 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 then recommends particular Funds and Model Managers to an internal governance committee, 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 and Model Managers as part of its ongoing review process. Centralized Due Diligence The Sub-Adviser is responsible for establishing and updating the overall strategic and tactical asset allocations for the Models and Investment Strategies. Asset allocations are based on the firm’s long-term capital market assumptions, as well as correlation between asset classes. Each Investment Strategy’s asset allocation mix is selected to have the appropriate level of risk and return for such investment strategy. This process includes an internal committee. These asset allocations generally are the overall basis for the process described below. The JPMPI personnel The manager solutions and operational due diligence teams of JPMPI or any of its affiliates provide research on Funds and Portfolio Managers. The “Qualitative Research Process,” is used by the Programs. An operational due diligence review is performed on Funds, Portfolio Managers and Model 33813_COL 11-05-2025 Page 15 of 35  The Sub-Adviser also can, for portfolio construction reasons, remove a Fund, SMA or Model Manager from the Programs. A Fund or Model Manager Investment Strategy that is put on probation can be held in a client Account, but generally, the Sub-Adviser will not direct new purchases until the Fund or Model Manager is removed from probation. During the probation period, the manager solutions and operational due diligence teams of JPMPI or any of its affiliates will continue to review the Fund or Model Manager. Generally, a Fund or Model Manager that is terminated will be sold in a client Account, and the Sub- Adviser will not direct new purchases of that Fund or Model Manager. Managers identified through the Qualitative Research Process. In the Qualitative Research Process, the manager solutions team of JPMPI or any of its affiliates conducts a qualitative analysis of Funds, Portfolio Managers and Model Managers on an ongoing basis. The team reviews the Portfolio Manager’s and Model Manager’s organization, investment process, investment philosophy and performance. As part of the due diligence process, JPMPI also applies an ESG eligibility framework that establishes minimum criteria for determining the universe of funds and strategies to be considered for inclusion in JPMPI sustainable investing and ESG strategies, and conducts a periodic review to confirm the ongoing applicability of the designation of such funds and strategies as JPMPI sustainable investing and ESG strategies. Funds and SMA Managers may be removed from (or no longer be eligible for purchase in) the applicable J.P. Morgan advisory programs if they do not continue to meet these criteria. If the Sub-Adviser removes a Fund or Model Manager from the Programs, the assets held in client Accounts will be sold and replaced with another Fund or Model Manager that is approved for use in the Program without notice to clients. When evaluating a replacement Fund or Model Manager, the Sub-Adviser is expected to consider the same factors described above. Initial Fund and Investment Strategy Review and Approval If a Fund or Model Manager is terminated, the Sub-Adviser will determine whether to re-invest Program account assets in a replacement Fund or Model Manager, and the Sub-Adviser will determine the specific Fund or Model Manager in which to re-invest the assets, using the factors described above. B. Advisory Program and FIAP Portfolio Managers and Model Managers Available in the Advisory Program and FIAP The internal governance committee approves or rejects new Funds, Portfolio Managers and Model Managers to be made available for the Sub- Adviser to use in the Programs. There can be Funds, Portfolio Managers or Model Managers that are not available in the Programs but that are available in other 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 committee for review. The internal governance committee generally considers the same factors in its review and approval process for J.P. Morgan and non–J.P. Morgan managed strategies. These factors include, 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. Portfolio Construction The Portfolio Managers available in FIAP are solely affiliated Portfolio Managers and in the Advisory Program, are both affiliated and non- affiliated Portfolio Managers and Model Managers. JPMS uses the same criteria to evaluate affiliated and non-affiliated Portfolio Managers and Model Managers, except in the case of its affiliate JPMPI (refer to “Affiliated Portfolio Managers and JPMS Conflicts” below). JPMS has a conflict of interest in including affiliated Portfolio Managers and Model Managers in the Program because JPMS and/or its affiliates will receive additional compensation when affiliated Portfolio Managers and Model Managers are selected by clients. For more information, refer to “Important Information About Your Investments and Potential Conflicts of Interest” below. From the pool of strategies, for JPMCAP and CSP, the Sub-Adviser selects the combination of Funds and/or SMAs or Model Managers that, in its view, fit each Model or Investment Strategy’s asset allocation goals and investment objectives. In making portfolio construction decisions, the Sub- Adviser will consider and is permitted to prefer J.P. Morgan Funds, including the Six Circles Funds, and affiliated SMA Managers. The Sub- Adviser is also more likely to select a J.P. Morgan Fund in circumstances where it would not be able to invest all desired client assets in a particular non-J.P. Morgan Fund due to capacity limitations as described under “Research Process” above. Refer to “Important Information About Your Investments and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. JPMS is not responsible for the performance of any Portfolio Manager or Model Manager in the Program or any Portfolio Manager’s or Model Manager’s compliance with laws or regulations, or other matters within the Portfolio Manager’s or Model Manager’s control. Each Portfolio Manager is solely responsible for the management of its designated Accounts. JPMS coordinates services with the Portfolio Manager and Model Manager but is not responsible for coordinating services among multiple Portfolio Managers or Model Managers if the client has allocated assets among more than one Portfolio Manager or Model Manager. MFAP clients select one or more Funds in each asset class for their Accounts from the Funds available in the selected asset allocation model. Portfolio Implementation The Portfolio Managers and Model Managers in the Program manage the same or substantially similar strategies to those offered in the Program for clients of other affiliated and non-affiliated entities. The Advisory Fees charged for these strategies can be higher or lower than the Advisory Fee charged in the Program, and the strategies may not be handled identically to the Investment Strategies made available in the Program. JPMPI (as Overlay Manager) provides portfolio implementation for each individual CSP and JPMCAP client’s Program Account. In MFAP, JPMS, not the Sub-Adviser, is responsible for the portfolio implementation in each individual client’s Account. Ongoing Review of Approved Funds and Investment Strategies reviews. JPMS engages JPMPI to provide research services and perform initial and ongoing reviews of Portfolio Managers, Model Managers, and Investment JPMPI also makes Strategies, and perform periodic recommendations to JPMS about which Portfolio Managers, Model Managers and/or Investment Strategies to include in the Program. JPMS as Program Sponsor has an internal governance committee that seeks to ensure that the Programs offer suitable investment products to clients and that assets in the Programs are managed in a compliant manner consistent with the goals of the Programs and applicable law, and that fulfills JPMS’ fiduciary duties, as sponsor, to Program clients. Another internal governance committee is responsible for the ongoing monitoring and oversight of Funds and Model Managers as approved and available for the Programs. From time to time, this internal governance committee may place them on probation or terminate them as part of its ongoing monitoring and oversight responsibilities. The factors considered by the committee are generally the same for J.P. Morgan and non– J.P. Morgan managed strategies, as further described under “Research Process” above. In addition, the Sub-Adviser may be limited from making additional purchases of a Fund due to capacity considerations. 33813_COL 11-05-2025 Page 16 of 35  Selection of Portfolio Managers, Model Managers and Investment Strategies in the Programs JPMS reviews or arranges for the review of Portfolio Managers, Model Managers, and their Investment Strategies to determine whether they should be included in the Programs. JPMS selects the Portfolio Manager, Model Manager and Investment Strategies based upon the research services, including recommendations, provided by JPMPI and such other information and resources that JPMS deems appropriate. The research services provided by JPMPI are described further below. During the course of the portfolio management of a client Account, for certain strategies, a client can change their Customized Portfolio for a municipal bond portfolio or taxable bond portfolio Account. Clients can decide whether (1) to immediately restructure the entire Account based on the new Customized Portfolio or (2) to adjust the Account as existing bond positions mature in accordance with the new Customized Portfolio. If the client does not elect for (1) or (2) as previously described, the Portfolio Manager will apply option (2) as a default. The client portfolio may hold positions that are not in line with the new Customized Portfolio if option (2) is applied. For preferred strategies, clients can only restructure an entire preferred portfolio Account. Immediately restructuring the entire Account to the new Customized Portfolio can result in taxable events upon the sale of positions. Clients should consult with their own tax professional to understand any such consequences. JPMPI Manager Research Services for Advisory Program and FIAP Investment Strategies The decision to include a particular Portfolio Manager, Model Manager and Investment Strategy in the Program is based upon the totality of the results of the review process and does not necessarily reflect a rigid application of any or all of the processes or guidelines applied. JPMS can remove a particular Portfolio Manager, Model Manager and/or Investment Strategy from the Program at any time for any reason and will notify clients that have selected that Portfolio Manager, Model Manager and/or Investment Strategy of the removal. A Portfolio Manager or Model Manager typically manages Investment Strategies that are made available through the Program. Each Portfolio Manager and Model Manager available through the Program has entered into a contract with JPMS to manage a model or client Accounts as set forth in the Investment Advisory Services Account Agreement provided to clients. JPMPI’s Investment Strategy Selection Process for the Multi-Manager Strategies in the Advisory Program JPMPI, as Portfolio Manager of the Multi-Manager Strategies, is responsible for portfolio construction, including selecting Funds and Model Managers for these Investment Strategies. JPMPI’s process for selecting Funds and Model Managers as available for Portfolio Managers of the Multi-Manager Strategies is described below. Refer to “Use of J.P. Morgan Funds, and Investment Strategies and Potential Conflicts of Interest” below for important information on the use of J.P. Morgan Funds and affiliated Model Managers. In providing the manager research services, JPMPI expects to generally follow a similar process to the one described above under “Research Process,” “Strategy Approval,” “Ongoing Review of Approved Strategies,” and “Portfolio Construction” in Item 6.A. JPMPI Review Process for Multi-Manager Investment Strategies JPMS has engaged JPMPI to perform manager research services regarding the Advisory Program and FIAP Investment Strategies for potential inclusion in the Advisory and Fixed Income Advisory Programs. The manager research services that JPMPI performs for JPMS include: (1) recommending the Portfolio Manager or Model Manager to an internal governance committee, which is responsible for approving or rejecting them for use in the Programs, (2) providing ongoing review of the Portfolio Manager or Model Manager, and (3) determining appropriate Portfolio Managers or Model Managers be placed on probation or terminated. The FIAP Investment Strategies are managed by an affiliated Portfolio Manager, JPMIM. The Advisory Program Investment Strategies are managed by affiliated Portfolio Managers and Model Managers, including JPMIM and JPMPI, and unaffiliated Portfolio Managers and Model Managers. JPMPI uses its manager solutions and operational due diligence teams to provide the manager research services. In providing the manager research services for the Advisory Program and FIAP Investment Strategies, JPMPI expects to generally follow a similar process to the one described under “Research Process,” “Strategy Approval,” “Ongoing Review of Approved Strategies,” and “JPMPI Review Process for Advisory Program and FIAP Investment Strategies,” above. Refer to “JPMPI’s Investment Strategy Selection Process for the Multi-Manager Strategies in the Advisory Program” above for manager research services for multi-manager strategies available in the Advisory Program. The manager research services JPMPI provides to JPMS for the Advisory Program and FIAP Investment Strategies are not advisory services provided by JPMPI or tailored to clients of the Advisory or Fixed Income Advisory Programs. JPMS (not JPMPI) is solely responsible for selecting the Advisory Program and FIAP Portfolio Managers to be made available in the Advisory and Fixed Income Advisory Programs, based upon the information and recommendations provided by the manager solutions team of JPMPI or any of its affiliates and such other information and resources that JPMS deems appropriate. The Multi-Manager Investment Strategies are subject to an initial and ongoing internal review process by JPMPI. This is different from the review process applied by JPMPI to other Investment Strategies in the Advisory Program and the FIAP described below and does not involve the manager solutions team of JPMPI or any of its affiliates or follow the same JPMPI governance procedure for placing an Investment Strategy on probation or terminating ongoing monitoring and oversight responsibilities for an Investment Strategy. However, JPMPI does have a process for taking action on the Multi-Manager Investment Strategies, if warranted, as a result of its ongoing internal review process. Availability of Customized Services for Clients in FIAP Investment Strategies JPMPI has the authority to place an Advisory Program or FIAP Portfolio Manager or Model Manager on probation or to terminate it from the Advisory Program or Fixed Income Advisory Program. When the manager solutions team of JPMPI or any of its affiliates’ monitoring process uncovers a significant enough concern, it will notify JPMS and will place the Advisory Program or FIAP Portfolio Manager or Model Manager on probation or terminate it from the Advisory Program or Fixed Income Advisory Program. JPMPI can terminate its manager research services on Advisory Program or FIAP Portfolio Managers or Model Managers at any time. Potential Conflicts of Interest in the Research and Advisory Program and FIAP Investment Strategies Taxable, Municipal and Preferred Investment Strategies are available and can be customized to individual client investment needs to various degrees depending on the Investment Strategy selected. In municipal bond portfolio strategies and taxable bond portfolio strategies, clients have the ability to select certain customizations (e.g., state preference, minimum credit quality options). The credit quality parameters that each client selects for a particular Account only apply at the time the Portfolio Manager initially purchases a particular bond for that Account. The Portfolio Manager may or may not liquidate bonds upon a credit rating downgrade. As a result, an Account can hold bonds with a credit rating below the client-selected parameter. In Preferred portfolio strategies, clients have the ability to select from an option for tax treatment. Collectively, all of the customizations are considered to be a “Customized Portfolio.” Depending on the Program, JPMPI recommends Investment Strategies managed by JPMPI, JPMIM or unaffiliated third parties for approval in the Programs. JPMPI has an incentive to recommend, and JPMS has an incentive to include, JPMPI and JPMIM-managed Investment Strategies because J.P. Morgan receives more overall fees when these strategies are chosen by clients. Similarly, with respect to manager termination, JPMPI 33813_COL 11-05-2025 Page 17 of 35  has a greater incentive to recommend the termination of unaffiliated third- party managers from the Programs and a greater incentive to terminate unaffiliated portfolio managers, particularly where the manager’s strategy is similar to one offered by JPMPI or JPMIM. For additional potential conflicts of interest, refer to Item 9.C., below. Affiliated Portfolio Managers and Model Managers and JPMS Conflicts replacement Investment Strategy (if any), JPMS will consider the appropriateness of the Investment Strategies available in the Program as suitable replacements for the removed Investment Strategy. JPMS also will assist the client in identifying a suitable replacement Portfolio Manager, Model Manager and/or Investment Strategy in cases where JPMS does not designate a default replacement Investment Strategy or in cases where JPMS does recommend liquidation, when an Investment Strategy is discontinued, or where the client wishes to consider alternatives to the default replacement Investment Strategy designated by JPMS. Such assistance is typically based on the same types of factors used by JPMS to identify Portfolio Managers, Model Managers, and Investment Strategies for Program clients in the first instance. JPMIM and JPMPI are affiliates of JPMS that act as Portfolio Managers in the Program. JPMIM is the Portfolio Manager and Model Manager for certain Advisory Program Investment Strategies and FIAP Investment Strategies and JPMPI is the sole Portfolio Manager for Multi-Manager Investment Strategies. The replacement Portfolio Manager can decline the Account if it deems the client’s investment restrictions unreasonable or if the client’s Account is below the replacement Portfolio Manager’s minimum account size. The replacement Portfolio Manager can sell securities to align the Account with its Investment Strategy, which can have tax consequences for clients. JPMIM and its Investment Strategies in the Program are subject to the same selection and review processes, conducted by the manager solutions team of JPMPI or any of its affiliates, as unaffiliated Portfolio Managers and Investment Strategies available in other Programs, though the manager solutions team of JPMPI or any of its affiliates applies its discretion and is not required to apply all factors equally to each Fund in the search universe. JPMPI’s strategies are subject to the separate though similar review process incorporating similar quantitative and qualitative assessments but implemented by different governance processes and committees. However, the JPMPI strategy review process does not include a search process to identify a universe and core peer set of strategies from which to select. For disclosures on the distinct review process over JPMPI and its Multi-Manager Investment Strategies and potential conflicts related to research and review processes conducted by JPMPI, refer to “Potential Conflicts of Interest in the Research and Review of the Advisory Program and FIAP Investment Strategies” and “JPMPI Review Process for Multi-Manager Investment Strategies” above. The manager solutions team of JPMPI or any of its affiliates’ review of FIAP and the Advisory Program Portfolio Managers and Model Managers and their Investment Strategies, as well as other information and events, also may result in the Portfolio Manager, Model Manager and/or one or more of its Investment Strategies in the Program being closed to new investors pending further review. During such status, clients cannot select the Portfolio Manager, Model Manager and/or Investment Strategy for the first time, but clients with Program assets already being managed according to an affected Investment Strategy when it was closed to new investors are permitted to contribute additional assets to such client’s Account(s). Clients invested according to an affected Investment Strategy will be notified in writing that the Portfolio Manager, Model Manager and/or Investment Strategy have been closed to new investors. Further review of the affected Portfolio Manager, Model Manager and/or Investment Strategies by the manager solutions team of JPMPI or any of its affiliates can result in a re-opening to new investors. Recommendations of Portfolio Managers and Model Managers in the Advisory Program and FIAP for Particular Clients JPMS has a conflict of interest in: (1) including JPMIM and JPMPI in the Program; (2) conducting, or having an affiliate research services provider (i.e., JPMPI) conduct, initial and periodic reviews of affiliated Portfolio Managers and their Investment Strategies in the Program; (3) identifying JPMIM, JPMPI and their Investment Strategies in the Program to clients; and (4) designating JPMPI and JPMIM Investment Strategies as default replacement Investment Strategies for Program Accounts invested in Investment Strategies that are removed from the Program when a client selects (or is re-invested into) one of their Investment Strategies. JPMS and its affiliates receive more total revenue than if the client were able to select an Investment Strategy of an unaffiliated Portfolio Manager. JPMS manages this conflict through disclosure to clients and by subjecting affiliated Portfolio Managers and Model Managers to a comprehensive review process. Termination, Removal, Discontinuance and Replacement of Portfolio Managers, Model Managers and Investment Strategies In connection with opening a Program Account, clients complete a client Profile that requests information about the client’s financial situation, investment experience, investment objectives, time horizon and risk tolerance. Based upon this information, the client, with the consultation of the IAR, will specify in what asset class the Account will be invested. An example of an asset class is Fixed Income. An example of an asset class subgroup is the LMS strategy which is a subgroup of fixed income that seeks to address specific fixed income investment objectives. Examples of investment style are U.S. Large Cap Growth, U.S. Small Cap Value, Municipal Fixed Income and Taxable Fixed Income. Based upon the client’s asset class selection, the IAR will provide the client with information about the Portfolio Managers and Model Managers available in the Program in the selected asset class and investment style and will assist client in selecting a Portfolio Manager or Model Manager. JPMS identifies suitable Investment Strategies for a client based on the investment objectives and other information provided by the client in the investment proposal. Clients are solely responsible for the selection of Portfolio Managers and Model Managers and Investment Strategies from among those identified by JPMS. JPMS and JPMPI cannot ensure that a given Investment Strategy’s investment objective will be attained. Important Information About Your Investments and Potential Conflicts of Interest As a result of JPMPI’s research services and recommendations, and/or other information and events, Portfolio Managers, Model Managers and/or specific Investment Strategies may be terminated, replaced, removed or discontinued from the Programs, in which event JPMS will notify affected clients and will either designate a Portfolio Manager, Model Manager or Investment Strategy in the Program as the default replacement for the Program Account assets invested in the removed Portfolio Manager, Model Manager or Investment Strategy, or recommend liquidation of clients’ securities in the Portfolio Manager, Model Manager or Investment Strategy. Discontinued Investment Strategies will be liquidated. If JPMS designates a default replacement or liquidation, each affected client will be notified in writing that, unless the client affirmatively selects, in writing, a replacement Investment Strategy in the Program by the date specified by JPMS (within 30 days of notification), the client’s assets will automatically be re-invested into the designated replacement Investment Strategy, without further notice to or consent of the client. In the case of a liquidation recommendation or liquidation of a discontinued Investment Strategy, the Program Account will be terminated from the Program and transferred to a JPMS limited purpose brokerage account. In designating a default The Portfolio Managers and Model Managers available in the Program include Portfolio Managers and Model Managers affiliated with JPMS. JPMS has a conflict of interest including affiliated Portfolio Managers and Model Managers in the Program because JPMS and/or its affiliates and parent company will receive more overall compensation when those Portfolio Managers and Model Managers are selected by clients. JPMS manages this conflict through disclosure to clients and by subjecting affiliated Portfolio 33813_COL 11-05-2025 Page 18 of 35  Managers and Model Managers to a comprehensive review process. For more information on the review of affiliated Portfolio Managers, refer to “Affiliated Portfolio Managers and Model Managers and JPMS Conflicts” above. Information About Portfolio Managers, Model Managers and Investment Strategies Account): (1) when J.P. Morgan invests in an investment product, such as a mutual fund, structured product, SMA, or hedge fund issued or managed by a J.P. Morgan affiliate, such as JPMIM or JPMPI; (2) when a J.P. Morgan entity obtains services, including trade execution and trade clearing, from a J.P. Morgan affiliate; (3) when J.P. Morgan receives payment as a result of purchasing an investment product for a client’s Account; or (4) when J.P. Morgan receives payment for providing services (including shareholder servicing, recordkeeping or custody) with respect to investment products purchased for a client’s Account. Other conflicts will result because of relationships that J.P. Morgan has with other clients or when J.P. Morgan acts for its own account. teams select those Except for FIAP, where only affiliated Investment Strategies are made available, depending on the investments available in each Program, Investment Strategies are selected from both J.P. Morgan and third-party asset managers and are subject to a review process by J.P. Morgan manager research teams. From this pool of Investment Strategies, J.P. Morgan portfolio construction Investment Strategies J.P. Morgan believes fit its asset allocation goals and forward-looking views in order to meet the investment objective of the Investment Strategy or portfolio. JPMS provides clients and prospective clients with information about Portfolio Managers and Model Managers that is provided by third parties and is based on and/or incorporates information provided by Portfolio Managers and Model Mangers, and other third-party sources. JPMS believes that this information is accurate; however, JPMS does not independently verify or guarantee the accuracy or completeness of the information. JPMS shall have no liability with respect to information provided by Portfolio Managers or Model Managers. Performance information included in the information provided by JPMS is provided by Portfolio Managers. This performance is calculated by the Portfolio Managers themselves or by third parties, and neither JPMS nor a third party (except when JPMS acts as Implementation Manager for certain Model Portfolios in the Advisory Program) engaged by it reviews Portfolio Manager performance information for JPMS to determine or verify its accuracy or its compliance with presentation standards. Portfolio Manager performance information is not calculated on a uniform and consistent basis. As a general matter, J.P. Morgan prefers J.P. Morgan managed strategies. J.P. Morgan expects the proportion of J.P. Morgan managed strategies will be high (in fact, up to 100 percent) in strategies, such as, for example, cash and high-quality fixed income, subject to applicable law and any account- specific considerations. J.P. Morgan may allocate a significant portion of the assets in JPMCAP, CSP and Multi-Manager Investment Strategy to J.P. Morgan Funds. That portion varies depending on market or other conditions. Program clients typically receive a quarterly performance review prepared by JPMS summarizing the investment performance of the client’s Account(s) for the prior quarter. In preparing such reviews for Program clients, JPMS uses various industry standards to measure Account performance. Clients receiving periodic written performance reviews from JPMS should review carefully the disclosures, definitions and other information contained in the reviews. Portfolio Manager Disclosure Documents and Performance While J.P. Morgan’s internally managed Investment Strategies generally align well with J.P. Morgan’s forward-looking views, and J.P. Morgan is familiar with the investment processes as well as the risk and compliance philosophy of the J.P. Morgan, it is important to note that J.P. Morgan receives more overall fees when internally managed Investment Strategies are included. In certain Programs (e.g., as discussed in Item 4 above, clients can elect to exclude from their JPMCAP Accounts investments in J.P. Morgan Funds and affiliated Model Managers), J.P. Morgan offers the option of choosing to exclude J.P. Morgan managed strategies (other than cash and liquidity products) in certain portfolios. Clients will receive one or more Portfolio Manager Disclosure Documents. Clients should review the Portfolio Manager Disclosure Document carefully for important information about the Portfolio Manager, including risks associated with the selected Investment Strategy (if applicable). Each Portfolio Manager is solely responsible for the truthfulness, completeness and accuracy of its own disclosure document. The J.P. Morgan Six Circles Funds (defined below) are mutual funds advised by JPMPI and sub-advised by third parties. Although considered internally managed strategies, neither JPMPI nor its affiliates retain a fee for Fund management or other Fund services. JPMS is not responsible for the performance of any Portfolio Manager or any Portfolio Manager's compliance with applicable laws and regulations or other matters within the Portfolio Manager's control (except when JPMS acts as Implementation Manager for certain Model Portfolios in the Advisory Program). Separately Managed Accounts Investment Strategies invested in individual equity or fixed income securities may be managed by JPMS affiliates or by a third-party manager. When an affiliate manages these investments, there is a benefit to J.P. Morgan since it increases the overall revenue of J.P. Morgan. Additionally, a manager of an SMA may invest in products that may result in additional revenue to J.P. Morgan. Each Portfolio Manager is solely responsible for the management of that Portfolio Manager's designated Account(s). If a client selects more than one Portfolio Manager, the Portfolio Managers may engage in contrary transactions with respect to the same security. JPMS will effect transactions for an Account only if and to the extent instructed by a Portfolio Manager. JPMS shall not be responsible for any act or omission of any Portfolio Manager or any misstatement or omission contained in any document prepared by or with the approval of any Portfolio Manager or any loss, liability, claim, damage or expense whatsoever, as incurred, arising out of or attributable to such misstatement or omission. IMPORTANT INFORMATION ABOUT MUTUAL FUNDS AND EXCHANGE- TRADED FUNDS REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, AS AMENDED Portfolio Managers are responsible for obtaining best execution. To learn more about Portfolio Manager trading and execution practices, refer to each Portfolio Manager's Portfolio Manager Disclosure Document. C. Use of J.P. Morgan Funds and Investment Strategies and Potential Conflicts of Interest Investment Principles and Potential Conflicts of Interest J.P. Morgan Funds — Management Fees. J.P. Morgan and its affiliates are the sponsor or manager of Funds, including ETFs, that can be purchased for accounts. In such case, J.P. Morgan or its affiliates will receive a fee for managing such Funds or for providing other services to such Funds based on the value of the assets invested in the Funds. As such, J.P. Morgan and its affiliates will receive more total revenue when the client’s portfolio is invested in such Funds than when it is invested in third-party Funds. When a retirement account can be invested in J.P. Morgan Funds, the retirement account will be credited an amount equal to the account’s pro rata share of all such fees paid to J.P. Morgan or its affiliates in connection with the account’s investments in J.P. Morgan Funds. Conflicts of interest will arise whenever J.P. Morgan has an actual or perceived economic or other incentive in its management of our clients’ accounts to act in a way that benefits J.P. Morgan. Conflicts will result, for example (to the extent the following activities are permitted in a client’s 33813_COL 11-05-2025 Page 19 of 35  J.P. Morgan Funds and Third-Party Funds — Other Fees and Expenses market or other conditions. There are multiple Investment Strategies available in JPMPI Multi-Manager Strategies. Certain Investment Strategies invest only in mutual funds and ETFs, while other Investment Strategies also utilize Model Managers. The following chart illustrates, as of the date indicated, the allocation of J.P. Morgan Funds (excluding Six Circles Funds), non–J.P. Morgan Funds, Six Circles Funds and J.P. Morgan cash for JPMPI Multi- Manager Strategies. The chart does not reflect strategies that utilize Model Managers. For the Dynamic Multi-Asset Strategy, the chart does not reflect models that elect not to use J.P. Morgan Funds. The chart assumes the sweep vehicle is J.P. Morgan Cash. October 6, 2025–Multi-Manager Investment Advisory Strategies J.P. Morgan Funds Non-J.P. Morgan Funds Six Circles Funds J.P. Morgan Cash All Funds have various internal fees and other expenses that are paid by managers or issuers of the Funds or by the Funds themselves, but that ultimately are borne by the investor. These fees and expenses are in addition to any fees paid to JPMS or received by JPMIM for acting as Portfolio Manager. J.P. Morgan may receive administrative and servicing fees for providing services to both J.P. Morgan Funds and third-party Funds that are held in a client’s Account. Refer to the discussion of “Share Classes” in Item 4 above for more information on the receipt of administrative and servicing fees. Clients can review the applicable prospectuses for Funds (including Liquid Alternative Funds, as applicable) for more information about these fees and expenses. These payments may be made by sponsors of the Funds (including affiliates of J.P. Morgan), or by the Funds themselves, and may be based on the value of the Funds in the client’s Account. Funds or their sponsors may have other business relationships with J.P. Morgan outside of its portfolio management role or with its broker-dealer affiliates of J.P. Morgan, which may provide brokerage or other services that pay commissions, fees, and other compensation. J.P. Morgan Six Circles Funds 10.00% 88.00% 0.00% 2.00% 0.00% 98.00% 0.00% 2.00% J.P. Morgan developed the J.P. Morgan Six Circles Funds (Six Circles Funds) exclusively for use in JPMC investment advisory accounts. Since October 2018, the Six Circles Funds have been available in Program Accounts where JPMPI is sub-adviser. 28.00% 71.00% 0.00% 1.00% 0.00% 99.00% 0.00% 1.00% 29.00% 70.00% 0.00% 1.00% 29.00% 70.00% 0.00% 1.00% Six Circles Funds are specifically designed for use in discretionary Program Accounts as completion funds to align with JPMC core portfolio views. JPMPI acts as investment adviser to the Six Circles Funds and engages third- party investment managers as sub-advisers to the Six Circles Fund investment portfolios. JPMC will have certain benefits and efficiencies from investing account assets in the Six Circles Funds instead of unaffiliated Funds; however, JPMC does not retain investment advisory fees for managing the Six Circles Funds through an agreement to waive any investment advisory fees that exceed the fees owed to Six Circles Fund third-party sub-advisers. Six Circles Funds do not pay fees to JPMC for any other services to the Six Circles Funds. Services to the Six Circles Funds are provided by third-party service providers and are generally paid by the Six Circles Funds or JPMC. (The market value of assets invested in the Six Circles Funds will be included in calculating the advisory fees paid on the overall portfolio.) 9.00% 90.00% 0.00% 1.00% 0.00% 99.00% 0.00% 1.00% Multi- Manager Investment Strategy Dynamic Multi-Asset Strategy Dynamic Multi-Asset Strategy – Non-Prop Dynamic Yield Strategy Emerging Markets Growth and Income Strategy Liquidity Management Strategy Liquidity Management Strategy – Retirement Sustainable Equity Strategy Sustainable Fixed Income Strategy Affiliated SMA and Model Managers in CSP, JPMCAP and the Advisory Program With respect to SMA and Model Managers, when an affiliate serves as Model Manager, there is a benefit to J.P. Morgan since it increases the overall revenue of J.P. Morgan. Additionally, both affiliated and unaffiliated Model Managers can invest in products that can result in additional revenue to J.P. Morgan. Sub-Adviser Allocation of Assets in CSP and JPMCAP Six Circles Fund shares may only be purchased in Program Accounts for which JPMC has investment discretion. Should the Client choose to close its discretionary Program Account but retain the interest in Six Circles Funds, Six Circles Fund shares must be held through an eligible brokerage account and no new purchases into the Six Circles Funds will be permitted (other than dividend reinvestment). Since the Six Circles Funds are completion portfolios designed to complement and work as part of the overall discretionary portfolio and are not intended to be standalone investments, each Six Circles Fund may underperform as a standalone investment, even in instances where the overall portfolio performs as intended. Further, the overall performance and liquidity of a Six Circles Fund may be negatively affected, and additional transaction costs may be incurred by the Six Circles Fund, as a result of (i) allocation decisions made by JPMC to shift discretionary client assets among the Six Circles Funds and other investments and (ii) allocation decisions made by JPMC to shift Six Circles Fund assets among different investment strategies and sub-advisors, which may negatively affect the value of Six Circles Fund shares even if they are no longer held through a JPMC portfolio. risks, charges, and expenses, go For more information about the Six Circles Funds, including the funds’ objectives, to sixcirclesfunds.com/literature or contact your IAR for a prospectus. Read the prospectus carefully. Allocation of J.P. Morgan Funds in the Advisory Program JPMPI can allocate a significant portion of the assets in a JPMPI Multi- Manager Strategy to J.P. Morgan Funds. That portion varies depending on JPMPI can allocate a portion of the assets in CSP and JPMCAP to J.P. Morgan Funds. That portion varies depending on market or other conditions. There are multiple Models in each of the Investment Strategies available in CSP and JPMCAP. Certain Models invest only in mutual funds and ETFs, while other Models can also invest in Liquid Alternative Funds and individual securities through Model Managers and SMAs. The prior composition of Investment Strategies in CSP and JPMCAP is not intended to predict the future composition of Investment Strategies or use of J.P. Morgan Funds in CSP and JPMCAP. The use of J.P. Morgan Funds, non–J.P. Morgan Funds and 33813_COL 11-05-2025 Page 20 of 35  October 6, 2025–Retirement Models CSP Investment Strategy Six Circles Funds J.P. Morgan Funds Non-J.P. Morgan Funds J.P. Morgan Cash JPMorgan Money Market Funds in a client’s Account will depend on the client’s asset level, the Model selected, reasonable restrictions placed by the client on the management of an Account, and other factors. Each client should review account opening documentation, confirmations, and quarterly and annual statements for more information about the actual allocation in their Account. 2.00% 74.00% 23.00% 1.00% Fixed Income Focused Conservative 4.00% 59.00% 36.00% 1.00% 5.00% 54.00% 40.00% 1.00% 6.00% 52.00% 41.00% 1.00% 7.00% 57.00% 35.00% 1.00% 8.00% 26.00% 65.00% 1.00% Moderate Moderate Growth Growth Aggressive Growth The following charts for CSP and JPMCAP show the allocation of assets between J.P. Morgan and non-J.P. Morgan Funds by Fund type for each Investment Strategy. The charts do not reflect models that elect not to use J.P. Morgan Funds, Models that elect only Index-Oriented Vehicles, or models that utilize Liquid Alternative Funds (other than the Aggressive Growth Investment Strategy because all Aggressive Growth Investment Strategies include Liquid Alternative Funds), Model Managers, or municipal fixed income options. The charts show the difference between the taxable and retirement Models in each Investment Strategy (except for the U.S. Focused Model). October 6, 2025–Retirement Models* Six Circles Funds JPMCAP Investment Strategy J.P. Morgan Funds Non-J.P. Morgan Funds J.P. Morgan Cash 13.00% 57.00% 29.00% 1.00% Allocations shown here are illustrative only, do not necessarily represent actual use of J.P. Morgan Funds and third-party issuers and managers represented in any particular client’s Account, and can change without notice. In CSP and JPMCAP, JPMPI has full discretionary authority to select securities, investment vehicles, SMAs and Model Managers, and is not required to adhere to the illustrative allocations pictured here. Aggressive Growth Growth 7.00% 57.00% 35.00% 1.00% October 6, 2025–Taxable Models Balanced 6.00% 52.00% 41.00% 1.00% 4.00% 59.00% 36.00% 1.00% CSP Investment Strategy Six Circles Funds J.P. Morgan Funds Non-J.P. Morgan Funds J.P. Morgan Cash 8.00% 26.00% 65.00% 1.00% 2.00% 74.00% 23.00% 1.00% 9.00% 61.00% 29.00% 1.00% Fixed Income Focused Conservative 4.00% 59.00% 36.00% 1.00% 3.00% 56.00% 40.00% 1.00% 0.00% 99.00% 0.00% 1.00% 4.00% 54.00% 41.00% 1.00% 4.00% 95.00% 0.00% 1.00% Conservative Managed Equities Managed Fixed Income U.S. Focused Balanced ESG 6.00% 58.00% 35.00% 1.00% 4.00% 30.00% 65.00% 1.00% Moderate Moderate Growth Growth Aggressive Growth * US Endowments & Foundations is not available to retirement accounts. Balanced ESG and JPMCAP models utilizing J.P. Morgan Affiliated Funds are available to certain retirement accounts. October 6, 2025–Taxable Models Refer to Item 9, section C for more information on Potential Conflicts of Interest. Credits for Retirement Accounts holding J.P. Morgan Funds JPMCAP Investment Strategy J.P. Morgan Funds Non-J.P. Morgan Funds Six Circles Funds J.P. Morgan Cash Aggressive Growth 13.00% 57.00% 29.00% 1.00% Growth 7.00% 57.00% 35.00% 1.00% Balanced 6.00% 52.00% 41.00% 1.00% Conservative 4.00% 59.00% 36.00% 1.00% If a Program Account owned by an IRA, or other client that is a qualified retirement plan subject to the prohibited transaction provisions of Section 4975 of the IRC, holds any J.P. Morgan Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with Program Account assets will be credited against the Advisory Fee. Refer to “Offset of Certain Fees to IRAs and Certain Other Retirement Plan Accounts” in Item 4 above. 8.00% 26.00% 65.00% 1.00% Prospectus Delivery for Discretionary Accounts 9.00% 61.00% 29.00% 1.00% Managed Equities Managed Fixed Income U.S. Focused 0.00% 99.00% 0.00% 1.00% 4.00% 95.00% 0.00% 1.00% 3.00% 96.00% 0.00% 1.00% Balanced ESG US Endowments & Foundations and with respect to A discretionary investment adviser can receive prospectuses and other issuer-related materials on behalf of a client for any mutual funds and ETFs in a client’s account with client authorization. JPMS or JPMPI, as a client’s agent, will have access to the prospectuses and issuer-related materials and can rely upon them to make mutual fund and ETF investments on the client’s behalf; however, clients will no longer receive such prospectuses or issuer-related materials directly but can access them via the issuer’s website or request copies from their advisor at any time. Prospectuses and issuer-related materials contain important information and detailed descriptions of additional fees and expenses, investment minimums, risk factors and conflicts of interest disclosures as well as client’s rights, liabilities responsibilities such contains other general this Brochure investments. Additionally, information regarding fees and expenses, risk factors and conflicts of interest. 33813_COL 11-05-2025 Page 21 of 35  Risk of Loss important to the management of the portfolio’s assets, the portfolio could suffer material adverse effects, including substantial share redemptions that could require the portfolio to sell portfolio securities at times when markets are not favorable. 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. Set forth below are certain material risk factors that are associated with the Programs. There are certain other risk factors described elsewhere in this Brochure. For a more complete summary of material risk factors and conflicts of interest associated with the Program, refer to the applicable Portfolio Manager’s Form ADV Part 2A and/or any applicable prospectuses or other relevant disclosure documents. GENERAL RISKS 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, or be otherwise harmful. J.P. Morgan typically incorporates human oversight to reduce the risk of acting on potentially defective outputs. AI Tools present Data Sources Risk, Cybersecurity Risk and Model Risk (as further 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. Further, 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. including Data Sources Risk. Although J.P. Morgan obtains data, alternative data, and information from third party sources that it considers to be reliable, J.P. Morgan does not warrant or guarantee the accuracy 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 the data to J.P. Morgan 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 provided by 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, embargoes, tariffs, sanctions and other trade barriers, regulatory events, other governmental trade or market control programs and related geopolitical events. 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, pandemics or endemics. AI Tools often use data feeds from a number of sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tool will be unable to properly function or their operation may be adversely impacted. The 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. Infectious Disease Risk. The effects of any future pandemic or other global events to business and market conditions may have a significant negative impact on the performance of the separately managed accounts and JPMorgan Fund investments; increase separately managed account and fund volatility; exacerbate pre-existing political, social and economic risks to separately managed accounts and J.P. Morgan Funds; 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 pandemic or other global events that affect the instruments in which a separately managed account or J.P. Morgan Fund invest, 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 pandemic or other global events and the extent to which the associated conditions and governmental responses impact a separately managed account or J.P. Morgan Affiliated Fund will also depend on future developments, which are highly uncertain, difficult to accurately predict and subject to frequent changes. Regulatory Risk. There have been legislative, tax, and regulatory changes and proposed changes that may apply to the activities of JPMS that may require legal, tax and regulatory changes, including requirements to provide additional information pertaining to a client Account to the Internal Revenue Service (IRS) or other taxing authorities. Regulatory changes and restrictions imposed by regulators, self-regulatory organizations and exchanges vary from country to country and may affect the value of client investments and their ability to pursue their investment strategies. Any such rules, regulations and other changes, and any uncertainty in respect of their implementation, may result in increased costs, reduced profit margins and reduced investment and trading opportunities, all of which would negatively impact performance. Key Personnel Risk. If one or more key individuals become unavailable, including any of the portfolio managers of an Investment Strategy, who are 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, improper release, corruption and destruction of, or unauthorized access to, confidential 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 can 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 which 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 cybersecurity defenses or plans of its service providers, financial intermediaries and companies in which they invest or with which they do business. Use of AI Tools may lead to increased risks of cyber 33813_COL 11-05-2025 Page 22 of 35  attacks or data breaches and the ability to launch more automated, targeted, and coordinated attacks, due to the vulnerability of AI technology to cybersecurity threats. 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. Tax Risks and Risks That Apply to Tax-Harvesting and Tax-Managed Investment Strategies. Account transactions can give rise to tax liability for which the client is responsible. Certain securities may generate unwanted excise taxes, income taxes and penalties under the Internal Revenue Code of 1986, as amended, any or all of which may affect the client’s return on investment and exempt tax status. JPMS nor any of its affiliates provide tax or legal advice. Clients should consult their own tax professional with respect to the federal, state and local tax consequences of investing in any Investment Strategy including, the potential application and impact of Section 1091 of the Internal Revenue Code of 1986, as amended, and the corresponding Treasury regulations (the wash sale rules) with respect to the client’s accounts inside or outside of J.P. Morgan. The client is responsible for complying with all applicable tax rules, including, but not limited to, the wash sale rules. Clients have the ability to select tax-managed or tax-aware strategies (each such strategy, a Tax-Managed strategy). There are risks and limitations associated with Tax-Managed strategies, and these limitations may result in tax-inefficient trades and wash sales. Tax management is not tax advice and may not achieve the intended results. Although Tax-Managed investment strategies may reduce a client’s taxable income, it will not eliminate it. These strategies may require trade-offs that reduce pre-tax income. Managing an Account or Investment Strategy to maximize after- tax returns may also potentially have a negative effect on an Account or Investment Strategy’s performance. To the extent tax consequences are considered in managing an Account or Investment Strategy, the Account’s or Investment Strategy’s pre-tax performance may be lower than that of a similar Investment Strategy that is not tax managed. Certain Tax-Managed Investment Strategies utilize tax-loss harvesting from positions which have experienced a capital loss. In certain market conditions, or when portfolio positions have not otherwise experienced capital losses during the relevant tax period, tax-loss harvesting opportunities will be limited. 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. lead to The manager of a Tax-Managed strategy may change the strategy’s parameters, including the manner and frequency of tax harvesting, at any time without notice. Generally, such strategy entails a repurchase of the sold security after the “wash sale” (i.e., 30-day) period. However, the wash sale rules apply to securities transactions in not only that Account but also to securities transactions in all other accounts held by the client, their spouse and certain entities controlled by the client and the client’s spouse. Tax-Managed strategies will not necessarily consider trading activity in any of these other securities accounts, and it is the client’s responsibility to comply with the wash sale rules with respect to such accounts. Additionally, Tax Managed strategies are not customized to a client’s specific tax circumstances; incorrect assumptions about the client’s tax attributes and transactions outside of the strategy may inefficient tax management. This may have an adverse effect on investment performance and result in adverse tax consequences. In addition, clients may engage in wash sale rule transactions in certain strategies as a result of trading activity for risk management purposes, among other reasons, and, in these instances, the tax benefit of this trading activity will be limited and clients may have additional tax liability. The client is responsible for understanding the merits and consequences of tax harvesting. Model Risk. Some Investment Strategies can include the use of various proprietary quantitative or investment models. Investments selected using models may perform differently than expected as a result of changes from the factors’ historical — and predicted future — trends, and technical issues in the implementation of the models, including, for example, issues with data feeds. Moreover, the effectiveness of a model may diminish over time, including as a result of changes in the market and/or changes in the behavior of other market participants. A model’s return mapping is based partially on historical data regarding particular economic factors and securities prices. The operation of a model, similar to other fundamental, active investment processes, may result in negative performance, including returns that deviate materially from historical performance, both actual and pro-forma. For a model-driven investment process – and again similar to other, fundamental, and active investment processes, there is no guarantee that the use of models will result in effective investment outcomes for clients. Additionally, client accounts with lower asset levels can experience some dispersion from the established models. As a result of tax considerations, a portfolio may dispose of certain securities or fail to acquire certain securities, which could adversely impact pre-tax returns. In addition, the deductibility of losses recognized within the portfolio may be subject to certain limitations depending on a client’s particular circumstances, such as investments they make outside the portfolio and the aggregate net capital losses they recognize during the year. Clients should speak with their own tax professional regarding the proper treatment of transactions in their 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 Mutual funds and exchange-traded funds may make large distributions of interest and dividends to investors at various times in a calendar year, and 33813_COL 11-05-2025 Page 23 of 35  • the client will be liable for taxes on such distributions without regard to the date of the client’s investment in an Investment Strategy. Exchange-Traded Funds 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, an ETF trades like a 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 funds, there are specific risks to consider with respect to an investment in ETFs, including, but not limited to: • index information, allowing Variance from Benchmark Index. ETF and index mutual fund performance may 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 mutual funds (such as mergers and spin-offs) may impact the variance between the performances of the funds and applicable indices. • including with respect Tracking the Index. Certain funds track financial indexes indices in which J.P. Morgan retains various intellectual property rights. As a result, J.P. Morgan may be entitled to receive index licensing fees from unaffiliated licensees of these indices. Affiliates of JPMS may develop or own and operate stock market and other indices based on investment and trading strategies developed by such affiliates. Affiliates of JPMS may also assist unaffiliated entities in creating indices that are tracked by certain ETFs or certain client accounts utilized by JPMS. Some of the ETFs advised by affiliates of JPMS (J.P. Morgan ETFs) seek to track the performance of certain of these indices. In addition, J.P. Morgan may manage client accounts which track the same indices used by the J.P. Morgan ETFs or which may be based on the same, or substantially similar, strategies that are used in the operation of the indices and the J.P. Morgan ETFs. The operation of the indices, the J.P. Morgan ETFs and client accounts in this manner may give rise to potential conflicts of interest. For example, client accounts that track the same indices used by the J.P. Morgan ETFs may engage in purchases and sales of securities relating to index changes to a time different to the implementation of index updates or J.P. Morgan ETFs engaging in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the J.P. Morgan ETFs’ 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 or less favorable performance relative to that of the index and the J.P. Morgan ETFs or other client accounts that track the index. Furthermore, JPMS may, from time to time, manage client accounts that invest in these J.P. Morgan include the potential for ETFs. Other potential conflicts unauthorized access to 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, to personnel responsible for coordinating the development and governance of the indices and those involved in decision-making for the ETFs and index mutual funds. 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. • Market-linked Certificates of Deposit (MLCD). MLCDs are a type of structured products (Structure) which are securities whose value is derived from an underlying asset or index. Structures have varying degrees of risk and can offer full or partial principal protection, others can subject you to the loss of the full amount invested. In addition, you are dependent on the issuer’s financial capacity to meet its obligations under a Structure. Structures may not be publicly listed or traded on an exchange and therefore may be illiquid investments. The MLCD strategy typically has a monthly investment process and it can take an extended period of time (e.g., 60 days) for a client's account to be fully invested in the strategy. MLCDs provide principal protection from market downturns because the original principal is not impacted by market activity when held to maturity. There is no guarantee of principal return unless the investment is held to maturity. MLCDs are not publicly listed or traded on an exchange and therefore are illiquid investments. Investing in an MLCD is not the same as investing directly in the underlying asset or index. The return on a MLCD at maturity generally will not be the same as the return on a direct investment in the underlying asset or index, and the maximum payment on a MLCD is subject to a cap, which would limit appreciation potential compared to a direct investment. A cap limits a client’s gain per year regardless of how well the relevant underlying asset or index performs. There are no voting rights or the right to receive dividends, distributions or other payments that would increase the return on a direct investment. Prior to maturity, the market value on the MLCD may change significantly, up or down, over a short period of time reflecting, a number of factors, including any volatility in the underlying asset or index, the time remaining until the MLCD matures, and the issuer's Secondary Market Risk. ETF shares are bought and sold in the secondary market at market prices. Although ETFs are required to calculate their 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. Further, 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 would vary substantially from the NAV per share of such ETF, and the client may incur significant losses from the sale of ETF shares. 33813_COL 11-05-2025 Page 24 of 35  creditworthiness. The amount of principal or interest that can be expected to become payable on a MLCD may vary substantially from time to time. There is no guarantee that any payment in excess of the original MLCD value will be paid. • Capped upside potential risk. The return on certain MLCDs may be capped by a predetermined maximum return cap and, as a result, may be lower than the return on a direct investment in the applicable underlying index. • result, could underperform other strategies that do not have an ESG or sustainable focus. Certain strategies focusing on a particular theme or sector can be more concentrated in particular industries that share common characteristics and are often 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 J.P. Morgan, or an investment manager or investment adviser selected by J.P. Morgan, will align with the beliefs or values of the client. Additionally, other investment managers and investment advisers 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. In addition to the ESG Strategies, J.P. Morgan also offers investment products that utilize ESG criteria in developing the product while seeking to maximize financial return. Federal Deposit Insurance Corporation (FDIC) Protection. MLCDs are insured CDs subject to applicable FDIC limits and regulations. In general, the original value of a MLCD held by clients is insured by the FDIC up to the amount permitted by law per issuer. A client purchasing a principal amount of MLCDs in excess of FDIC insurance limits, when aggregated with all other deposits held by the client at the respective issuer, will be subject to the credit risk of the issuer. In addition, any payment of the MLCD in excess of the applicable FDIC insurance limits is subject to the credit risk of the issuer. • Rate of return. Rate of return is calculated based on the valuation date of the CD based on the particular terms of the contract. There is no guarantee that any payment in excess of the original CD value will be paid. • When evaluating investments, an investment manager or investment adviser 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 uses 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. Principal protection. MLCDs provide principal protection from market downturns because the original principal is not at risk, when held to maturity. The investor is risking the interest that would otherwise be paid on the CD for the term. MLCDs sold before maturity may be worth less than the purchase amount or face value. There is no guarantee of principal return unless the investment is held to maturity. • MLCD Issuer Credit Risk. Any investment in an MLCD that exceeds applicable FDIC insurance limits is subject to the ability of the issuer to make payments when due. If the issuer defaults on its payment obligations, the client may not receive any amount in excess of applicable FDIC insurance limits and could lose all or a significant portion of the initial investment, including the loss of the client's entire investment. In addition, the actual or perceived creditworthiness of the issuer may affect the value of MLCDs prior to maturity. ESG and sustainable investing are not uniformly defined concepts, and scores or ratings may vary across 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 companies 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 sustainability-related practices and the Advisor’s assessment of such practices could change over time. • J.P. Morgan takes a global approach to ESG and sustainable investing, and the solutions offered through our sustainable investing platform meet our internally developed criteria for inclusion in our sustainable investing platform and, where applicable, take into account ESG or sustainable investing regulations. As part of the due diligence process, the manager solutions team of JPMPI or any of its affiliates applies an eligibility framework that establishes minimum criteria for determining the universe of funds and strategies to be considered for inclusion in the ESG Strategies offered to our clients. Early liquidation and secondary market risk. MLCDs are highly illiquid, long-term investments and a client may not be able to redeem their MLCD at their discretion. MLCDs are typically not listed on any securities exchange, and there is no guarantee of the existence of a secondary market. Neither the issuer, the Adviser, nor any other person is required to maintain a secondary market for any MLCD. Accordingly, there may be limited opportunities, if any, to redeem MLCDs prior to maturity and a client may be unable to sell their MLCD prior to its maturity date. MLCDs generally are repurchased only by the issuer and only upon terms and conditions acceptable to such issuer, and, in most cases, the MLCDs are non-transferable and non-negotiable. In the event an issuer consents to early liquidation, the client will likely not fully participate in the benefits of the MLCD, such as principal protection, buffers, or enhanced returns. The price offered by the issuer may be lower than the principal amount of the MLCD. • Tax treatment. MLCDs may be treated differently than traditional CDs for tax purposes. Before investing in these products, you should carefully review the disclosures concerning the reporting of interest income and consult a tax adviser if appropriate. finance regulations and the The evolving nature of sustainable 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 difference in 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 an investment to be classified as a “sustainable investment.” Unless otherwise specified and where permitted by applicable law, 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. Risks That Apply Primarily to ESG/Sustainable Investing Strategies Category Restrictions and Exclusions Risks ESG Strategies can follow different approaches. For example, some ESG Strategies select companies based on positive ESG characteristics while Investment approaches that incorporate ESG considerations or sustainable investing can include additional risks. ESG or sustainable investing strategies (together, ESG Strategies), including SMAs, mutual funds and ETFs, can limit the types and number of investment opportunities and, as a 33813_COL 11-05-2025 Page 25 of 35  others may apply screens in order to exclude particular sectors or industries from a portfolio. industries selected or recommended for a portfolio or the securities market as a whole, such as changes in economic or political conditions. 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 or the Portfolio Manager may rely on information about a company, industry classification, industry grouping and/or issuer screening provided by J.P. Morgan, an affiliate service provider or a third party. Equity securities that are included for inclusion in growth strategies are generally those that the IAR or Portfolio Manager believes will experience rapid earnings growth relative to value or other types of stocks. The value of these stocks generally is much more sensitive to current or expected earnings than stocks of other types of companies. Short-term events, such as a failure to meet industry earnings expectations, can cause dramatic decreases in the growth stock price compared to other types of stock. Growth stocks generally trade at higher multiples of current earnings compared to value or other stocks, leading to inflated prices and thus potentially greater declines in value. Category restrictions aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category; however, they do not exclude all companies with any tie or revenue derived from such restricted category. If a client holds an investment that is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event for the client. Equity securities that are included or recommended for inclusion in value strategies are generally those that the IAR or Portfolio Manager believes the market has undervalued, according to the IAR or Portfolio Manager’s estimate of the company’s true worth. An IAR or Portfolio Manager that engages in value investing selects stocks at prices that it believes to be temporarily low relative to factors such as the company’s earnings, cash flow or dividends. A value stock can decrease in price or not increase in price as anticipated by the IAR or Portfolio Manager if other investors fail to recognize the company’s value or the factors that the IAR or Portfolio Manager believes will cause the stock price to increase do not occur. Third-party managers or programs 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. Further, 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. JPMS and its affiliates do not review, guarantee or validate any third-party data, issuer screenings and ratings, screenings or processes. Moreover, processes to implement category restrictions are not absolute, and could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in 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. Certain Investment Strategies or Portfolio Managers may invest or may recommend investments in securities of smaller companies. Investments in smaller companies are generally riskier than investments in larger companies. Securities of smaller companies tend to be less liquid than securities of larger companies. In addition, small companies are generally more vulnerable to economic, market and industry changes. As a result, the changes in value of their securities may be more sudden or erratic than in large capitalization companies, especially over the short term. Because smaller companies may have limited product lines, markets or financial resources or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than large capitalization companies. This may cause unexpected and frequent decreases in the value of an investment. Finally, emerging companies in certain sectors may not be profitable and may not realize earning profits in the foreseeable future. Equity Investment Conversion Risk. A non-equity investment such as a convertible debt obligation, may convert to an equity security. Alternatively, equity securities may be acquired in connection with a restructuring event related to non-equity investments. An investor may be unable to liquidate the equity investment at an advantageous time from a pricing standpoint. The application of category restrictions vary by asset class. Restrictions are not available for all strategies, and JPMS or the Portfolio Manager can reject a restriction if it deems the restriction to be unreasonable or not in line with the strategy. The number of restrictions that a client can select are limited based on the potential impact to the applicable Investment Strategy and potential deviation from the Investment Strategy. Only those restrictions that can be applied by JPMS or the Portfolio Manager will be applied. Other Miscellaneous Investment Risks 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. Methods of Analysis and Risk of Loss - JPMS as Implementation Manager for Model Manager Investment Strategies in the Advisory Program Liquidity Risk. Investments in some equity or other instruments can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. JPMS will implement Model Manager Investment Strategies. When acting as Implementation Manager, JPMS generally purchases and sells in the Accounts investments that are consistent with the Model Portfolios provided by the Model Manager, though JPMS retains investment discretion over the Account investments. Risks That Apply Primarily to Equity Investments Active Trading. Certain Investment Strategies engage in active and frequent trading leading to increased portfolio turnover, higher transaction costs, and the possibility of increased capital gains, including short-term capital gains that are generally taxable as ordinary income. Equity Securities. Investment Strategies that invest in equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in a company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or Geographic and Sector Focus Risk. Certain Investment Strategies concentrate their investments in a region, small group of countries, an industry or economic sector, and as a result, the value of the portfolio will generally be subject to greater volatility than a more geographically or sector diversified portfolio. Investments in issuers within a country, state, geographic region, industry or economic sector that experiences adverse 33813_COL 11-05-2025 Page 26 of 35  regulated as securities markets, may be riskier than other types of investments, and may increase the volatility of a portfolio. economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio may affect the overall value of the portfolio and may cause greater losses than it would in a portfolio that holds more diversified investments. Diversification Risk. Certain asset allocation and model portfolio construction processes assume that diversification is beneficial. This concept is a generally accepted investment principle, although no amount of diversification can eliminate investment risk, and the investment returns of a diversified portfolio may be lower than a more concentrated portfolio or a single investment over a similar period. REITs Risk. The value of real estate securities in general, and REITs in particular, are subject to similar risks as direct investments in real estate and mortgages, and their value will be influenced by many factors including the value of the underlying properties or the underlying loans or interests. The underlying loans may be subject to the risks of default or of prepayments that occur later or earlier than expected, and such loans may also include so-called "subprime" mortgages. The value of these securities will rise and fall in response to many factors, including economic conditions, the demand for rental property, interest rates and, with respect to REITs, the management skill and creditworthiness of the issuer. In particular, the value of these securities may decline when interest rates rise and will also be affected by the real estate market and by the management of the underlying properties. There is no public trading market for private or public non-traded REITs; therefore, such REITs may be more volatile and/or more illiquid than publicly traded REITs and other types of equity securities Focused Portfolio Risk. A focused portfolio Investment Strategy’s portfolio will generally have more volatility risk than a strategy that invests in securities of a greater number because changes in the value of an individual security will have a more significant effect, either negative or positive, on the portfolio’s value. To the extent that the portfolio invests its assets in fewer securities, the portfolio is subject to greater risk of loss if any of those securities lose value. in securities of foreign issuers Foreign Issuers Risk. Investments denominated in foreign currencies are subject to risks in addition to the risks of securities of U.S. issuers. These risks include political and economic risks, civil conflicts and war, greater volatility, expropriation and nationalization risks, sanctions or other measures by the United States or other governments, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in “emerging markets,” which may have relatively unstable governments and less-established market economies than those of developed countries. Concentration of Investments. Clients may concentrate account assets in a region, a small group of countries, or an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors, certain accounts may or may be advised to hold concentrated positions in specific securities. Therefore, at times, an account may or may be advised to hold a relatively small number of securities positions, each representing a relatively large portion of assets in the account. As a result, the value of the account may be subject to greater volatility than a more geographically or sector diversified portfolio. Investments in issuers within a country, state, geographic region, industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio may affect the overall value of the portfolio and may cause greater losses than it would in a portfolio that holds more diversified investments. If the Portfolio Manager assembles a concentrated position in an account, the client assumes the risk of a substantial loss in value to the entire account if there is a decline in the concentrated position or industry sector. Other risks of holding concentrated positions include substantial loss in an account based upon the loss in value of a single security or industry sector and the impact that a large, concentrated position will have on the manager’s ability to diversify the account. ITEM 7 — CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Emerging Markets Risk. International investing bears greater risk due to social, economic, regulatory and political instability in countries in “emerging markets.” Emerging market securities can be more volatile and less liquid than developed market securities. Changes in exchange rates and differences in accounting and taxation policies outside the United States can also affect returns. Investments in foreign currencies and foreign issuers are subject to additional risks, including political and economic risks, greater volatility, civil conflicts and war, currency fluctuations, higher transaction costs, delayed settlement, possible foreign controls on investment, expropriation and nationalization risks, and less stringent investor protection and disclosure standards. These risks are magnified in countries in “emerging markets.” Investment Strategy (or Strategies), JPMS provides to Overlay, Implementation and Portfolio Managers a summary of client information relevant to Overlay, Implementation and Portfolio Managers’ services to the client, including the client’s name, address, Account number, Social Security number or taxpayer identification number, whether the Account is taxable or non-taxable, the client’s selected investment restrictions requested by the client, and the amount to be invested. The information provided to the Overlay, the Implementation and the Portfolio Managers is updated if it becomes materially incorrect, such as in the event that the client changes the investment restrictions. This Item is not applicable to MFAP as MFAP does not involve the engagement of Overlay, Implementation or Portfolio Managers. ITEM 8 — CLIENT CONTACT WITH PORTFOLIO MANAGERS Counterparty Risk. An account may have exposure to the credit risk of counterparties with which it deals in connection with the investment of its assets, whether engaged in exchange traded or off-exchange transactions or through brokers, dealers, custodians and exchanges through which it engages. In addition, many protections afforded to cleared transactions, such as the security afforded by transacting through a clearing house, might not be available in connection with over-the-counter (OTC) transactions. Therefore, in those instances in which an account enters into OTC transactions, the account will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and will sustain losses. This includes where accounts enter into uncollateralized covered agency transactions and derivatives transactions. For CSP and JPMCAP Program Accounts, JPMS, JPMPI, SMA and Model Manager personnel knowledgeable about the management of CSP and JPMCAP Program Accounts are available for client consultation upon reasonable request. IARs can assist clients in contacting such personnel. FIAP and Advisory Program Portfolio Managers and Model Managers are available for consultation by clients upon reasonable request. Clients should contact their IAR if they wish to consult with their Portfolio Manager or Model Manager. Currency Risk. Changes in foreign currency exchange rates will affect the value of certain portfolio securities. Generally, when the value of the U.S. dollar rises in value relative to a foreign currency, an investment impacted by that currency loses value because that currency is worth less in U.S. dollars. Currency exchange rates may fluctuate significantly over short periods of time for a number of reasons, including changes in interest rates. Devaluation of a currency by a country’s government or banking authority also will have a significant impact on the value of any investments denominated in that currency. Currency markets generally are not as 33813_COL 11-05-2025 Page 27 of 35  a copy of the Order, go to sec.gov/ For litigation/admin/2015/33-9992.pdf. The MFAP Program does not engage portfolio managers to manage Program Accounts; clients select Funds for their Accounts. Clients will generally have no contact with the investment advisers of the Funds. JPMS personnel knowledgeable about the management of the MFAP Program Accounts are available for client consultation upon reasonable request. IARs can assist clients in contacting such personnel. ITEM 9 — ADDITIONAL INFORMATION A. Disciplinary Information JPMS has been involved in the following material legal or disciplinary events during the last ten years. 2) On or about July 28, 2016, JPMS and JPMCB entered into a Consent Agreement (Agreement) with the 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. 3) 1) On December 18, 2015, JPMS and JPMCB (together Respondents) entered into a settlement with the SEC resulting in the SEC issuing an order (Order). The Respondents consented to the entry of the Order that finds that JPMS violated Sections 206(2), 206(4), and 207 of the Investment Advisers Act of 1940 and Rule 206(4)-7 and JPMCB violated Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The Order finds that JPMCB negligently failed to adequately disclose (a) from February 2011 to January 2014, a preference for affiliated mutual funds in certain discretionary investment portfolios (the Discretionary Portfolios) managed by JPMCB and offered through J.P. Morgan’s U.S. Private Bank (the U.S. Private Bank) and the Chase Private Client lines of business; (b) from 2008 to 2014, a preference for affiliated hedge funds in certain of those portfolios offered through the U.S. Private Bank; and (c) from 2008 to August 2015, a preference for retrocession-paying third-party hedge funds in certain of those portfolios offered through the U.S. Private Bank. With respect to JPMS, the Order finds that from May 2008 to 2013, JPMS negligently failed to adequately disclose, including in documents filed with the SEC, conflicts of interest associated with its use of affiliated mutual funds in the Chase Strategic Portfolio (CSP) program, specifically, a preference for affiliated mutual funds, the relationship between the discounted pricing of certain services provided by an affiliate and the amount of CSP assets invested in affiliated products, and that certain affiliated mutual funds offered a lower-cost share class than the share class purchased for CSP. In addition, the Order finds that JPMS failed to implement written policies and procedures adequate to ensure disclosure of these conflicts of interest. Solely for the purpose of settling these proceedings, the Respondents consented to the Order, admitted to the certain facts set forth in the Order and acknowledged that certain conduct set forth in the Order violated the federal securities laws. The Order censures JPMS and directs the Respondents to cease-and-desist from committing or causing any violations and any future violations of the above-enumerated statutory provisions. Additionally, the Order requires the Respondents to pay a total of $266,815,000 in disgorgement, interest, and civil penalty. In October 2018, JPMS submitted an 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) reasonably 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 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. Concurrently, on December 18, 2015, JPMCB reached a settlement agreement with the Commodity Futures Trading Commission (CFTC) to resolve its investigation of JPMCB’s disclosure of certain conflicts of interest to discretionary account clients of J.P. Morgan Private Bank’s U.S.-based wealth management business. In connection with the settlement, the CFTC issued an order (CFTC Order) finding that JPMCB violated Section 4o(1)(B) of the Commodity Exchange Act (CEA) and Regulation 4.41(a)(2) by failing to fully disclose to certain clients its preferences for investing certain discretionary portfolio assets in certain commodity pools or exempt pools, namely (a) investment funds operated by J.P. Morgan Asset Management and (b) third-party managed hedge funds that shared management and/or performance fees with an affiliate of JPMCB. The CFTC Order directs JPMCB to cease- and-desist from violating Section 4o(1)(B) of the CEA and Regulation 4.41(a)(2). Additionally, JPMCB shall pay $40 million as a civil penalty to the CFTC and disgorgement of $60 million satisfied by disgorgement to be paid to the SEC by JPMCB and an affiliate in a related and concurrent settlement with the SEC. 4) 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 and controls in place to determine whether eligible customers were eligible to purchase the less expensive share classes. 33813_COL 11-05-2025 Page 28 of 35  in disgorgement, pre-judgment 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 interest, and civil penalty. (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. 5) 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 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 J.P. Morgan Funds, (ii) there was an economic incentive to invest CSP assets in J.P. Morgan 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 J.P. Morgan Fund share classes. Solely for the purpose of settling these proceedings, JPMS consented to the March 2020 Order, with no admissions as to liability. JPMS agreed to pay a total of $325,000 to resolve the KDFI investigation. 6) 8) 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. B. Other Financial Industry Activities and Affiliations JPMS’ primary business is providing brokerage products and services as a bank-affiliated broker-dealer and making available to its customers, in addition to investment advisory services, a variety of bank, securities and insurance products through its affiliates. JPMS’ officers, managers and IARs spend the majority of their time in administrative or supervisory duties with broker-dealer activities rather than investment adviser activities. JPMS is affiliated with several other SEC registered broker-dealers, investment companies, investment advisers, insurance agencies, mortgage companies and JPMCB. Other registered investment advisers, collectively referred to as “J.P. Morgan Asset Management,” are affiliated with JPMS under the common ownership by JPMC. One or more of these affiliated investment advisers, including, but not limited to, JPMIM, serve(s) as the investment adviser to various J.P. Morgan Funds. Program clients, by selecting a Program, Model or Investment Strategy which uses affiliated Portfolio Managers, or by investing in J.P. Morgan Funds within their Program Account, should note that JPMC receives more overall fees. JPMS affiliates will benefit from such selection and/or purchase as the result of receipt of the investment advisory fees. JPMS addresses this conflict through disclosure to clients. In September 2020, JPMS, together with JPMC and JPMCB (collectively, JPMorgan) 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 JPMorgan 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. JPMorgan 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 JPMorgan 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. JPMorgan 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, JPMorgan agreed to pay a total of $920,203,609 to DOJ, CFTC, and SEC, consisting of civil and criminal monetary penalties, restitution, and disgorgement. JPMorgan agreed to cease and desist from any further violations, and also agreed, among other things, to certain cooperation, remediation, and reporting requirements. JPMS can receive as additional compensation distribution (Rule 12b-1) fees on money market fund assets held in Program Accounts. If a client selects a money market fund for which an affiliate of JPMS serves as investment advisor, the client will pay both its pro rata share of the money market funds advisory fees paid to JPMS or an affiliate as well as the Advisory Fee on the assets invested in the money market fund. However, any 12b-1 fees received by JPMS will be credited to the client’s Program Account. 7) 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 33813_COL 11-05-2025 Page 29 of 35  C. Material Relationships with Related Persons and Potential Conflicts of Interest related to such concerns or requirements, in light of the management of multiple portfolios and businesses by JPMS and its affiliates. Such policies preclude JPMS or its affiliates from purchasing certain securities for clients and can cause JPMS to sell certain securities held in client accounts. A potential conflict of interest also can arise if transactions in one account closely follow related transactions in a different account, such as when a purchase increases the value of securities previously purchased by another account or when a sale in one account lowers the sale price received in a sale by a second account. JPMS has several relationships or arrangements with related persons that are material to its investment advisory business or to clients in the Programs. Below is a description of such relationships and some of the conflicts of interest that arise from them. JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest that may arise between JPMS and its affiliates. These policies and procedures include information barriers designed to prevent the flow of information between JPMS and certain other affiliates, as more fully described below. The use of affiliates to provide services to clients creates certain conflicts of interest for JPMS, JPMIM and JPMPI. Among other things, there are financial incentives for JPMS, JPMIM and JPMPI (and their affiliates), including its parent company, JPMC to favor affiliated service providers over non-affiliated service providers, and compensation of supervised persons of JPMS, JPMIM and JPMPI generally is directly or indirectly related to the financial performance of J.P. Morgan. Affiliated Portfolio Managers and Model Managers in the Advisory Program and FIAP JPMS and IARs can recommend to clients Portfolio Managers and Model Managers that are affiliated with JPMS. Should clients select an affiliated Portfolio Manager or Model Manager, it is important to note that JPMC receives more overall fees when affiliated Portfolio Managers or Model Managers are used. JPMS addresses this through disclosure to clients. Affiliated Fund Advisors and Model Managers Conflicts of interest can arise with both the allocation of investment opportunities, including trading opportunities and pricing of trading generally, and the aggregation of orders and allocation of executed transactions specifically, because of market factors or investment restrictions imposed upon JPMS and its affiliates by law, regulation, contract or internal policies. Allocations of transactions resulting from aggregated orders, particularly orders that are only partially completed (due to limits on availability, capacity constraints and other factors) and allocation of investment opportunities generally, would raise a conflict of interest where JPMPI or its affiliates have an incentive to allocate investment opportunities or securities that are expected to increase in value to favored accounts, including affiliated accounts and accounts that pay higher fees. JPMS mitigates this conflict by using guidelines designed by JPMS and affiliates to allocate investment and trading opportunities among similarly situated Program Accounts on a fair and equitable basis over time. A conflict of interest also would arise if transactions in securities in one account closely follow transactions in the same securities in different accounts, especially when the transactions or series of transactions are large in relation to the securities’ trading volume and potentially have market impact, such as when a purchase increases the value of securities previously purchased by the other accounts or when a sale in one account lowers the sale price received in a sale by other accounts. Funds, including money market funds, pay fees and expenses that are ultimately borne by clients. Clients can review the applicable prospectuses for Funds in the Program for additional information about these fees and expenses. These fees and expenses are in addition to the Advisory Fee. Refer to “Other Fees and Expenses” in Item 4 above for more information. JPMS and its affiliates have intercompany arrangements whereby one or more affiliates share personnel for one or more purposes, including the construction and implementation of trade orders for multiple programs and affiliated entities. Any such shared personnel are subject to the policies and procedures of the applicable affiliate when acting on its affiliate’s behalf. Any such shared personnel will have potentially conflicting interests when playing these various roles. Such personnel splitting time and attention between one or more JPMS affiliates creates conflicts of interest in that the time and effort of these shared personnel will not necessarily be devoted exclusively, or even predominately, to JPMS. While the affected affiliates have adopted policies, procedures or guidelines to address conflicts of interest associated with personnel sharing, such policies, procedures or guidelines can differ and there can be no assurance that such policies, procedures or guidelines will successfully eliminate or mitigate all such conflicts in every case. Affiliates of JPMS provide investment advisory and other services to the J.P. Morgan Funds for compensation. Therefore, because JPMS and its affiliates will in the aggregate receive more revenue when Program Accounts are invested in J.P. Morgan Funds than they would receive if the Program Accounts were invested in non–J.P. Morgan Funds, JPMS has a conflict of interest when Program Accounts are invested in J.P. Morgan Funds. The use of affiliated Model Managers in the Programs is also a benefit to JPMS and its affiliates since it increases the overall revenue of affiliates of JPMS and their parent company. JPMS addresses this conflict through disclosure and subjecting the J.P. Morgan Funds and non- J.P. Morgan Funds to the investment process described in Item 6 above. Refer to “Important Information About Your Investments and Potential Conflicts of Interest” in Item 6 above for more information on the use of J.P. Morgan Funds. Conflicts Related to the Advising of Multiple Accounts Securities Allocations and Limitations JPMS is part of a large financial services firm. In connection with providing investment advisory services to its clients, JPMS uses the products or services of its affiliates or other related persons, as described both above and below. JPMS and/or its affiliates can receive more compensation from certain accounts that use strategies similar to those used by Program Accounts (Similar Accounts) than it or its affiliates receive from Program Accounts. JPMS or its affiliates have a conflict of interest to the extent that JPMS or an affiliate has a proprietary investment in Similar Accounts, the Portfolio Managers have personal investments in Similar Accounts, or the Similar Accounts are investment options in JPMS’ or its affiliates’ employee benefit plans. JPMS and its affiliates maintain certain investment limitations on the positions in securities, or other financial instruments, that JPMS or its affiliates will take on behalf of its various clients due to, among other things: (i) liquidity concerns; (ii) operational considerations; (iii) regulatory requirements applicable to JPMS or its affiliates; and (iv) internal policies Certain portfolio managers of JPMS manage or advise multiple client accounts, investment vehicles or portfolios. These portfolio managers are not required to devote all or any specific portion of their working time to the affairs of any specific client. Conflicts of interest do arise in allocating management time, services, or functions among such clients, including clients that have the same or similar type of investment strategies. JPMS addresses these conflicts by disclosing them to clients and through its supervision of portfolio managers and their teams. Responsibility for managing JPMS’ client portfolios is organized according to investment strategies within asset classes. Generally, client portfolios with similar strategies are managed by portfolio managers in the same portfolio management group using the same or similar objectives, approach and philosophy. Therefore, portfolio holdings, relative position sizes, industry and sector exposures generally tend to be similar across client portfolios with similar strategies. JPMS faces conflicts of interest when JPMS’ portfolio managers manage accounts or portfolios with similar investment objectives and strategies. For example, investment opportunities that are appropriate for certain clients may also be appropriate for other groups of clients, 33813_COL 11-05-2025 Page 30 of 35  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 February 26, 2025, the Vanguard Group, Inc. and BlackRock, Inc. hold more than a 5% interest in J.P. Morgan. Payment for Order Flow including the clients of JPMS, other affiliated investment advisers, and related persons, and, as a result, client accounts would have to compete for positions. There is no specific limit on the number of accounts which will be managed or advised by JPMS or its related persons. Once held by a client, certain investments compete with other investments held by other clients of JPMPI and its related persons. The conflict associated with managing assets on behalf of different clients that compete with each other are heightened when JPMS retains certain management, control or consent rights over such assets. JPMS has controls in place to monitor and mitigate these potential conflicts of interest. Also, it is JPMS’ policy, to the extent practicable, to allocate, within its reasonable discretion, investment opportunities among clients over a period of time on a fair and equitable basis. One or more of JPMS’ other client accounts may at any time hold, acquire, increase, decrease, dispose of, or otherwise deal with positions in investments in which another client account would have an interest. For instance, due to differences in investment strategies, JPMS might sell a security for a client at the same time that it might hold or purchase the same security for a different client. Distribution and Other Fees and Revenue Sharing JPMS does not receive payment for order flow from market makers for customer orders in equity securities. JPMS receives rebates from and pays fees to some registered securities exchanges for providing or taking liquidity on those exchanges, according to those exchanges’ published fee schedules approved by the SEC. Alternative trading systems also charge fees and, in some cases, pay rebates for the provision or removal of liquidity. In addition, JPMS receives marketing fees from options exchanges under marketing fee programs sponsored by some exchanges. Under some circumstances, the amount received by JPMS from a trading center over a period of time may exceed the amount that JPMS is charged by a trading center. These practices are one of many factors that may impact routing decisions and do not alter JPMS’ policy to route customer orders in securities to the trading centers where it believes customers will receive the best execution, taking into account, among other factors, price, transaction cost, volatility, reliability, market depth, and speed. JPMS receives distribution fees from certain mutual funds pursuant to Rule 12b-1 under the Investment Company Act of 1940. If JPMS receives 12b-1 fees on load-waived Class A shares, it will credit these fees to the client’s Program Account. JPMS, directly or indirectly, receives servicing or administrative fees for certain Funds that are held in a client’s Account. Refer to the discussion of “Share Classes” in Item 4 above for more information on the receipt of administrative and servicing fees. In addition, JPMS’ affiliates receive licensing fees for their indices used by unaffiliated ETFs or other product sponsors. Affiliates of JPMS have ownership interests in some trading centers. Accordingly, JPMS stands to share in any profits that these trading centers earn from the execution of JPMS customer orders on those trading centers. Additional information on the material aspects of JPMS’ relationships with the primary trading centers to which JPMS routes, including descriptions of arrangements for payment for order flow and profit-sharing relationships, is available in JPMS’ SEC Rule 606 reports at jpmorgan.com/OrderExecution. J.P. Morgan’s Use of Index Products information about JPMS has negotiated revenue sharing arrangements with a number of mutual funds and mutual fund families. Some of these mutual funds are available in the Programs, and JPMS will receive additional revenue on either the mutual fund assets in Program Accounts or on the initial purchase of these mutual funds. Some of the mutual funds make revenue sharing payments to JPMS for mutual funds held in brokerage accounts for which JPMS does not provide investment advisory services. Additional these arrangements is available at jpmorgan.com/TheGuide. IARs are not compensated from JPMS’ receipt of shared revenues received from mutual funds. J.P. Morgan’s Use and Ownership of Trading Systems interest. J.P. Morgan will receive JPMS may effect trades on behalf of Program Accounts through exchanges, electronic communications networks, alternative trading systems, and similar execution systems and trading venues (collectively, Trading Systems), including Trading Systems in which J.P. Morgan has a direct or indirect indirect proportionate ownership compensation based upon its ownership percentage in relation to the transaction fees charged by such Trading Systems in which it has an ownership interest. Such Trading Systems (and the extent of J.P. Morgan’s ownership interest in any Trading System) may change from time to time. JPMS addresses this conflict by disclosure to its clients. Ownership Interest in J.P. Morgan Stock JPMS or one of its affiliates develop or own and operate stock market and other indexes based on investment and trading strategies developed by JPMS or its affiliates or assist unaffiliated entities in creating indexes that are tracked by certain ETFs utilized by JPMS or an affiliate. Some of the ETFs for which an affiliate of JPMS acts as investment adviser (the JPM ETFs) seek to track the performance of these indexes. JPMS and its affiliates from time to time manage client accounts that invest in these JPM ETFs. In addition, JPMS and its affiliates manage client accounts which track the same indexes used by the JPM ETFs or which are based on the same, or substantially similar, strategies that are used in the operation of the indexes and the JPM ETFs. The operation of the indexes, the JPM ETFs and the client accounts in this manner gives rise to potential conflicts of interest. For example, client accounts that track the same indexes used by the JPM ETFs may engage in purchases and sales of securities relating to index changes prior to the implementation of index updates or the time as of which the JPM ETFs engage in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the JPM ETFs’ portfolios are only rebalanced on a periodic basis corresponding with the rebalancing of an index. These differences can result in the client accounts having more favorable performance relative to that of the index and the JPM ETFs or other client accounts that track the index. Other 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 JPM ETFs. JPMS and its affiliates have established certain information barriers and other policies to address the sharing of information between different businesses within JPMS and its affiliates, including with respect to personnel responsible for maintaining the indexes and those involved in decision-making for the JPM ETFs. Other Compensation from ETFs Certain ETFs in which account assets are invested in for the Programs execute transactions for their portfolios through JPMS or an affiliate as broker-dealer, and JPMS or an affiliate receives traditional brokerage in connection with these compensation and fees from the ETFs Certain asset management firms (each, an asset manager) through their funds and separately managed accounts currently hold a 5% or more 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 (collectively, JPM) recommends or purchases the publicly traded security of the asset manager or the separately managed accounts or funds that are managed or advised by the asset manager. JPM addresses this conflict by disclosing the ownership interest of the asset manager and by subjecting the asset manager’s separately managed accounts and funds to a research process. Additionally, the financial advisors 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 33813_COL 11-05-2025 Page 31 of 35  from providing potential adverse effect on JPMS’ clients. In addition, J.P. Morgan derives investment advisory, custody, ancillary benefits administration, prime brokerage, transfer agency, fund accounting and shareholder servicing and other services to JPMS’ clients, and providing such services to JPMS’ clients enhances J.P. Morgan’s relationships with various parties, facilitates additional business development, and enables J.P. Morgan to obtain additional business and generate additional revenue. transactions. Such compensation presents a conflict of interest between JPMS and Program clients because JPMS has a financial incentive to invest Program Account assets in such ETFs: (1) in the hope or expectation that increasing the amount of assets invested with the ETFs will increase the number and/or size of transactions placed by the ETFs 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 ETFs and thereby preserve and foster valuable brokerage relationships with the ETFs. Portfolio Manager Trading Practices in the Advisory Program and FIAP The following are descriptions of certain additional conflicts of interest and potential conflicts of interest that are associated with the financial or other interests that JPMS and J.P. Morgan have in transactions effected by, with or on behalf of its clients. In addition to the specific mitigants described further below, JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit, or mitigate conflicts of interest. In addition, many of the activities that create these conflicts of interest are limited and/or prohibited by law and are conducted under an available exception. Certain Portfolio Managers can execute trades for institutional and other non-wrap fee clients before executing trades for clients in SMA programs, such as the “Advisory Program” and “Fixed Income Advisory Program.” As a result, Program Accounts can pay a higher price, or receive a lower price, than the Portfolio Manager’s trades in the same security for institutional or other clients. Trade execution practices of the Portfolio Managers are described in the Portfolio Manager ADV Disclosure Document, which is provided to Program clients. JPMorgan Chase Bank, N.A. J.P. Morgan or JPMS’ related persons provide financial, consulting, investment banking, advisory, brokerage (including prime brokerage) and other services to, and receive customary compensation from, an issuer of equity or debt securities held by client Accounts. Any fees or other compensation received by J.P. Morgan in connection with such activities will not be shared with the Program clients or used to offset fees charged to Program clients. Such compensation could include financial advisory fees, monitoring fees, adviser fees or fees in connection with restructurings or mergers and acquisitions, as well as underwriting or placement fees, financing or commitment fees, trustee fees and brokerage fees. JPMCB is a national banking association affiliated with JPMS and is subject to supervision and regulation by the U.S. Department of Treasury's Office of the Comptroller of the Currency. JPMCB provides investment management, trustee, custody and other services to both institutional and non-institutional clients. Refer to Item 4 for additional conflicts of interest and other information relating to the sweep Deposit Account. All (or substantially all) IARs are employees of JPMCB. In their capacities as employees of JPMCB and outside of the Program, IARs may market and sell to clients products and services of JPMCB and be compensated in connection with such sales. D. Participation or Interest in Client Transactions and Other Conflicts of Interest J.P. Morgan Acting in Multiple Commercial Capacities Additionally, from time to time, directors, officers and employees of JPMC serve on the board of directors or hold another senior position with a corporation, investment fund manager or other institution which may desire to sell an investment to, acquire an investment from or otherwise engage in a transaction with, JPMS clients. The presence of such persons in such circumstances may require the relevant person to recuse themselves from participating in a transaction or cause JPMS, a corporation, investment fund manager or other institution to determine that it (or its client) is unable to pursue a transaction because of a potential conflict of interest. In such cases, the investment opportunities available to JPMS clients and the ability of such clients to engage in transactions or retain certain investments or assets will be limited. J.P. Morgan’s Policies and Regulatory Restrictions Affecting Client Accounts As part of a global financial services firm, JPMS will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by J.P. Morgan, J.P. Morgan’s roles in connection with other clients and in the capital markets, J.P. Morgan’s internal policies and/or potential reputational risk. As a result, client accounts managed by JPMS may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by J.P. Morgan. In addition, potential conflicts of interest also exist when J.P. Morgan maintains certain overall investment limitations on positions in securities or other financial instruments due to, among other things, investment restrictions imposed upon J.P. Morgan by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude, JPMS from including particular securities or financial instruments in its portfolios, even if the securities or financial instruments would otherwise meet the investment objectives of such portfolio. For example, there are limits on the aggregate amount of investments by affiliated investors in certain types of securities within a particular industry group that cannot be exceeded without additional regulatory or corporate consent. If such aggregate ownership thresholds are reached, the ability of a client to purchase or dispose of investments, or exercise rights or undertake business transactions, will be restricted. J.P. Morgan is a diversified financial services firm that provides a broad range of services and products to its clients and is a major participant in the global currency, equity, commodity, fixed income and other markets in which JPMS client Accounts invest. J.P. Morgan is typically entitled to compensation in connection with these activities and the Program clients will not be entitled to any such compensation. In providing services and products to clients other than JPMS’ clients, J.P. Morgan from time to time faces conflicts of interest with respect to activities recommended to or performed for JPMS clients on one hand and for J.P. Morgan’s other clients on the other hand. For example, J.P. Morgan has, and continues to seek to develop, banking and other financial and advisory relationships with numerous U.S. and non-U.S. persons and governments. J.P. Morgan also advises and represents potential buyers and sellers of businesses worldwide. JPMS client Accounts have invested in, and in the future may invest in, such entities represented by J.P. Morgan or with which J.P. Morgan has a banking, advisory or other financial relationship. In addition, certain clients of J.P. Morgan, including JPMS clients, invest in entities in which J.P. Morgan holds an interest, including a J.P. Morgan Fund or J.P. Morgan ETF. In providing services to its clients and as a participant in global markets, J.P. Morgan from time to time recommends or engages in activities that compete with or otherwise adversely affect a JPMS client Account or its investments. It should be recognized that such relationships can preclude JPMS’ clients from engaging in certain transactions and can also restrict investment opportunities that would otherwise available to JPMS clients. For example, J.P. Morgan is often engaged by companies as a financial adviser, or to provide financing or other services, in connection with commercial transactions that are potential investment opportunities for JPMS’ clients. There are circumstances in which advisory accounts are precluded from participating in such transactions as a result of J.P. Morgan’s engagement by such companies. J.P. Morgan reserves the right to act for these companies in such circumstances, notwithstanding the 33813_COL 11-05-2025 Page 32 of 35  proprietary accounts of JPMS and/or J.P. Morgan. JPMS and/or J.P. Morgan, within their discretion, can make different investment decisions and take other actions with respect to their proprietary accounts than those made for client accounts, including the timing or nature of such investment decisions or actions. Further, JPMS is not required to purchase or sell for any client account securities that it, J.P. Morgan and any of their employees, principals or agents may purchase or sell for their own accounts or the proprietary accounts of JPMS or J.P. Morgan. JPMS, J.P. Morgan and their respective directors, officers and employees face a conflict of interest as they will have income or other incentives to favor their own accounts or the proprietary accounts of JPMS or J.P. Morgan. Conflicts of Interest Created by Contemporaneous Trading Potential conflicts of interest may also arise as a result of JPMS’ current policy to seek to manage its clients’ accounts so that the various requirements and liabilities imposed pursuant to Section 16 of the Securities Exchange Act of 1934 (Section 16 and the Exchange Act, respectively) are not triggered. Section 16 applies to, among other things, “beneficial owners” of 10% or more of any security subject to reporting under the Exchange Act. In addition to certain reporting requirements, Section 16 also imposes on such “beneficial owner” a requirement to disgorge of “short-swing” profits derived from the purchase and sale or sale and purchase of the security, executed within a 6-month period. JPMPI may be deemed to be a “beneficial owner” of securities held by its advisory clients. Consequently, and given the potential ownership level of the various accounts and funds managed for its clients, JPMS may limit the amount, or alter the timing, of purchases of securities in order not to trigger the foregoing requirements. As a result, certain contemplated transactions that otherwise would be consummated by JPMS on behalf of its clients will not take place, will be limited in their size, or will be delayed. Positions taken by a certain client account may also dilute or otherwise negatively affect the values, prices or investment strategies associated with positions held by a different client account. For example, this can occur when investment decisions for one client are based on research or other information that is also used to support portfolio decisions by JPMS or an affiliate for a different client following the same, similar or different investment strategies or by an affiliate of JPMS in managing its clients’ accounts. When a portfolio decision or strategy is implemented for an account ahead of, or contemporaneously with, similar portfolio decisions or strategies for JPMS or an affiliate's other client (whether or not the portfolio decisions emanate from the same research analysis or other information), market impact, liquidity constraints or other factors could result in one account being disadvantaged or receiving less favorable investment results than the other account, and the costs of implementing such portfolio decisions or strategies could be increased. In addition, it is perceived as a conflict of interest when the activity in one account closely correlates with the activity in a similar account, such as when a purchase by one account increases the value of the same securities previously purchased by another account, or when a sale in one account lowers the sale price received in a sale by a second account. Furthermore, if JPMS or an affiliate manages accounts that engage in short sales of securities in which other accounts invest, JPMS or an affiliate could be seen as harming the performance of one account for the benefit of the account engaging in short sales if the short sales cause the market value of the securities to fall. Also, certain private funds managed by JPMS or its affiliates hold exclusivity rights to certain investments and therefore, other clients are prohibited from pursuing such investment opportunities. E. Account Errors and Resolutions Furthermore, J.P. Morgan has adopted policies and procedures reasonably designed to ensure compliance with economic and trade sanctions-related obligations applicable to its activities (although such obligations are not necessarily the same obligations that its clients are subject to). Such economic and trade sanctions prohibit, among other things, transactions with and the provision of services to, directly or indirectly, certain countries, territories, entities and individuals. These economic and trade sanctions, and the application by JPMS of its compliance policies and procedures in respect thereof, may restrict or limit a client’s account’s investment activities. In addition, J.P. Morgan from time to time subscribes to or otherwise elects to become subject to investment policies on a firm- wide basis, including policies relating to environmental, social and corporate governance. JPMS may also limit transactions and activities for reputational or other reasons, including (i) when J.P. Morgan provides or may provide advice or services to an entity involved in such activity or transaction; (ii) when J.P. Morgan or a client is or may be engaged in the same or a related activity or transaction to that being considered on behalf of the client account; (iii) when J.P. Morgan or a client account has an interest in an entity involved in such activity or transaction; or (iv) when such activity or transaction on behalf of or in respect of the advisory account could affect J.P. Morgan, JPMPI, their clients or their activities. J.P. Morgan may also become subject to additional restrictions on its business activities that could have an impact on Program clients accounts’ activities. In addition, JPMPI may restrict its investment decisions and activities on behalf of particular client accounts and not other accounts. Investing in Securities which JPMS or a Related Person Has a Material Financial Interest Account errors, trade errors and other operational mistakes occasionally occur in connection with the management of Funds and client Accounts. JPMS has developed policies and procedures that address the identification and correction of such errors and generally require that errors caused by JPMS and affecting a client's account be resolved promptly and fairly. Errors can result from a variety of situations, including portfolio management (e.g., inadvertent violation of investment restrictions) trading, processing or other functions (e.g., miscommunication of information, such as wrong number of shares, wrong price, wrong account, executing the order as a buy rather than a sell and vice versa). The intent of the policies and procedures is to restore a client account to the appropriate financial position as determined in good faith by the Adviser based on what it considers reasonable in light of all relevant facts and circumstances surrounding the error. JPMS makes its determinations pursuant to its error policies and procedures on a case-by-case basis, in its discretion, based on factors it considers reasonable. Under certain circumstances, JPMS may consider whether it is possible to adequately address an error through cancellation, correction, reallocation of losses and gains or other means. JPMS and its related persons recommend or invest securities on behalf of its clients that JPMS and its related persons also purchase or sell. As a result, positions taken by JPMS and its related persons may be the same as or different from, or made contemporaneously or at different times than, positions taken for clients of JPMS. As these situations involve actual or potential conflicts of interest, JPMS has adopted policies and procedures relating to personal securities transactions, insider trading and other ethical considerations. These policies and procedures are intended to identify and mitigate actual and perceived conflicts of interest with clients and to resolve such conflicts appropriately if they do occur. The policies and procedures contain provisions regarding pre-clearance of employee trading, reporting requirements and supervisory procedures that are designed to address potential conflicts of interest with respect to the activities and relationships of related persons that might interfere or appear to interfere with making decisions in the best interest of clients, In addition, JPMS has including the prevention of front-running. implemented monitoring systems designed to ensure compliance with these policies and procedures. J.P. Morgan’s Proprietary Investments JPMS, J.P. Morgan and any of their directors, partners, officers, agents or employees also buy, sell or trade securities for their own accounts or the If a trade error is made in a client’s Account, JPMS will take action to make the Account whole. JPMS corrects trade errors in IRA and ERISA Accounts in the impacted Program Account and uses a firm account to correct all other trade errors in non-retirement Program Accounts. If bonds are erroneously sold from a client’s Account, it is possible that JPMS, the 33813_COL 11-05-2025 Page 33 of 35  the Programs and provide clients with nondiscretionary advisory services and Account maintenance support. Implementation Manager or the Portfolio Manager will not be able to find the same bonds to buy back for the Account. In that case, JPMS, the Implementation Manager or Portfolio Manager will purchase bonds that it believes are equivalent in quality and yield. If a client requests that any securities be transferred out of an Account or there is a trade error in an Account, JPMS may temporarily suspend trading in the Account until the transfer is complete or the trade error is remediated. During such time, Fees (as defined in this Item 4) will continue to accrue. F. Code of Ethics JPMS contacts clients at least annually to determine whether there have been any changes in the client’s financial situation, investment objectives or investment restrictions that would require changes to the client’s Program Account. To ensure that the Program and the selected Model, Investment Strategy and/or Portfolio Manager remain suitable for the client, clients are instructed to promptly notify their IAR or JPMS of any material changes to their investment objectives and/or financial situation. Clients are solely responsible for notifying JPMS in the event that any information that JPMS maintains about them is inaccurate or becomes inaccurate. JPMS has adopted a Code of Ethics (the Code of Ethics) pursuant to Rule 204A-1 under the Advisers Act. The Code of Ethics is designed to ensure that JPMS and its supervised persons comply with applicable federal securities laws and place the interests of clients first in conducting personal securities transactions. The Code of Ethics imposes certain restrictions on securities transactions in the personal accounts of supervised persons to help avoid or mitigate conflicts of interest, as described more fully below. A copy of the Code of Ethics is available free of charge to any client or prospective client upon request by contacting a client service representative or your IAR. General As most Program Accounts are managed in a similar manner according to the Model or Investment Strategy selected by the client, JPMS does not review individual trades or individual Program Accounts. As described in this Brochure, JPMS periodically reviews Model composition, Funds available, Investment Strategies, Model Managers and the Portfolio Managers available in the Programs to ensure that the Models, Funds, Model Managers, Investment Strategies and Portfolio Managers continue to meet the Program requirements. For Program Accounts that have requested investment restrictions, JPMS periodically monitors the Accounts to ensure compliance with the accepted investment restrictions. The Code of Ethics contains policies and procedures relating to: • JPMS, JPMPI, JPMIM, Portfolio Managers and Model Manager personnel who are knowledgeable about the management of client Program Accounts are available for client consultation upon reasonable request. including Account holding reports and personal trading, reporting and pre-clearance requirements for all personnel of JPMS; • Confidentiality obligations to clients set forth in the J.P. Morgan privacy notices; interest, which • Conflicts of include guidance relating to restrictions on trading on material non-public information (MNPI). The information in this Brochure does not include all the specific review features associated with each Model, Fund, Investment Strategy, Model Manager and Portfolio Manager. Clients are urged to ask questions regarding JPMS’ or JPMPI’s review process applicable to a particular Model, Model Manager, Fund, Investment Strategy or Portfolio Manager, to read all product-specific disclosures, and to determine whether a particular Model, Model Manager, Fund, Investment Strategy, Portfolio Manager or type of security is suitable for their Account in light of their circumstances, investment objectives and financial situation. Reports to Programs’ Clients Clients receive Account statements from the custodian at least quarterly and also receive quarterly performance reports. Refer to “Trade Confirmations, Statements and Performance Reporting” above. JPMS does not provide tax advice, and discussions with IARs, Account statements and quarterly performance reports should not be construed as tax advice and are not a substitute for the careful review of Account statements or tax reporting forms by clients. In general, the personal trading rules under the Code of Ethics require that accounts of JPMS personnel be maintained with an approved broker and that certain trades in reportable securities for such accounts be precleared and monitored by compliance personnel. The Code of Ethics also prohibits certain types of trading activity, such as short-term and speculative trades. JPMS personnel must obtain approval prior to engaging in all covered security transactions, including those issued in private placements. In addition, JPMS personnel are not permitted to buy or sell securities issued by J.P. Morgan during certain periods throughout the year. Certain Access Persons (defined as persons with access to nonpublic information regarding JPMS’ recommendations to clients, purchases, or sales of securities for client accounts and advised funds) are prohibited from executing personal trades in a security at certain times. In addition, Access Persons are required to disclose household members’ personal security transactions and holdings information. These disclosure obligations and restrictions are designed to mitigate conflicts of interest that arise if Access Persons transact in the same securities as advisory clients. Performance reviews are not a substitute for regular monthly or quarterly brokerage account statements or IRS Forms 1099 and should not be used to calculate the fees or to complete income tax returns. JPMS and its affiliates are entitled to rely on the financial and other information that clients or any third party provides to JPMS. The client is solely responsible for any information that the client provides to JPMS, and JPMS shall not be liable in connection with its use of any information provided by the client or a third party in the periodic review. JPMS and its IARs do not provide tax advice, and nothing in the performance review should be construed as advice concerning any tax matter. Neither JPMS nor any of its supervised persons acts as a Portfolio Manager in the Program. Additionally, all JPMS personnel are subject to the J.P. Morgan firm-wide policies and procedures including those found in the J.P. Morgan Code of Conduct (the Code of Conduct). The Code of Conduct sets forth restrictions regarding confidential and proprietary information, information barriers, private investments, outside business activities and personal trading. All J.P. Morgan employees, including JPMS personnel, are required to familiarize themselves with, comply with and attest annually to their compliance with the provisions of the Code of Conduct’s terms as a condition of continued employment. Where appropriate, JPMS and its affiliates generally address the conflicts disclosed in this Brochure through policies and procedures. G. Review of Accounts Subject to JPMS’ policies and procedures and applicable law, the periodic written performance review provided to Program clients can include information about assets in other accounts. By including such assets in the written performance review, JPMS is not undertaking to provide or be responsible for providing any services with respect to those assets. Clients have ongoing reasonable access, during normal business hours, to an IAR or a centralized team of IARs who are available for consultation regarding clients’ Program Accounts. IARs are an essential component of In preparing Account statements and performance reviews, JPMS may use multiple valuation sources that provide different values for a single asset. As a result, the determination of an Account's asset values may differ for 33813_COL 11-05-2025 Page 34 of 35  different purposes and different statements, reviews and reports. Client Account asset values are available from JPMS upon request. H. Testimonials and Endorsements Program Accounts are offered and sold only through IARs associated with JPMS. In addition to compensating IARs for their provision of investment advisory services to clients on behalf of JPMS, and/or for their referral or introduction of investors who become advisory clients of JPMS, JPMS has entered into agreements with certain unaffiliated third-party solicitors (sometimes also called a “finder,” “referrer” or “promoter”) for their referral of prospective investment advisory clients to JPMS in accordance with Rule 206(4)-1 of the Advisers Act. Under these arrangements, JPMS agrees to pay each finder when a referred prospective client is either referred or becomes an investment advisory client of JPMS. JPMS either pays the finder a flat amount or a specified portion of the Fee it receives and retains relating to each such client’s advisory account. In addition to the third-party referral agreement described above, pursuant to an agreement between JPMS and JPMCB, an affiliate, JPMCB can compensate its employees for referring clients to JPMS for various products and services, including the Program and other advisory products and services. Any such payments to JPMCB employees shall not increase the total account fees paid by the client. Financial Information I. JPMS is not aware of any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to its clients, nor has JPMS been the subject of a bankruptcy petition at any time during the past 10 years. 33813_COL 11-05-2025 Page 35 of 35 

ITEM 6 — PORTFOLIO MANAGER SELECTION AND EVALUATION .. 18 i. Selection of Portfolio Managers, Model Portfolio Providers and/or Program Securities, as applicable ........................... 18 ii. Review of Portfolio Managers, Model Portfolio Providers and/or Program Securities, as applicable ........................... 19 iii. Related Person Portfolio Managers, Model Portfolio Providers and/or Program Securities, as applicable ........... 21 FORM ADV PART 2A APPENDIX 1 WRAP FEE PROGRAM BROCHURE J.P. Morgan Securities LLC iv. Use of J.P. Morgan Funds and Model Portfolio Providers and Potential Conflicts of Interest ............................................. 21 November 5, 2025 v. Allocations of Client Assets to J.P. Morgan Funds (Including New Funds) in JPMCAP and the J.P. Morgan Multi-Manager Strategies in STRATIS .......................................................... 23 383 Madison Avenue New York, NY 10179 (212) 272-2555 vi. Methods of Analysis, Investment Strategies and Risk of Loss 24 SEC File No. 801-3702 jpmorgan.com/adv vii. Performance-Based Fees and Side by Side Management ... 33 viii. Voting Client Securities ....................................................... 33 ix. Prospectus and Issuer-Related Material Delivery for Discretionary Accounts (PM, JPMCAP, J.P. Morgan Multi- Manager Strategies in STRATIS, UMA - Wealth Advisor Discretion) .......................................................................... 34 Portfolio Advisor Program Portfolio Manager Program Strategic Investment Services Program Customized Bond Portfolios Program Unified Managed Account Program Investment Counseling Service Program J.P. Morgan Core Advisory Portfolio Program J.P. Morgan Securities LLC (JPMS or the Firm) sponsors other wrap fee programs in addition to those discussed in this brochure. Clients can obtain brochures for the other programs by contacting us at (212) 272-2555. ITEM 7 — CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ..................................................................................... 34 ITEM 8 — CLIENT CONTACT WITH PORTFOLIO MANAGERS ........... 35 ITEM 9 — ADDITIONAL INFORMATION ........................................... 35 Disciplinary Information ..................................................... 35 i. ii. Other Financial Industry Activities and Affiliations ............. 36 iii. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......................................................... 40 iv. Review of Accounts ............................................................. 46 v. Testimonials and Endorsements ......................................... 48 vi. Financial Information .......................................................... 48 ITEM 4 — SERVICES, FEES AND COMPENSATION This wrap fee disclosure brochure provides information about the qualifications and business practices of JPMS. If you have any questions about the contents of this brochure, please contact us at (212)-272-2555. 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. 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. 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 Financial Industry Regulatory Authority (FINRA). JPMS’ investment advisory services include sponsoring a variety of wrap fee programs and providing certain services to defined contribution plan sponsors. The advisory services described in this brochure are: not insured by the Federal Deposit Insurance Corporation (FDIC); not a deposit or other obligation of, or guaranteed by, JPMorgan Chase Bank, N.A. or any of its affiliates; and subject to investment risks, including possible loss of the principal amount invested. ITEM 2 — MATERIAL CHANGES This brochure (the Brochure) is dated November 5, 2025 and is an interim update to the Brochure. Clients should carefully review this Brochure in its entirety. This section describes the material and/or other changes to the Brochure since the last amendment dated June 27, 2025. JPMS offers investment advisory services through several separate sales channels. Similar wrap fee programs that offer the same and similar investment strategies are offered in different sales channels and at different fee levels with different features and with different execution experiences. The wrap fee clients pay for investment advisory services will vary depending on the investment advisory program clients select. The Form ADV Part 2A Brochure for JPMS is available at jpmorgan.com/adv or by contacting your JPMS Wealth Advisor. ITEM 3 — TABLE OF CONTENTS Many of the tools and analytics that are used to support services provided through JPMS advisory programs are also available through JPMS without enrolling in an advisory program and paying a fee. Further, clients could purchase these services separately from JPMS. However, while clients can obtain similar products and services from JPMS without enrolling in an advisory program, they would not receive the same discretionary or non- discretionary account services offered through the advisory programs; the mutual funds share classes available will generally be more expensive; and the client would generally not be able to obtain the same combination of financial planning and investment advisory services. The overall cost of purchasing the products and services separately will most likely differ from each advisory program’s advisory fees. Clients should consider the value of these advisory services when making such comparisons. This Brochure provides information about JPMS and the following investment advisory programs offered by JPMS through “Wealth Advisors” or “Wealth Partners” ITEM 2 — MATERIAL CHANGES ......................................................... 1 ITEM 3 — TABLE OF CONTENTS ........................................................ 1 ITEM 4 — SERVICES, FEES AND COMPENSATION ............................. 1 i. Services ................................................................................. 2 ii. Fees and Compensation ...................................................... 11 ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ...... 16 Program Minimums ............................................................. 17 i. Types of Clients ................................................................... 17 ii. iii. Employee Benefit Plans and Retirement Plans ................... 17 iv. Acceptance of Accounts ...................................................... 17 v. Cash Balances in Program Accounts ................................... 18 • 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 33823_J 11-05-2025 Page 1 of 49  (collectively referred to herein as Wealth Advisors and each, a Wealth Advisor): Portfolio Advisor Program (PA), Portfolio Manager Program (PM), Strategic Investment Services Program (STRATIS), Customized Bond Portfolios Program (CBP), Unified Managed Account Program (UMA), Investment Counseling Service Program (ICS), and J.P. Morgan Core Advisory Portfolio Program (JPMCAP) (collectively, the Programs). In this Brochure, the term “Portfolio Manager” refers to a client’s affiliated or unaffiliated discretionary investment adviser, sub-adviser or implementation manager, which for certain Programs may be JPMS or its affiliates, including (but not limited to) J.P. Morgan Private Investments Inc. (JPMPI) and/or J.P. Morgan Investment Management Inc. (JPMIM) or in certain Programs, the overlay manager (e.g., the UMA Overlay Manager (as defined below)) and/or a Joint Discretion Manager (as defined below). The term “Model Portfolio Provider” refers to the non-discretionary investment advisers that provide a model portfolio (Model Portfolio). The term “Funds” refers to mutual funds and/or exchange-traded funds (ETFs). Where applicable, JPMS will communicate any client-requested investment restrictions to the Portfolio Manager(s) for an account. All investment restriction requests are subject to acceptance as reasonable by JPMS, in its sole discretion, and where applicable, by the Portfolio Manager(s) in their sole discretion. Note that reasonable investment restrictions will not apply to the underlying portfolio of any Fund that is held or purchased in an account. Along these lines, category investment restrictions will not be applied to strategies that invest only in Funds, nor will they be applied to investments made by Funds, so it is possible that a client’s category investment restriction(s) would not have any practical effect on an account comprised primarily of Funds. The termination or removal of an account from a Program will also terminate any client-imposed investment restrictions previously accepted by JPMS or a Portfolio Manager for that account, and such restrictions will not be applicable to the account as a brokerage account or other account outside of the Program. Where JPMS does not have discretion, JPMS does not monitor for the adherence to investment restrictions. Information about other programs sponsored by JPMS are contained in separate Brochures, which can be obtained upon request from a Wealth Advisor or at the SEC’s website at adviserinfo.sec.gov/IAPD. The Form ADV Part 2A brochure for each Portfolio Manager and Model Portfolio Provider available in certain of the Programs is also available at the SEC’s website at adviserinfo.sec.gov/IAPD. Any restrictions a client imposes on the management of the accounts can limit the ability to make investments or take advantage of opportunities and can cause the account to perform differently than similar unrestricted accounts. Neither JPMS nor the Portfolio Manager are required to accept investment restrictions that they deem unreasonable and may decline an account when they deem any client requested restriction unreasonable. Services i. Please note, however, that the ability to request reasonable investment restrictions is not applicable to accounts in PA. Since PA is a non- discretionary Program in which clients retain final investment decision making authority, clients remain responsible for adhering to any investment restriction they deem appropriate. Generally, JPMS will act as custodian for the securities held in accounts in the Programs. For certain Programs, in limited circumstances, upon a client’s request and direction with JPMS’ consent, a client may utilize the services of certain unaffiliated, third-party qualified custodians to custody the assets held in the client’s Program account(s). Any such arrangements are not included in the fees paid to JPMS and the client will pay any and all separate fees and expenses as agreed upon by and between the client and any such unaffiliated, third-party qualified custodian. As a result of selecting an unaffiliated, third-party qualified custodian, certain programs or services will not be available to clients. To enroll into the wrap fee programs, clients must provide certain information to JPMS including, but not limited to, the client’s investment objectives and risk tolerance. The client must also enter into an investment advisory agreement (the Client Agreement) with JPMS. The Client Agreement governs the terms of existing and future investment advisory accounts and relationships with JPMS. JPMS discontinued the use of separate program-specific agreements for opening new accounts in the programs (but some existing program accounts may have been opened using the separate program-specific agreement). Pursuant to the Client Agreement, clients pay certain asset-based wrap fees for participation in and investment advisory services received through the Programs. In the Programs, JPMS and/or its affiliates typically provide clients not only with investment advice but also with trade execution, clearing, settlement, custody and reporting services. When provided by JPMS, these trade execution, clearing, settlement, custodial and reporting services are included in the fees paid to JPMS. THE PROGRAMS Portfolio Advisor Program (PA) JPMS tailors its investment advisory services to the individual needs of clients in a Program. JPMS’ recommendation of a Program as suitable for a particular client is typically based on the client’s financial circumstances, and the investment objective and risk tolerance (when referred to collectively, the Risk Score) for the assets the client wishes to invest, as well as other information provided by the client prior to opening an account. PA is intended for investors who seek to establish strategic investment goals and receive ongoing investment advice but wish to retain ultimate decision-making authority over the trading activity in their account. PA is not intended for clients who maintain consistently high levels of cash, money market mutual funds or other short-term securities, or for clients who engage in trading activity that is not consistent with the investment advice provided through PA. One or more Wealth Advisors, who are employees and investment advisory representatives of JPMS, will advise the client’s PA account on a non- discretionary basis and provide information and advice in accordance with the client’s Risk Score for the account. This advice may include recommendations to purchase or sell assets in the account. Because PA accounts are advised on a non-discretionary basis, the client’s Wealth Advisor will only effect transactions for the PA account after receipt of client approval to effect a transaction. For most Programs, clients can request reasonable restrictions on management of their account, including, depending on the Program, particular securities or categories of securities related to a sector or industry (e.g., weapons or tobacco) that will be implemented, subject to acceptance by JPMS or the Portfolio Manager and in their sole discretion. JPMS and/or the Portfolio Manager (i.e., STRATIS and UMA) may rely on the information about a company, industry classification, industry grouping and issuer screening provided by J.P. Morgan or a third-party to implement the investment restrictions. Category restrictions aim to screen companies with revenue derived from the restricted category, but they do not exclude all companies with any tie or revenue derived from such restricted category. JPMS does not review, guarantee or validate third-party screenings or processes. Issuer screenings and processes to implement category investment restrictions are not absolute and may change at any time and could result in the portfolio holding investments in companies that derive revenue from the restricted category. If a client’s investment is perceived to belong to the restricted category, such security will be sold and could trigger a taxable event to the client. Based on information the client provides, JPMS assists the client in assessing the client’s investment objectives, risk tolerance, liquidity needs and other relevant factors to help develop a customized target asset allocation for the account in connection with portfolio construction. The client is solely responsible for making all decisions regarding the adoption and implementation of the client’s investment objective, risk tolerance and target asset allocation. Once an allocation is established, JPMS will propose investment recommendations to a client that may include equities, fixed 33823_J 11-05-2025 Page 2 of 49  Approach in PM is distinguished by how JPMS implements and delivers advice to clients in PM. income, Funds and/or other investment vehicles to aid the construction of the investment portfolio. Where suitable and appropriate for a particular client, such recommendations may include options and/or structured products approved for PA. When the client adopts a particular target asset allocation, the actual asset allocation of the client’s PA account changes over time due to fluctuations in the market value of account assets, client additions or withdrawals and/or investment decisions by the client that deviate from JPMS’ advice or the target allocation. JPMS will contact the client periodically to review the PA account to assist the client in ensuring that the account remains consistent with the client’s Risk Score and within appropriate asset allocation parameters. The client retains final decision- making authority and responsibility for the selection of, and any changes to, the investment objective, risk tolerance, the target and/or actual asset allocation, and the particular securities and other assets held in the account. Modeled Strategy Approach. When a client selects the Modeled Strategy approach for their PM account(s), the Wealth Advisor will manage the client’s PM account in accordance with the investment strategy that the client has selected in consultation with the Wealth Advisor, taking into account the client’s financial situation, Risk Score and other information the client has provided for their account(s). The asset allocation of any such account will be based on the Risk Score for the client’s account. Modeled Strategies in PM are constructed and implemented by the Wealth Advisor across such Wealth Advisor’s PM client accounts invested in the same Modeled Strategy. The Risk Score of the strategy will be consistent with the Risk Score of the accounts that are invested in the Modeled Strategy. Not all Wealth Advisors are approved to manage accounts according to this Investment Strategy Approach. JPMS generally permits clients to place unsolicited orders for the purchase and/or sale of securities in PA accounts, subject to any limits, restrictions and/or conditions. JPMS may choose to enforce on such orders and JPMS can, in its sole discretion, decline to accept or effect such an order in a PA account at any time, with or without prior notice to the client. Portfolio Manager Program (PM) Custom Strategy Approach. When a client selects the Custom Strategy approach for their PM account(s), the Wealth Advisor(s) will take into account the client’s account Risk Score and other financial circumstances and information the client has shared to provide specific customization tailored to client’s individual needs. The Risk Score of the strategy will be consistent with the Risk Score of the accounts that are invested in the Custom Strategy. Not all Wealth Advisors are approved to manage accounts according to this Investment Strategy Approach. Strategic Investment Services Program (STRATIS) PM is designed for investors who seek to delegate discretion for investment decisions in their account to certain approved Wealth Advisors. PM is a discretionary Program in which JPMS will manage the PM account on a discretionary basis in accordance with a client’s Risk Score, subject to any reasonable investment restrictions provided to and accepted by JPMS. Management of PM accounts will be implemented by one or more specific Wealth Advisors in accordance with the Wealth Advisor’s individual investment style and strategy or strategies, taking into consideration each client’s financial situation and Risk Score for the particular PM account. Each client’s grant of discretion to JPMS typically includes the client’s authorization of JPMS to invest in securities and other investments including, but not limited to, equities, fixed income, Funds, options, cash and/or cash alternatives at the time and in the manner that JPMS determines. JPMS is also authorized to act on the client’s behalf in all other matters necessary or incidental to the handling of the account, without having to first obtain an “order” from the client or discussing these transactions or actions with the client in advance. One or more Wealth Advisors will be directly responsible for making the investment decisions for the account and will be reasonably available to discuss the management of the account with the client. STRATIS provides clients access to a select group of affiliated and unaffiliated Portfolio Managers and Model Portfolio Providers, each of whom offer a specific investment strategy (equity and fixed income) and market sector expertise. The affiliated Portfolio Managers and Model Portfolio Providers in STRATIS include JPMIM and JPMPI. Clients select the Portfolio Managers or Model Portfolio Providers and investment strategy from among the Portfolio Managers, Model Portfolio Providers and investment strategies made available by JPMS. Portfolio Managers provide discretionary investment management in separately managed accounts. Model Portfolio Providers provide nondiscretionary Model Portfolios to JPMS to implement. Portfolio Managers, Model Portfolio Providers and strategies available through STRATIS are reviewed and approved by J.P. Morgan or one or more third parties engaged by it (which may be affiliates of JPMS) on a periodic basis, as described in further detail below. Accordingly, from time to time, JPMS may add or remove specific Portfolio Managers, Model Portfolio Providers and/or strategies to or from STRATIS, as further discussed below. For PM, the degree of consistency or uniformity with which Wealth Advisors apply a particular investment strategy across all of the Program accounts they manage in the strategy varies based on Wealth Advisor Investment Strategy Approach (as defined below) and strategy; in all cases, however, the client’s individual situation and needs are considered by the Wealth Advisor in their initial assessment of whether any of their strategies is suited to the client’s financial circumstances and achievement of the client’s objective. Only Wealth Advisors that meet certain eligibility requirements (refer to Item 6 “Portfolio Manager Selection and Evaluation”) can participate in PM. Additionally, Wealth Advisors must be approved to participate in PM and manage either or both Modeled or Custom Strategies (as defined below). (each, an Based on the Risk Score that the clients provide to JPMS, the client consults with one or more Wealth Advisors to determine how to invest through STRATIS and for assistance in selecting from the Portfolio Manager(s), Model Portfolio Providers and strategies from among those available through STRATIS. Although JPMS will assist clients in identifying suitable Portfolio Managers, Model Portfolio Providers and strategies in which to invest, clients are responsible for selecting the Portfolio Managers, Model Portfolio Providers and strategy for their accounts. JPMS will notify each Portfolio Manager of a client’s selection of the Portfolio Manager and the applicable strategy. JPMS will also provide each Portfolio Manager with information about the client and the account, as provided by the client during the account opening process. If a Portfolio Manager accepts an account, the Portfolio Manager will manage it on a discretionary basis. JPMS can in its sole discretion refuse to allow a client to utilize a particular Portfolio Manager or strategy through STRATIS. Investment Strategy Approaches in PM. PM currently offers two types of investment strategy approaches Investment Strategy Approach): a Modeled Strategy approach where the client selects an investment strategy or strategies created and managed by a Wealth Advisor on a fully discretionary basis based on the Wealth Advisor’s specified investment method, or a Custom Strategy approach where the client requires some level of customization and grant their Wealth Advisor(s) discretion to implement a custom strategy that takes into account their own individual investment needs and requests. A further description of each PM Investment Strategy Approach is included below. Each Investment Strategy In the event a strategy is removed from STRATIS, JPMS will provide written notice to clients. For certain strategies, JPMS may designate another strategy in STRATIS as the default replacement for the STRATIS assets invested in the removed strategy. If JPMS designates such a default replacement, each affected client will be notified in writing that, unless the client affirmatively selects a replacement strategy by the date specified by JPMS, the client’s assets in the removed strategy will automatically be re- invested into the designated default replacement strategy, without further 33823_J 11-05-2025 Page 3 of 49  notice to or consent of the client. In designating a default replacement (if any), JPMS will consider the appropriateness of the strategies available in STRATIS as suitable replacements for the removed strategy. The sale of the client’s assets in the removed strategy may have tax consequences for the client. To the extent a strategy is removed from STRATIS and another strategy is not designated as a default replacement, the securities would be held in-kind in an unmanaged brokerage account. Any restrictions or customizations will be maintained once the assets are reinvested in the default replacement subject to acceptance by the Portfolio Manager. who provide models of securities for certain investment strategies. The Liquidity Management Strategy is a subgroup of Multi-Manager Strategies and seeks to address specific fixed income investment objectives. Funds available through these certain strategies in STRATIS include both J.P. Morgan Funds (as defined below) and non- J.P. Morgan Funds. Affiliates that sponsor or manage J.P. Morgan Funds may include JPMPI and JPMIM. A substantial portion of the assets in these J.P. Morgan Multi-Manager Strategies are expected to be invested in J.P. Morgan Funds. In addition, unaffiliated and affiliated Model Portfolio Providers will be evaluated and selected for these accounts. In the case of Dynamic Multi-Asset Strategy (DMAS), clients can select a strategy that excludes J.P. Morgan Funds or one that may include J.P. Morgan Funds. JPMS has a conflict in recommending the DMAS strategy that may include J.P. Morgan Funds. If a client requests tax harvesting, JPMS or the Portfolio Manager can sell certain investments at a gain or loss to offset the client’s tax liability. If utilizing tax harvesting, the client’s account holdings can differ from those accounts that do not utilize such election, and therefore performance will likely differ. JPMS or the Portfolio Manager may reject a client’s request for tax harvesting in whole or in part, at its discretion. For certain strategies, Portfolio Managers may not offer tax harvesting services. • Refer to “Use of J.P. Morgan Funds and Model Portfolio Providers and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds and affiliated Model Portfolio Providers. Customized Bond Portfolios Program (CBP) CBP is designed to provide discretionary investment management services in separately managed accounts by an affiliated Portfolio Manager, JPMIM. The Program is designed as a solution for investors with the specific asset class needs or desire to invest in taxable and tax-aware fixed income portfolios consisting of laddered bonds within the risk tolerance of the client’s investor profile. In bond ladder portfolios, the Portfolio Manager buys bonds that have maturities spanning over a designated period of years, and which are intended to be held until maturity. For accounts where JPMS does not have discretion, unless JPMS specifically agrees otherwise, clients are responsible for monitoring a Portfolio Manager’s adherence to or consistency with any investment restrictions or guidelines that have been submitted by the client for the account and accepted by the Portfolio Manager. JPMS has no responsibility for monitoring STRATIS accounts, even if JPMS assisted the client in determining an asset allocation and/or identifying Portfolio Managers and/or strategies. Unless specifically agreed to by JPMS in writing, JPMS is not obligated to provide ongoing advice with respect to the client’s selection of any Portfolio Manager or strategy. JPMS is not responsible for the management of any STRATIS account, including the consistency of the management of any account with the client’s investment objective for the account or any other information provided by the client. CBP portfolios are designed by a team of portfolio managers in JPMIM and are available with different average maturities to fit different needs and risk tolerances. The portfolio management team constructs the portfolios using fundamental credit and relative value analysis combined with ongoing credit and security oversight. The team focuses on identifying and monitoring attractive risk/reward investments within client-specified criteria. CBP portfolios are separately managed accounts that give clients direct ownership of securities and that have several additional features, including that portfolio managers can choose to hold bonds to maturity and can choose to reinvest or withdraw coupon interest income. Customizations subject to acceptance by the Portfolio Manager are available to meet a client’s investment criteria, including, but not limited to state of residence, credit quality, sector, tax treatment, dividend/coupon type, duration preferences and instructions to not reinvest proceeds from maturing bond or bond sales and income. JPMS acts as the implementation manager for certain Model Portfolios provided by Model Portfolio Providers. When JPMS acts as an implementation manager, JPMS provides portfolio implementation and coordination services to accounts with Model Portfolios. Services include: (1) managing the accounts on a discretionary basis by implementing instructions to purchase, hold or sell securities; (2) continuously monitoring the account holdings and coordinating the trading activity; (3) implementing specific reasonable restrictions requested by the client that are placed on the client account; and (4) generally rebalancing the Program account to the allocation in a chosen investment strategy when the asset allocation percentages deviate from established parameters. JPMS will generally purchase and sell in the account investments that are consistent with the Model Portfolios provided by the Model Portfolio Provider, though JPMS retains investment discretion over the account investments. Currently, the only Model Portfolios in STRATIS are those provided by Model Portfolio Providers that are affiliated with JPMS. Review the attached Appendix A for a list of relevant strategies and their objectives. Certain STRATIS Strategies Managed by Affiliates of JPMS. The strategies offered through STRATIS can include those that provide access to affiliated Portfolio Managers or Model Portfolio Providers. Based on information provided to JPMS by a client, JPMS will assist such client in selecting a suitable CBP strategy in which to invest from those made available by JPMS, which currently include the Customized Taxable Bond Portfolio Strategy, the Customized Municipal Bond Portfolio Strategy and the Customized Preferred Portfolio Strategy. Clients should review the Portfolio Manager’s Form ADV 2A for additional risk factors, conflicts of interest and other important information. All CBP accounts are customized to the individual client’s investment needs. • There are strategies for which JPMIM acts as a Portfolio Manager or act as a Model Portfolio Provider. For the strategies in which JPMIM acts as a Model Portfolio Provider, JPMS acts as implementation manager. Refer to the attached Appendix A for a description of strategies for which JPMS acts as implementation manager. • Clients determine how to invest through CBP after consulting with a Wealth Advisor. Clients may request that JPMS assist them in the review, evaluation and/or formulation of investment objectives. Clients are responsible for making all decisions regarding the adoption and implementation of any investment objectives. JPMS will notify the Portfolio Manager of the client’s selection and the strategy and will also provide the Portfolio Manager with information about the client and the account as provided by the client during the account opening process. If the Portfolio Manager accepts an account, the Portfolio Manager will manage it on a discretionary basis. JPMPI provides discretionary investment management services to those clients in STRATIS who select the Multi-Manager Strategies (the J.P. Morgan Multi-Manager Strategies). The J.P. Morgan Multi- Manager Strategies seek to address specific investment objectives, provide exposure to targeted asset classes, capture timely market opportunities, and/or address specific client objectives through actively managed portfolios. These investment strategies may include a variety of marketable securities, such as stocks, bonds, Funds, and may leverage the expertise of Model Portfolio Providers The Portfolio Manager manages client accounts in CBP in accordance with each client’s specific guidelines, investment objectives and any reasonable investment restrictions that the client has provided to JPMS and the Portfolio Manager and the Portfolio Manager has accepted. 33823_J 11-05-2025 Page 4 of 49  (as defined below). The management of the investment products takes place in a single, unified JPMS account. Envestnet Asset Management, Inc. (Envestnet), an unaffiliated Portfolio Manager, acts as discretionary overlay manager for investment products in this Program (the UMA Overlay Manager). As UMA Overlay Manager, Envestnet provides the implementation and coordination services (as following portfolio applicable) with respect to clients’ accounts invested in the Program: (i) implementing, consistent with their discretionary investment and trading authority, investment instructions furnished to Envestnet by Model Portfolio Providers with respect to the specific securities to be purchased, held or sold for clients’ accounts and the account assets to be allocated to each such security; (ii) continuously monitoring the account holdings and coordinating the trading activity; (iii) rebalancing accounts; and (iv) implementing reasonable restrictions imposed by clients. In the event a strategy is removed from CBP, JPMS will provide written notice to clients. For certain strategies, JPMS may designate another strategy in CBP as the default replacement for the CBP assets invested in the removed strategy. If JPMS designates such a default replacement, each affected client will be notified in writing that, unless the client affirmatively selects a replacement strategy by the date specified by JPMS, the client’s assets in the removed strategy will automatically be re-invested into the designated default replacement strategy, without further notice to or consent of the client. In designating a default replacement (if any), JPMS will consider the appropriateness of the strategies available in CBP as suitable replacements for the removed strategy. The sale of the client’s assets in the removed strategy may have tax consequences for the client. To the extent a strategy is removed from CBP and another strategy is not designated as a default replacement, the securities would be held in-kind in an unmanaged brokerage account. Any restrictions or customizations will be maintained once the assets are reinvested in the default replacement subject to acceptance by JPMIM. Unless JPMS specifically agrees otherwise, clients are responsible for monitoring the Portfolio Manager’s adherence to or consistency with any investment restrictions and/or guidelines that have been submitted by the client for the account and accepted by the Portfolio Manager. JPMS has no responsibility for monitoring CBP accounts, even if JPMS assisted the client in determining an asset allocation and/or identified the Portfolio Manager as a portfolio manager to the client. Unless specifically agreed to by JPMS, JPMS is not obligated to provide ongoing advice with respect to the client’s selection of the Portfolio Manager or the strategy. JPMS is not responsible for the management of any CBP account, including the consistency of the management of any account with the client’s investment objective for the account or any other information provided by the client. UMA account assets can be allocated to available Model Portfolios. Model Portfolios are managed by affiliated or unaffiliated Model Portfolio Providers that select the securities to be included in the Model Portfolio. The Model Portfolios are then implemented by the UMA Overlay Manager, consistent with its discretionary and trading authority, and subject to any reasonable restrictions imposed by the client and accepted by the UMA Overlay Manager. Typically, the UMA Overlay Manager will invest UMA assets the client has allocated to each Model Portfolio in a manner consistent with that Model Portfolio. As the Model Portfolio Provider makes changes to the Model Portfolio and communicates changes to the UMA Overlay Manager, the UMA Overlay Manager will manage the account to reflect those changes. However, the UMA Overlay Manager can deviate, at any time and in its sole discretion, from the Model Portfolio. Thus, the performance between Model Portfolio and the strategies as implemented in UMA accounts will vary. Availability of Customized Services for Clients in CBP Investment Strategies. CBP strategies can be customized to individual client investment needs to various degrees depending on the investment strategy selected. UMA account assets can also be allocated to available investment strategies (Joint Discretion Strategies) that are subject to discretionary management, jointly, by the UMA Overlay Manager and affiliated and unaffiliated investment advisers (Joint Discretion Managers). Joint Discretion Managers select the securities to be included in the Joint Discretion Strategy and direct the execution through third-party broker- dealers, in accordance with the Joint Discretion Managers’ best execution obligations. In municipal bond portfolio strategies and taxable bond portfolio strategies, clients have the ability to select certain customizations (e.g., state preference, minimum credit quality options). The credit quality parameters that each client selects for a particular account only apply at the time the Portfolio Manager initially purchases a particular bond for that account. The Portfolio Manager may or may not liquidate bonds upon a credit rating downgrade. As a result, an account can hold bonds with a credit rating below the client-selected parameter. The UMA Overlay Manager has an investment advisory relationship with the client and is not an agent or sub-adviser of JPMS in UMA. Similarly, each Joint Discretion Manager has an investment advisory relationship with the client and is not an agent or sub-adviser of JPMS in UMA. However, the client will not be an advisory client of any Model Portfolio Providers or with the issuers of securities or such issuers’ advisers. In preferred portfolio strategies, clients have the ability to select from an option for tax treatment. Discretionary Authority Types. There are two types of discretionary authority for a client to select for the account in the Program. Collectively, all of the customizations are considered to be a “Customized Portfolio.” During the course of the portfolio management of a client account, for certain strategies, a client can change their Customized Portfolio for a municipal bond portfolio or taxable bond portfolio account. Clients can decide whether (1) to immediately restructure the entire account based on the new Customized Portfolio or (2) to adjust the account as existing bond positions mature in accordance with the new Customized Portfolio. If the client does not elect for (1) or (2) as previously described, the Portfolio Manager will apply option (2) as a default. The client portfolio may hold positions that are not in line with the new Customized Portfolio if option (2) is applied. For preferred strategies, clients can only restructure an entire preferred portfolio account. Immediately restructuring the entire account to the new Customized Portfolio can result in taxable events upon the sale of positions. Clients should consult with their own tax professional to understand any such consequences. Unified Managed Account Program (UMA) • Client Discretion: Clients have the authority and responsibility to select the investment products for the Program account. Upon request from the client, JPMS will identify and recommend to the client suitable investment products to create the Target Portfolio (as defined below) and assist the client, on a non-discretionary basis, in allocating assets among them based on the information the client provides to JPMS, including the risk profile for the UMA account. However, the client is responsible for the ultimate selection of the investment products for their account(s). Clients are solely responsible (even if JPMS assisted the client) for monitoring the UMA Overlay Manager’s adherence to or consistency with the client’s risk profile, target allocation and Target Portfolio and any investment restrictions and/or guidelines that have been submitted by the client and accepted by the UMA Overlay Manager. In addition, clients are solely responsible (even if JPMS assisted the client) for providing any tax gain or loss requests and mandates. Each client is further responsible for monitoring the actual allocation of the account on an ongoing basis and determining whether to instruct the UMA Overlay Manager to rebalance and/or reallocate UMA assets. It may take In UMA, client accounts may invest in some or all of the following investment products in an account, which may or may not be affiliated with JPMS: (i) Funds, (ii) Model Portfolios, and/or (iii) Joint Discretion Strategies 33823_J 11-05-2025 Page 5 of 49  several days to implement a request from a client to change an investment product. Unless specifically agreed to by JPMS, JPMS is not obligated to provide ongoing advice with respect to the client’s selection of any for investment product, and clients are solely responsible determining whether a change in the client’s circumstances may warrant a change to the client’s target allocation or selection of investment products. • Wealth Advisor Discretion: Clients can authorize an approved Wealth Advisor to (i) select and change investment products for clients without their prior authorization, and (ii) define and adjust the target asset allocation and Target Portfolio. Within the Program, JPMS will exercise discretion primarily through the Wealth Advisor(s). Clients are solely responsible for providing tax gain or loss requests and mandates and monitoring the UMA Overlay Manager’s adherence to any investment restrictions and/or guidelines that have been submitted by the client and accepted by the UMA Overlay Manager. For Client Discretion, in the event an investment product is removed from the Program, JPMS may designate another investment product as the default replacement for UMA assets invested in the removed investment product. If JPMS designates such a default replacement, each affected client account will be notified in writing that, unless the client affirmatively selects a replacement by the date specified by JPMS, the client’s assets in the removed investment product will automatically be re-invested into the designated default replacement, without further notice to or consent of the client. In designating a default replacement, JPMS will consider the appropriateness of the investment products available in UMA as suitable replacements for the removed investment product. If an investment product is removed from UMA and JPMS does not designate a default replacement, the client’s UMA assets that were invested in the removed investment product will automatically be re-invested into a Fund available in UMA, selected by JPMS, that is in an asset class or employs an investment strategy similar (as determined by JPMS) to that of the removed investment product, unless the client affirmatively selects a replacement of the client’s own choosing by the date specified by JPMS. Regardless of whether JPMS designates a default replacement, the sale of the client’s assets in the removed investment product may have tax consequences for the client. Any restrictions or customizations will be maintained once the assets are reinvested in the default replacement, subject to acceptance by the UMA Overlay Manager. While the client (or JPMS for Wealth Advisor Discretion accounts) is solely responsible for the selection of investment products and determining the percentage allocation to each, the UMA Overlay Manager (jointly with any Joint Discretion Manager the client may select) maintains discretion over day-to-day portfolio decisions, trading and account administration, and is responsible for coordinating investment product transactions. JPMS is not responsible for the management of UMA accounts, including the conformity of the management of each account to any information provided by the client. Currently, the UMA Overlay Manager is reviewed as part of JPMS’ vendor management process. JPMS could determine, as a result of its vendor management reviews and/or other information or events, that Envestnet should be replaced as the UMA Overlay Manager or that the UMA account should be modified or terminated. JPMS will notify clients in UMA in the event JPMS’ agreement with Envestnet is terminated. Services Provided. Clients will provide information relating to the client’s investment objective(s), goals, time horizon and risk tolerance, which will identify the risk profile for the account. The risk profile will guide a target asset allocation for the account. Based on such information, JPMS and the client (or JPMS for Wealth Advisor Discretion accounts) develop the recommended target allocation. The client (or JPMS for Wealth Advisor Discretion accounts) may deviate from the recommended asset class weightings for the selected risk profile but can only deviate to the next, more conservative risk profile (e.g., the target allocation selected for an account with a moderate risk profile can select the target allocation for the moderately conservative risk profile). An account can invest in multiple investment products or can invest in only one Model Portfolio Provider or Joint Discretion Manager. The client (or JPMS for Wealth Advisor Discretion accounts) then selects the investment product(s) that correspond to the target allocation to create the “Target Portfolio.” The investment styles for the selected investment products generally correspond to the target allocation. JPMS will notify the UMA Overlay Manager of the Target Portfolio selected by the client (or JPMS for Wealth Advisor Discretion accounts) and will give the UMA Overlay Manager information about the client, including any investment restrictions the client wishes to place on the investments in the UMA account. Tax Management Services. If elected by the client, the UMA Overlay Manager will implement tax management services (Tax Management Services) for securities held in accordance with Model Portfolios and/or Joint Discretion Strategies in the account. In providing Tax Management Services, the UMA Overlay Manager will, subject to client-imposed restrictions and investment guidelines accepted by the UMA Overlay Manager, consider the tax consequences of transactions in the account and evaluate the implementation of the Model Portfolios and/or Joint Discretion Strategies in the context of such consequences. Investment restrictions and guidelines accepted by the UMA Overlay Manager will take precedence over Tax Management Services and may impact the ability of the UMA Overlay Manager to improve after-tax returns. The UMA Overlay Manager can, in light of other considerations in an account, effect transactions even though they may generate tax liabilities, including short- term taxable income, or exceed or violate any of the limits or mandates identified by the client. The UMA Overlay Manager makes no guarantee that tax liability in the account will be reduced or that any indicated limits or mandates will be met. The UMA Overlay Manager does not provide Tax Management Services with respect to certain investment products, although any additional fee charged for Tax Management Services will be based on and applied to the market value of all assets in the account, including Joint Discretion Strategies and Funds. Accordingly, Tax Management Services are more appropriate and likely to prove more effective for an account that is more heavily concentrated in Model Portfolios than in Joint Discretion Strategies and Funds. Tax Management Services are available for U.S. taxable clients but not for tax-exempt clients. The actual allocation of the account may change over time due to fluctuations in the market value of UMA assets and/or additions to or withdrawals from the account. In addition, a change in the client information provided to JPMS or other circumstances may warrant a change to a client’s target allocation or Target Portfolio. If the client discontinues Tax Management Services, the UMA Overlay Manager will begin managing the account as if it never were tax managed, which may result in the recognition of significant short-term taxable gains. The UMA Overlay Manager will not be responsible for any such gains that may be realized in managing the client’s account after the termination of Tax Management Services. The UMA Overlay Manager will generally accept specific tax gain and loss requests for taxable accounts that are not enrolled in Tax Management Services, but the extent to which the UMA Overlay Manager implements such a request may be affected by its qualitative assessment of market liquidity. Typically, after December 15 of Review of Investment Products. JPMS determines which UMA Overlay Manager and investment products are available through UMA and reviews (or arranges for the review of) the UMA Overlay Manager and the relevant investment products on a periodic basis to determine whether they will continue to meet the investment needs of UMA clients. Accordingly, from time to time, JPMS may change the UMA Overlay Manager and/or add and remove specific investment products to and from UMA. 33823_J 11-05-2025 Page 6 of 49  each calendar year, the UMA Overlay Manager may experience reduced liquidity in the market and determine that executing a client’s tax gain or loss request in such an environment would not be in the client’s best interest. For this reason, the client should typically make tax-related trading requests before December 15 of each calendar year. In general, specific tax gain and loss requests are not appropriate for accounts enrolled in Tax Management Services but may be implemented on an exception basis in the sole discretion of the UMA Overlay Manager. as accounts without Tax Management Services if, in the UMA Overlay Manager’s opinion, doing so would generate excessive tax liabilities. For clients whose accounts are not tax-exempt, rebalancing may result in possibly substantial taxable gains or losses. JPMS will not be liable for any tax consequences of rebalancing or other transactions in Program accounts. The UMA Overlay Manager can disregard certain smaller positions in securities when making rebalancing decisions. In addition, the rebalancing of the account is typically subject to any security’s availability and any minimum purchase requirement set forth in the security’s prospectus. Investment Counseling Service Program (ICS) Values Overlay Services. The client may elect to place exclusionary screens (e.g., socially conscious restrictions, such as weapons or tobacco) on the management of their account (Values Overlay Services), subject to the acceptance of the UMA Overlay Manager and/or each Joint Discretion Manager selected by the client, as applicable. No restriction will be applied to the underlying holdings of a Fund that is held or purchased in the client’s account. If a client elects to enroll in Values Overlay Services, the UMA Overlay Manager will receive an additional fee for the services, which will be applied to all assets in the account, including securities. If a client has already elected for the UMA Overlay Manager to implement Tax Management Services, an additional fee for Values Overlay Services will typically not be charged. ICS provides clients access to discretionary investment management services of client accounts in accordance with certain strategies managed by affiliated or unaffiliated Portfolio Managers. Based on the Risk Score and other information clients provide to JPMS, the clients consult with one or more Wealth Advisors to determine how to invest ICS assets. At the client’s request, and based on the information the client provided, a Wealth Advisor will identify and present the client with one or more Portfolio Managers and strategies that are in the universe of Portfolio Managers and strategies that JPMS periodically reviews (the ICS Universe). JPMS identifies Portfolio Managers and strategies that appear to be suitable for the client based on the information the client provides to JPMS, including the client’s Risk Score for the ICS assets (unless the client invests assets with a Portfolio Manager or strategy outside the ICS Universe). Although JPMS will identify and recommend suitable Portfolio Managers and strategies to clients requesting it, clients are responsible for selecting the Portfolio Managers and strategies for their accounts. Rebalancing. The UMA Overlay Manager may periodically rebalance accounts, triggered by deviations from the target asset allocation. For Client Discretion, clients can elect the frequency (i.e., annual, semi-annual or quarterly) with which systematic rebalancing occurs. Only in certain circumstances, in JPMS’ discretion, will Client Discretion accounts be allowed to request that their accounts do not undergo systematic rebalancing. For Wealth Advisor Discretion, Wealth Advisors will have the option to rebalance the account on a quarterly, semi-annual or annual basis or to elect that the accounts do not undergo systematic rebalancing. The client (for Client Discretion accounts) or Wealth Advisor (for Wealth Advisor Discretion accounts) also may request an ad hoc rebalancing review to be implemented as soon as practicable upon receipt of such request by the UMA Overlay Manager. In addition to entering into the Client Agreement with JPMS, clients will enter into a separate investment management agreement (the IM Agreement) with each Portfolio Manager they select. As part of the IM Agreement, clients will grant each selected Portfolio Manager complete and sole discretionary trading authorization over the applicable ICS account(s). Given the dual contract nature of ICS, JPMS relies on the accuracy and completeness of the information the client provides (or that is provided on the client’s behalf) in connection the applicable ICS accounts without further investigation, including the strategy selected for such accounts. Unless the Portfolio Manager has agreed with the client to notify JPMS of any change of the selected strategy, JPMS will have no knowledge of such change until it receives notice of the change from the client or the Portfolio Manager; such notice will only be effective if it is in writing or confirmed by JPMS in writing. The UMA Overlay Manager will evaluate the account at the interval selected by the client to determine if the account should be considered for rebalancing. Accounts for which quarterly rebalancing is selected will be evaluated after being managed for one full calendar quarter after the account has been accepted into the Program; accounts for which semi- annual rebalancing is selected will be evaluated after being managed for two full calendar quarters after the account has been accepted into the Program; and accounts for which annual rebalancing is selected will be evaluated after being managed for four full calendar quarters after the account has been accepted into the Program. Rebalancing takes into consideration the weight of each investment product in the account as of the end of the applicable period and represents a weighting of the account’s Target Portfolio. If a client requests tax harvesting, the Portfolio Manager may sell certain investments at a gain or loss to offset the client’s tax liability. If utilizing tax harvesting, the client’s account holdings can differ from those accounts that do not utilize such election and therefore performance will likely differ. JPMS or the Portfolio Manager may reject a client’s request for tax harvesting in whole or in part, at its discretion. Each client is responsible for monitoring the client’s ICS account(s). This monitoring includes reviewing any asset allocation between or among strategies on an ongoing basis and determining whether to rebalance and/or reallocate the ICS assets, as applicable. The actual allocation of the ICS assets may change over time due to fluctuations in market value of the ICS assets and/or additions or withdrawals by the client. In addition, clients are responsible for determining whether a change in the client’s circumstances may warrant a change to the client’s strategy selection. Upon evaluating the account for rebalancing, the UMA Overlay Manager can decide not to rebalance the UMA account, in whole or in part, if in its discretion it would be in the account’s best interest not to do so. In addition, if a rebalancing would entail the purchase of additional shares of a security that has been scheduled for removal from UMA, the account may not be rebalanced. If the UMA Overlay Manager determines that the account should be rebalanced, it will initiate transactions with a goal of restoring the account as closely as practicable to the Target Portfolio. Large cash contributions and/or withdrawals may cause the UMA Overlay Manager to seek to invest such contributions or to raise proceeds to fund withdrawals, as the case may be, in a manner so as to bring the account in closer alignment with the Target Portfolio. Clients are responsible for monitoring a Portfolio Manager’s adherence to or consistency with any investment restrictions or guidelines that have been submitted by the client for the account and accepted by the Portfolio Manager. JPMS has no responsibility for monitoring ICS accounts, even if JPMS assisted the client in selecting a Portfolio Manager and strategy in ICS, or in determining an asset allocation or in developing investment restrictions and/or guidelines. Unless specifically agreed to by JPMS, JPMS is not obligated to provide ongoing advice with respect to the client’s selection of any Portfolio Manager or strategy. JPMS is not responsible for For clients who elect to receive Tax Management Services, the UMA Overlay Manager will evaluate the trade-off between rebalancing the account and the tax consequences in light of any constraints or tax mandates identified by the client; such considerations may cause the UMA Overlay Manager not to rebalance the account. Further, accounts enrolled in Tax Management Services may not be restored as closely to their respective Target Portfolios 33823_J 11-05-2025 Page 7 of 49  the management of any ICS account, including the consistency of the management of any account with the client’s investment objective for the account or any other information provided by the client. investment), and determines portfolio construction. JPMPI, as sub-adviser of JPMCAP, from time to time may close investment strategies to new investments. JPMS oversees the selections using an investment policy statement and remains responsible for overseeing JPMPI’s performance. JPMS determines which Portfolio Managers and strategies are available in the ICS Universe, and reviews (or arranges for the review of) such Portfolio Managers and strategies on a periodic basis to determine whether they will continue to meet the investment needs of ICS clients. Accordingly, JPMS may add or remove specific Portfolio Managers and/or strategies to or from the ICS Universe at any time. Refer to Item 6.ii for more information. Funds sponsored or managed by affiliates of JPMS (J.P. Morgan Funds or J.P. Morgan-affiliated Funds) and Funds managed by third-party asset managers (non–J.P. Morgan Funds or unaffiliated Funds) are available in JPMCAP. Currently, a substantial portion of the assets in JPMCAP are invested or expected to be invested in J.P. Morgan Funds. Refer to “Use of J.P. Morgan Funds and Model Portfolio Providers and Potential Conflicts of Interest” below for more information on the use of J.P. Morgan Funds. In managing JPMCAP, JPMPI will not consider any assets owned by the client outside of the relevant JPMCAP account, including any assets held in other JPMCAP accounts. JPMS generally does not recommend the replacement of a particular Portfolio Manager or strategy for a particular client unless JPMS removes the Portfolio Manager or strategy from the Program, in which event JPMS may assist the client in identifying a suitable replacement manager and/or strategy based on the same types of factors used by JPMS to identify Portfolio Managers and strategies for ICS clients in the first instance. The investment strategy for a particular client is based on the client’s discussion with JPMS and the client’s risk tolerance. The investment strategies available in JPMCAP are conservative, balanced, growth, aggressive growth, managed fixed income and managed equities. In addition, U.S.-focused investment strategies for conservative, balanced and growth are offered in JPMCAP. The Balanced ESG investment strategy primarily consists of Funds or other investments that consider environmental, social and governance (ESG) factors and/or focus on sustainable themes. The conservative, balanced and growth investment strategies are generally available for clients regardless of whether they are eligible to include or have elected to include Liquid Alternative Funds in their accounts, as applicable. The aggressive growth investment strategies are only available to those clients who are eligible for and have elected to include Liquid Alternative Funds in their account. Liquid Alternative Funds are not available in managed equities or managed fixed income strategies. In certain circumstances, a client may be permitted to maintain ICS assets with a Portfolio Manager or in a strategy that no longer is, or never was, in ICS (ICS Non-Researched). While the client in such cases will typically receive the other services customarily provided by JPMS and its affiliates in the Program to clients, JPMS will not perform periodic reviews of any such Portfolio Manager or strategy. In addition, JPMS (and its affiliates) may have access to or may collect information about ICS Non-Researched Portfolio Managers and strategies, but they have no obligation to share any such information with any client, even if such information is negative or reflects poorly on the relevant Portfolio Manager or strategy. Any strategy that is not specifically included in the ICS Universe is excluded. If clients select an ICS Non-Researched Portfolio Manager and strategy, they will not receive the full range of services available in ICS for Portfolio Managers and strategies that are part of the ICS Universe. Clients will pay the full Fee to JPMS for any account invested in an ICS Non-Researched Portfolio Manager’s strategy, even though they will not receive all of the services, including initial and ongoing reviews of such Portfolio Managers and strategies that other clients utilizing Portfolio Managers and strategies in the ICS Universe may receive. The decision to utilize an ICS Non-Researched Portfolio Manager or strategy and the review and selection of the Portfolio Manager(s) is the client’s decision and responsibility. JPMS will not assist with the recommending or soliciting of Portfolio Managers selected in the ICS Non-Researched program. JPMS may also determine that it will no longer permit clients to maintain ICS assets with an ICS Non-Researched Portfolio Manager or strategy. In such cases, clients may select a Portfolio Manager or strategy that is part of the ICS Universe, or the ICS account may be terminated by the client or by JPMS. J.P. Morgan Core Advisory Portfolio Program (JPMCAP) The U.S. Endowments & Foundations (E&F) investment strategy is designed to primarily service the investment goals of nonprofit entities (i.e., endowments and foundations). This investment strategy is made available to clients of Wealth Advisors and is appropriate for a growth investment strategy. The endowment investing approach is generally characterized by a longer-term investment horizon. A long-term investment mindset can allow a client to look through the short-term volatility and focus on the potential of enhancing long-term returns. For more information on these investment strategies and related risks, clients should review the advisory brochure for JPMPI, which can be obtained upon request from a Wealth Advisor or at the SEC’s website at adviserinfo.sec.gov. JPMS has delegated certain of its discretionary responsibilities and authority to JPMPI as the Program’s sub-adviser. JPMPI is an affiliate of JPMS. JPMPI, as the sub- adviser, determines strategic and tactical asset allocations, is responsible for security selection (i.e. selects the Funds for investment), and determines portfolio construction. JPMS oversees the selections using an investment policy statement and remains responsible for overseeing JPMPI’s performance. JPMCAP is a unified managed account Program managed and offered by JPMS. In JPMCAP, clients establish a discretionary managed account that is invested in a manner consistent with one of the single-asset class (managed fixed income and managed equities) or multi-asset class (conservative, balanced, growth and aggressive growth) investment strategies JPMS makes available to clients. In addition, U.S.-focused investment strategies for conservative, balanced and growth are offered in JPMCAP. The investment policy statement specifies investment guidelines designed by JPMS to address operational considerations. These operational considerations, such as Fund concentration and capacity issues, can affect the timing of certain tactical trades and can result in the timing or implementation of trades for a client’s account differing from that of another client or group of clients of JPMS or its affiliates. Assets within an investment strategy are generally invested in each asset class through one or more Funds. Depending on the investment strategy selected, clients have the option to make certain elections including municipal fixed income (for taxable accounts), Liquid Alternative Funds or non-J.P. Morgan Funds, as described further below. JPMS and JPMPI have full discretionary authority to be exercised in their exclusive judgment and consistent with the investment strategy selected by the client, to determine the allocation of assets (inclusive of selecting, adding, removing, or replacing) among Funds. In addition, as applicable, JPMPI provides trade instructions to JPMS for each investment strategy. JPMS has delegated this discretionary authority to JPMPI as the Program’s sub-adviser. Clients with at least $250,000 in JPMCAP can elect to include funds that hold more non-traditional investments and employ more complex strategies than traditional mutual funds (Liquid Alternative Funds); refer to “Liquid Alternative Funds” in Item 6.vi below for more information. JPMS has retained JPMPI as the Program’s overlay manager for Program accounts. JPMPI, as the overlay manager for JPMCAP, provides portfolio implementation and coordination services to JPMCAP accounts. Services JPMPI, as sub-adviser of JPMCAP, determines strategic and tactical asset allocations, is responsible for security selection (i.e., selects the Funds for 33823_J 11-05-2025 Page 8 of 49  include: (1) managing the accounts on a discretionary basis by implementing instructions to purchase, hold or sell securities or shares of Funds; (2) continuously monitoring the account holdings and coordinating the trading activity; (3) implementing specific reasonable restrictions requested by the client that are placed on the accounts; and (4) generally rebalancing the Program account to the allocation in a chosen investment strategy when the asset allocation percentages deviate from established parameters. implemented using Index-Oriented Vehicles was not available for accounts invested in aggressive growth, managed fixed Income or managed equities investment strategies. This election directs JPMPI to use Passively Managed Vehicles except when, in JPMPI’s judgment, active management is expected to closely reflect an underlying index and either (i) to better reflect the overall characteristics of the underlying asset class or market segment, or (ii) is necessary to implement the client’s instructions. Actively Managed Vehicles typically charge higher management fees than Passively Managed Vehicles. JPMPI does not have any responsibility or liability for JPMS’ determinations that the investment strategy selected by the client is suitable in light of the client’s investment objectives and financial situation. Clients who elected to have their accounts implemented using Index- Oriented Vehicles had to also elect having their accounts implemented using non-J.P. Morgan Funds, as defined and further described below. In providing services to JPMS, JPMPI can rely on affiliated and unaffiliated third parties to fulfill its services as overlay manager. Currently, clients that selected the Index-Oriented Vehicle election will not be invested in any J.P. Morgan Funds (except for J.P. Morgan sweep vehicles; refer to “Cash Allocations or Balances and the Sweep Feature” below for more detail) or affiliated Model Portfolio Providers. Rebalancing. Program accounts will be rebalanced only if the percentage variance at the asset class level exceeds a threshold amount that has been established as effective for rebalancing to the investment strategy. If the client made an election for Index-Oriented Vehicles for an existing JPMCAP account, sales of Funds could be subject to redemption fees. There can be a period of time during which non–Index-Oriented Vehicles remain in a client’s account. To rebalance the account, shares of Funds in the client’s account that are underweight or overweight compared to their asset class percentage in the Model Portfolios are bought or sold, as applicable, until the account holdings are consistent with the client’s selected Model Portfolio. Over time, the Funds will appreciate (or depreciate) in value at different rates. For JPMCAP, when a client elected to implement Index-Oriented Vehicles, it could affect the ability to make investments, access asset classes, or take advantage of opportunities that are available to clients who do not make that election. As a result, performance of an account with an election can differ from the performance of other accounts without an election. Liquid Alternative Funds. Liquid Alternative Funds are available to accounts depending on the investment strategy and assets available in the account (generally accounts with an investment balance of at least $250,000). For additional information related to risks associated with Liquid Alternative Funds, refer to Item 6.vi. Rebalancing has tax implications for most clients unless the account is an individual retirement account (IRA) or qualified retirement plan. JPMPI will continuously review client asset allocations relative to the selected investment strategy and will generally rebalance the Program account to the allocation in the chosen investment strategy when the asset allocation percentages deviate from established parameters. To rebalance the account, shares of Funds that are underweight or overweight compared to their asset class percentages in the investment strategy will be bought or sold, as applicable, until the account holdings are consistent with the investment strategy. Over time, the Funds will appreciate (or depreciate) in value at different rates. Without rebalancing, the change in the percentages of each asset class held will change the level of risk from the risk level that is associated with the original model and/or allocations in the selected investment strategy. Municipal Fixed income (for taxable accounts). For taxable (non- retirement) accounts, clients can elect to substitute tax-aware investments for certain equities or municipal investment for some fixed income options. Non–J.P. Morgan Funds and Unaffiliated Model Portfolio Providers. As described below in “Use of J.P. Morgan Funds and Model Portfolio Providers and Potential Conflicts of Interest,” JPMPI prefers J.P. Morgan Funds and affiliated Model Portfolio Providers. Clients can elect to exclude from their JPMCAP accounts J.P. Morgan managed strategies (except for J.P. Morgan sweep vehicles; refer to “Cash Allocations or Balances and the Sweep Feature” below for more detail), including J.P. Morgan managed strategies where a party other than J.P. Morgan is appointed investment adviser (Non-Proprietary Strategy Election). The Non-Proprietary Strategy Election excludes from JPMCAP accounts J.P. Morgan Funds (except J.P. Morgan sweep vehicles). Index-Oriented Vehicles. JPMS and the sub-adviser prefer to follow an investment process that maintains the option of using a range of active and passive vehicles, some of which are Index-Oriented Vehicles (as defined below) and some of which are not. JPMCAP in the past offered certain clients, as described below, the option to implement certain account investment strategies using an Index-Oriented Vehicle election. Currently, the Non-Proprietary Strategy Election is available for all JPMCAP strategies, including where clients are eligible for and have elected to include Liquid Alternative Funds in their accounts. It is possible that the availability of this election will change in the future. When a client elects to exclude J.P. Morgan managed strategies, it can affect the ability to make investments, access asset classes, or take advantage of opportunities that are available to clients who do not make the Non-Proprietary Strategy Election. As a result, performance of an account with an election can differ from the performance of other accounts without an election. To the extent a client holds J.P. Morgan managed investments in an existing JPMCAP account at the time of making the Non-Proprietary Strategy Election, the sales of Funds can be subject to redemption fees. The following disclosures are for all Programs, as applicable: Tax Consequences JPMCAP Index-Oriented Vehicles (Passively Managed Vehicles) include ETFs and index mutual funds, and “Actively Managed Vehicles” include funds. Actively managed vehicles typically charge higher mutual management fees than passively managed vehicles. In determining whether a particular Actively Managed Vehicle or Passively Managed Vehicle can be considered an “Index-Oriented Vehicle,” JPMPI will, using due diligence and vehicle evaluation from its affiliates, consider, among other things, how closely the vehicle’s historical returns track the index JPMPI is targeting for the relevant asset class as well as the cost, liquidity and complexity of the vehicle’s strategy. The determination of whether a vehicle is an Index-Oriented Vehicle is in JPMPI’s sole discretion, is subject to change and does not guarantee that an Index-Oriented Vehicle will perform in line with, or in excess of, the underlying index. The election does not apply to cash and liquidity funds. When client elections result in the sale of securities, when accounts are funded with securities, or when funds are removed or replaced in a client portfolio, clients may incur redemption charges and taxable gains or losses. Clients who selected the conservative, balanced, or growth investment strategies and who did not elect to include Liquid Alternative Funds could have elected to use Index-Oriented Vehicles in their accounts for asset classes other than cash and liquidity Funds. The election to have an account 33823_J 11-05-2025 Page 9 of 49  Clients should consult their own tax professionals when making these decisions. JPMS and its affiliates do not provide tax advice. clients that are invested in the same model portfolio or investment strategy. Funding J.P. Morgan will not verify the accuracy of any external account information, including account statements provided by clients from third parties. The validity of recommendations provided by J.P. Morgan and any analyses contained in any report provided by J.P. Morgan is dependent upon the accuracy and thoroughness of the data and information provided by the client. The use of incomplete or inaccurate data and information will result in different outcomes. The tax implications set forth in any report or any guidance provided by J.P. Morgan pursuant to a client’s tax transition plan are not guaranteed and should not be viewed as tax advice. Actual tax incurred by clients will vary from any illustrated projections provided by J.P. Morgan pursuant to client’s tax transition plan. Clients should contact their tax professional to review their tax transition plan. A client’s plan can be modified at any point in time during discussion with their J.P. Morgan team. Share Class Conversion of Mutual Funds and Contribution of Ineligible Funds, ETFs or Share Class For PA and PM: Clients can fund their accounts by depositing cash and/or securities acceptable to JPMS. JPMS may determine in its sole discretion that certain securities are ineligible for the Programs. If JPMS determines, in its sole discretion, that contributed investments are not eligible or unacceptable (by execution of the Client Agreement), clients authorize JPMS to sell those investments and charge them a commission for the sale of these assets. If JPMS or the Portfolio Manager is not able to sell the assets or determines not to sell the ineligible asset, JPMS has the right to transfer the asset to a securities brokerage account. JPMS will be acting as a broker, and not acting as a fiduciary or investment adviser, and we may charge a commission or execute a principal transaction for the sale of these ineligible investments. Investment management will begin after JPMS has accepted the account into the Program. The investment of assets of an account will only occur when all operational requirements have been met. Account acceptance may be delayed or rejected if the account is overfunded, underfunded, or funded with ineligible securities. Cash to fund an account will be placed in the sweep option selected by the client. Clients funding Program accounts with securities direct JPMS or the Portfolio Manager, as applicable, to liquidate the securities on behalf of the client and allocate the proceeds in accordance with the applicable investment strategy. The Portfolio Manager, on a best-efforts basis, will sell a portion or all of any securities that are not consistent with the applicable investment strategy. Neither JPMS nor any Portfolio Manager will advise a client regarding the liquidation of these securities. Liquidation will be done free of commission charges or spread on fixed income trades unless the trade is placed away from JPMS. • Approved Mutual Funds. If a client contributes or holds a mutual fund that is approved for the platform but is not in the approved advisory share class, then JPMS can exchange the client’s shares into the eligible advisory share class of the same mutual fund, under the authority provided to JPMS under the Client Agreement, mutual fund prospectus rules and its own policies, as soon as practicable. The eligible share class will generally be subject to lower net expenses, though in certain circumstances, can be subject to higher net expenses. JPMS may not elect to exchange particular share classes of a mutual fund if, for example, there is no equivalent advisory share class eligible for the Programs or if other circumstances exist. Depending on the type of security involved, liquidation may result in redemption charges and taxable gains or losses. Before contributing mutual fund shares, clients should consider if they paid a front-end sales charge, as they can incur a contingent deferred sales charge or a redemption fee in the event the mutual fund shares are liquidated in accordance with the Investment Strategy selected. These mutual fund fees and charges are the responsibility of the client and are in addition to the wrap fee. Clients should review the potential tax consequences of these liquidations with their tax professional before funding their Program account with securities. JPMS does not provide tax advice. If non-U.S. denominated securities are sold, the client will incur currency conversion charges. • Non-Approved Mutual Funds. When a client contributes to or holds a mutual fund that is not approved for the platform, and a client or Wealth Advisor decides to hold the non-approved mutual fund, JPMS will not monitor or review the appropriateness of the existing share class. In certain circumstances, JPMS can, but is not required to, exchange the client's shares into an approved advisory share class of the same mutual fund. The non-approved mutual fund will be subject to the Fee (as defined below). Clients should discuss with their Wealth Advisor the impact of contributing or holding any non- approved mutual fund shares in their account. Refer to Item 6 (Portfolio Manager Selection and Evaluation) for more information on mutual fund selection. When liquidating these securities and other securities that are affiliated with J.P. Morgan for purposes of establishing a client’s account, JPMS will be acting as a broker, not an investment adviser. Liquidations will be effected promptly after funding client accounts at the then prevailing market prices, separately from the acceptance of the account by the Portfolio Manager. If a particular security cannot be liquidated or is not eligible for the Program, it will not be used to fund an account and will be transferred to another account owned by the client. For STRATIS, UMA and JPMCAP, if a client holds a mutual fund share class that was previously approved and that JPMS now deems to be ineligible for the Program, JPMS can exchange the shares into the newly approved advisory share class of the same mutual fund, under the authority provided to JPMS under the Client Agreement, mutual fund prospectus rules and its own policies, as soon as practicable. The newly approved advisory share class will generally be subject to lower net expenses, though in certain circumstances, can be subject to higher net expenses as compared to the previously approved share class. If a client contributes funds, ETFs or certain share classes, JPMS will generally require the client to remove a mutual fund or ETF from the account if the mutual fund, the share class, or the ETF is not approved for the Program or is not part of the client’s target allocation. If the mutual fund is approved for the platform but the client’s share class of the mutual fund is not the approved share class, then JPMS will not exchange the client’s share class into the approved share class. However, the Portfolio Manager may sell their share class and purchase the approved share class. There can be tax consequences related to the sale and purchase of mutual fund shares. For certain strategies, if clients transfer securities into their portfolio, they may request to have J.P. Morgan work to transition such securities into their portfolio in a more tax efficient manner. Clients will work with their Wealth Advisor to discuss which securities (or any particular security or securities) can be held in their portfolio and sold over an extended period of time, at the Portfolio Manager’s sole discretion. Clients understand that the sale of these securities may generate taxable income, and J.P. Morgan does not make any guarantees regarding tax implications with respect to a client’s portfolio. Clients should discuss their specific tax transition and portfolio with their tax professional. Requesting that any security be held for an extended period of time can result in deviation from the Model Portfolio guidelines and/or from the investment strategy that a client has selected. The longer the time period for transition, the longer the deviation from the Model Portfolio guidelines and/or from the investment strategy. As such, the client’s performance will differ from the performance of other Pursuant to the Client Agreement, clients authorize and instruct JPMS, upon the termination of the account or the removal of the client’s account 33823_J 11-05-2025 Page 10 of 49  from the Programs, to the extent that the mutual fund shares in the account are an institutional or other share class not eligible to be held by the client in a brokerage account or an account outside of the Programs, to convert such shares to a retail or other share class. Certain mutual funds may charge a redemption fee in the event of such conversions, and conversions may have tax consequences for clients. The amount of the Fee is specified in communications that JPMS sends to clients, which include playbacks and/or statements for the account. Except as otherwise agreed to in writing by JPMS, accounts are charged the Fee with respect to all assets in the account regardless of whether the client has previously paid or incurred commissions, sales charges or “loads,” mark-ups, mark-downs, dealer spreads, or other costs, charges, fees or expenses in connection with the client’s previous purchase of some or all of the assets in a brokerage account or otherwise outside of the Programs. Refer to Item 9.iii.3 (Additional Information — Other Compensation from Affiliated and Unaffiliated Mutual Funds and Other Pooled Investment Vehicles) for more information on share class selection and mutual fund compensation. The maximum annual rate for JPMS’ component of the Fee is 2.00% for all Programs except for: Fees and Compensation • CBP, which has a maximum annual rate for JPMS’ component of the ii. Fee of 0.70%, a. Wrap Fee • Certain strategies in STRATIS managed by affiliates of JPMS, which may have a lower maximum annual rate for JPMS’ component of the Fee of 2.00%. (For example, JPMPI Liquidity Management Strategy is offered in STRATIS as part of the Multi-Manager Strategies for which the maximum annual rate for JPMS’ component is 0.40%.) Important Information Regarding the Maximum for JPMS’ component of the Fee The Programs are known as “wrap fee” investment advisory programs because clients pay JPMS an asset-based fee for the various services JPMS and the Wealth Advisors provide in the Programs. This fee covers JPMS’ investment advisory services, trade execution, clearing and settlement, custody, reporting and other administrative services, and (where applicable) portfolio management and/or rebalancing services. Unless otherwise disclosed, a separate fee is charged for any Portfolio Manager investment management services and any Model Portfolio Provider’s provision of Model Portfolios. These separate fees (i.e., the asset-based fee to JPMS and the fee charged for any Portfolio Manager or Model Portfolio Provider services) are referred to collectively as the “Fee” and will appear either together as a single fee on account statements and other communications, except for STRATIS and ICS where it will appear as separate fees. Wrap fee programs that offer the same and similar programs and/or investment strategies are offered in the different sales channels and at different fee levels. Although JPMCAP and investment strategies in STRATIS are available through Wealth Advisors at the maximum annual rate for the JPMS’ component of the Fee of 2.00%, the same or similar program or strategy is available through another J.P. Morgan sales channel with a lower maximum annual rate. JPMS will provide the client with written confirmation reflecting the agreed upon Fee. However, for ICS, the Fee does not include the fee that the client agrees to pay any Portfolio Managers. Wealth Advisors receive less compensation for Programs or strategies with a lower maximum annual rate for JPMS’ component of the Fee than the other Programs or strategies described herein. Credit of Certain Fees to IRAs and Certain Other Retirement Plan Accounts The Fee does not cover any (i) brokerage commissions or other charges resulting from transactions not effected through JPMS or its affiliates; (ii) “mark-ups,” “markdowns” and “dealer spreads” that we or other broker- dealers may receive when acting as principal in certain transactions; (iii) custody services provided by any unaffiliated custodian; (iv) certain costs or charges imposed by third parties, including odd-lot differentials, margin interest, transfer taxes, exchange fees, and other fees or taxes required by law; (v) any retirement account fee; (vi) the cost of investment manager fees and other expenses charged by Funds; or (vii) any pass-through or other fees associated with investment in American Depositary Receipts (ADRs). Certain retirement accounts are able to hold affiliated Funds. If an account owned by an IRA, or other client that is a qualified retirement account subject to the prohibited transaction provisions of Section 4975 of the Internal Revenue Code of 1986, as amended (IRC), holds any J.P. Morgan Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with the client’s Program account assets will be credited to the account. The credit will appear as a separate line item on the client’s Program account statement. This credit does not apply to account investments in non–J.P. Morgan Funds. In addition, for those J.P. Morgan accounts that hold unaffiliated investment sub-advisers for all or a portion of portfolio management, the amount of the advisory fees paid to unaffiliated investment sub-advisers is not credited. Portfolio Manager and Model Portfolio Provider Fees Typically, Program accounts are charged the Fee quarterly, in advance, on the net market value of the assets in the account (including all cash and cash alternatives such as money market mutual funds) and, in most cases, is automatically deducted from the account. However, certain accounts may be charged the Fee in arrears and/or on other than a quarterly basis (e.g., monthly), and JPMS also may agree in certain instances to calculate the Fee on a basis other than a percentage of the net market value of the assets in the Program account (e.g., calculating the Fee on a cents-per- share-deposited-into-the-account basis). General information regarding fee rates of the Portfolio Managers, the UMA Overlay Manager, and each Model Portfolio Provider and Joint Discretion Manager are included below, though such rates may change over time. Clients can obtain the Fee schedules for the Portfolio Managers and certain Model Portfolio Providers by asking their Wealth Advisor(s), or by visiting jpmorgan.com/ManagerFees. (i) PM • JPMS typically pays a portion of the JPMS component of the Fee it receives from each client to the Wealth Advisor(s) for that client. (ii) STRATIS The quarterly Fee paid by the client may be adjusted upward or downward if the client deposits additional cash or securities into, or withdraws cash or securities from, the account. The Client Agreement typically provides that (i) a prorated Fee will be charged on total same-day contributions to the account (net of total same-day withdrawals from the account) of $25,000 or more to cover the period from the date of the net same- day contribution until the end of the quarterly billing period and (ii) a prorated Fee credit will be made for total same-day withdrawals from the account (net of total same-day contributions to the account) of $25,000 or more to cover the period from the date of the net same-day withdrawal until the end of the quarterly billing period. Upon termination of the account, JPMS will refund to the client any prepaid amount of the Fee prorated for the number of days remaining in the billing period. • The Portfolio Manager or Model Portfolio Provider component of the Fee varies by Portfolio Manager, Model Portfolio Provider, type of account and type of strategy. The Portfolio Manager component of the Fee is currently up to 1.00% annually of the net market value of 33823_J 11-05-2025 Page 11 of 49  the accounts managed by a Portfolio Manager, generally as set forth in a fee schedule that is part of an agreement between JPMS and each such Portfolio Manager. The Model Portfolio Provider component of the Fee is currently up to 0.38% annually of the net market value of the accounts managed by the Model Portfolio Provider. • For certain Portfolio Manager strategies, rather than the Fee being charged on the net market value of assets in the account, the Fee is charged on a fixed notional value (the Mandate Size) as specified by the client (and agreed to separately by and between a client and Portfolio Manager). • The fee schedule also may contain breakpoints at which the percentage of the value of the managed assets paid to the Portfolio Manager goes down as the total of all client assets the Portfolio Manager manages in STRATIS increases. • The Fee does not cover any fees charged by any Portfolio Manager(s) selected by the client to manage the account assets, and clients are responsible for paying Portfolio Managers for their services separately. (Clients typically authorize JPMS to debit their ICS accounts to pay their Portfolio Manager(s) upon JPMS’ receipt of instructions from such Portfolio Manager(s).) • The Portfolio Manager’s or Model Portfolio Provider’s component of the Fee is generally separate from and in addition to JPMS’ component of the Fee. (vi) JPMCAP • JPMS reimburses JPMPI for its costs for investment advisory services, rather than being paid a component of the Fee separate from and in addition to JPMS’ component of the Fee. • For the strategies managed by JPMPI, JPMS reimburses JPMPI for its costs for investment advisory services in support of the strategy, rather than being paid a component of the Fee separate from and in addition to JPMS’ component of the Fee. In its sole discretion, JPMPI may waive or reduce a portion of the Fee. • (iii) CBP • JPMIM’s component of the Fee is paid by JPMS and generally ranges from 0.11% to 0.25% annually of the net market value of the accounts managed by JPMIM, which is set forth in a fee schedule that is part of an agreement between JPMS and the Portfolio Manager. • In its sole discretion, the Portfolio Manager may waive or reduce its portion of the Fee. (iv) UMA • The UMA Overlay Manager’s component of the Fee (for Model Portfolios and Joint Discretion Strategies, the UMA Overlay Manager's fee is comprised of an investment management fee and an administration fee) is: Fees for certain Portfolio Managers or Model Portfolio Providers that are affiliated with JPMS are waived or rebated to client Program accounts that are IRAs or tax-qualified plans, including plans subject to Employee Retirement Income Security Act of 1974, as amended (ERISA). In this case, JPMS may share a portion of the Fee with the affiliated Portfolio Manager or Model Portfolio Provider. This revenue sharing arrangement will not affect the total fees due by the client. The lower pricing structure creates a conflict of interest and provides an opportunity for Wealth Advisors to charge a higher JPMS Fee for these strategies than they would for strategies that charge an additional Portfolio Manager fee. The opportunity to negotiate a higher JPMS Fee in circumstances where the affiliated Portfolio Manager fee is waived also creates an incentive to recommend affiliated Portfolio Managers, which benefits JPMS as further described below. i. maximum of 0.05% annually of the market value of the account's assets allocated in the Target Portfolio to securities; ii. maximum fee of 0.07% annually of the market value of the account's assets allocated in the Target Portfolio to Model Portfolios and Joint Discretion Strategies; and iii. if the client has elected to receive Tax Management Services and/or Values Overlay Services, maximum 0.10% annually of the account's assets. • Each Joint Discretion Manager’s and Model Portfolio Provider’s component of the Fee is generally between 0.20% and 0.425% annually (depending upon the Joint Discretion Manager or Model Portfolio Provider) of the market value of the account’s assets allocated in the Target Portfolio to each Model Portfolio and Joint Discretion Manager. • The Model Portfolio Provider and Portfolio Manager’s component(s) of the Fee is separate from and in addition to JPMS’ component of the Fee. • When two or more UMA accounts are related together for billing purposes, clients may be able to benefit by reducing the UMA Overlay Manager’s component of the Fee (including Tax Management and/or Values Overlay Services). Only certain accounts may be related for billing purposes, based on the law and JPMS’ policies and procedures. UMA accounts with the same primary tax identification number will be automatically related for billing purposes. Even where other accounts are eligible to be related under the policies and procedures, they will only be related if agreed to between the client and the client’s Wealth Advisor. (v) ICS • The applicable ICS Universe Portfolio Manager fee rate is agreed to separately by and between a client and Portfolio Manager. For UMA, the UMA Overlay Manager’s and each Model Portfolio Provider’s and Joint Discretion Manager’s components of the Fee are based on the application of potentially varying fee rates to the market value at the end of each quarter of the account’s allocation in the Target Portfolio to Model Portfolios, Joint Discretion Strategies and securities. As a result, the amount of the Fee could differ, perhaps significantly, from what it would be if it were instead based on application of the rates to the market value at the end of each quarter of the account’s actual allocation to Model Portfolios, Joint Discretion Strategies and securities. For example, the quarterly Fee for an account with a quarter-end market value of $100,000 and an allocation in the Target Portfolio of 25% to Model Portfolios, 25% to Joint Discretion Strategies and 50% to securities will be based on the application of the relevant rates to an allocation of $25,000 to Model Portfolios, $25,000 to Joint Discretion Strategies, and $50,000 to securities — even if (because of changes in the values of the securities in the account over time) the actual allocation of the account’s market value at quarter-end was 35% ($35,000) to Model Portfolios, 20% ($20,000) to Joint Discretion Strategies, and 45% ($45,000) to securities. The extent to which an account’s Target Portfolio allocation to the various types of investment vehicles available in the Program will differ from its actual allocation to such vehicles may depend upon the frequency of account rebalancing requested by the client; in general, clients who choose more frequent rebalancing may be expected to experience less divergence over time between an account’s Target Portfolio allocation and its actual allocation. Note that this divergence between the Target Portfolio allocation and the actual allocation that results from market movements between rebalancing could result in a client paying an advisory fee that is higher or lower than the amount that would be paid if the rate was applied to the actual market value of the account. The rate used each quarter for each component of the Fee will be approximately one-fourth of the annual rate based on the number of days in the quarter. Any change to the Target Portfolio of an existing account will not result in an adjustment of the Fee for the quarter in which the change is made; any new or different fee rate(s) for the UMA Overlay Manager’s, Model Portfolio Provider’s or Joint 33823_J 11-05-2025 Page 12 of 49  Discretion Manager’s component(s) of the Fee will take effect the following quarter. • The cost of the services if provided and charged for separately, • The Fee rate charged to the client in the Program, • The trading activity in the client’s account, and • The quality and value of the services provided. If a client requests that any securities be transferred out of an account or there is a trade error in an account, JPMS may temporarily suspend trading in the account until the transfer is complete or the trade error is remediated. During such time, Fees (as defined in this Item 4) will continue to accrue. From time to time, Fees can be increased or decreased (that is, JPMS may increase any fees to JPMS, the Portfolio Manager or the Model Portfolio Provider). JPMS will notify the client whenever a fee increase is made to the client’s Program account(s). b. Negotiability of Fee For example, certain Programs may offer “buy-and-hold” investment strategies that generally seek investments intended to be held on a long- term basis. Accounts invested in such a strategy will typically experience less trading activity and lower turnover than accounts invested in a shorter- term strategy. Therefore, because the client pays the full Fee regardless of the low number of transactions in the account, such an account increases the likelihood that the client would pay less for the services provided in the particular Program (including brokerage services) on a separate, “unbundled” basis than on that Program’s “wrap-fee” basis, other things being equal. In its discretion, and subject to the maximum Fee described above, JPMS can negotiate, reduce, or completely waive the JPMS component of the Fee for any client or group of clients. JPMS may negotiate the amount and calculation of the Fee based on a number of factors, including the type and size of the account, anticipated level of trading activity, services provided to the account, historical factors and/or the scope of the client’s relationship with JPMS, subject to certain internal guidelines. As described in Item 4.i above, for STRATIS and UMA, a client’s acceptance of a Model Portfolio, strategy or security designated by JPMS as the default replacement for one removed from certain Programs may cause the client to incur expenses or to pay an overall Fee greater than the client was incurring or paying prior to the replacement or than client would have incurred or paid had JPMS selected a different default replacement. In addition, for UMA, certain default replacements will cause an increase in the amount of the UMA Overlay Manager’s component of the Fee. With respect to the portion of the Fee paid to a Portfolio Manager, on a case-by-case basis, Portfolio Managers may agree to apply a lower fee rate with respect to individual client accounts in the Program (e.g., if an account has over $5,000,000 in assets). For PA, PM, and UMA, the securities may be available to clients directly from the issuers of the securities or a broker-dealer, as applicable, pursuant to the terms of their prospectuses and without paying the Fee. e. Costs in Addition to the Fee The Fee (or component of the Fee) paid by a client may be higher or lower than the fees other clients pay in the same Program or another Program and/or the cost of similar services offered through other financial firms. JPMS charges fees that it believes are reasonable in relation to the scope of services and nature of the investment advice provided, but these fees are not always the lowest available from other firms and/or our affiliates. c. Portion of Fee Paid to Wealth Advisors The Fee does not cover commissions or other charges resulting from transactions not executed through JPMS or its affiliates, or the clearing, settlement and custody services provided by a custodian other than JPMS. When trade clearing and settlement services are provided by another executing broker-dealer or custodian — either because applicable law requires it or upon the client’s request and JPMS’ consent — they are not included in the Fee, and the other broker-dealer and/or custodian are entirely responsible for the execution, clearing and/or settlement of the transaction and/or custody of the client’s account assets. JPMS typically pays a portion of the Fee it receives from each client to the Wealth Advisor(s) for that client. The exact portion of the Fee paid by JPMS to the Wealth Advisor varies among the Wealth Advisors and depends on factors such as each Wealth Advisor’s overall annual revenue production but is most commonly within a range from 40% to 50%. The amount received by a Wealth Advisor as a result of a client’s participation in certain Programs may be more than the Wealth Advisor would receive if the client participated in certain other Programs, or paid separately for investment advice, brokerage and other services covered by the Fee. In those circumstances, the Wealth Advisor has an incentive to recommend the Program that would pay higher compensation. In addition, the Fee does not cover “mark-ups,” “mark-downs” or “dealer spreads” charged by dealers unaffiliated with JPMS when JPMS, acting as agent for the client in the Program, effects a transaction with an unaffiliated dealer acting as principal (i.e., for the dealer’s own account), typically in connection with certain fixed income and over-the-counter securities that are traded primarily in “dealer” markets. Such “mark-ups” on securities bought by the client, “mark-downs” on securities sold by the client, and “dealer spreads” (the difference between the bid price and offer price) are generally incorporated into the net price that the client pays or receives in the transaction. Similarly, the Fee does not cover “dealer spreads” that JPMS (or its affiliates) or other broker-dealers may receive when acting as principal in certain transactions. However, JPMS and its affiliates will not charge, and the net price paid or received by the client will not incorporate, any “mark- up” or “mark-down” in connection with such principal transaction. As disclosed above, certain of our wrap Programs charge a negotiable JPMS Fee and others charge a negotiable JPMS Fee plus a Portfolio Manager fee, which in certain circumstances may be waived but is not negotiable. Differences in fees for Portfolio Managers in Programs with a third-party manager, or the absence of such fees in any Program, create a conflict of interest as such differences provide an opportunity for Wealth Advisors to negotiate a higher JPMS Fee for a strategy with lower or no separate Portfolio Manager fees than they would for strategies that charge a higher Portfolio Manager fee. The opportunity to negotiate a higher fee also creates a financial incentive for Wealth Advisors to recommend such Programs and/or Portfolio Managers. The ability of the Wealth Advisor to negotiate a higher JPMS Fee in these circumstances also provides a financial benefit to JPMS, which retains a portion of the Fee. d. Comparative Cost of the Program The Fee also does not cover certain costs or charges that may be imposed by JPMS (or its affiliates) or third parties, including costs associated with using margin, exchanging foreign currencies, borrowing fees on short sales, odd-lot differentials, activity assessment fees, transfer fees, transfer taxes, exchange fees, wire transfer fees, termination fees, postage fees, auction fees, certain structured products, foreign clearing and settlement fees and expenses associated with ADRs, Global Depository Receipts (GDRs), World Equity Benchmark Shares (WEBS), exchange-traded notes (ETNs), real estate investment trusts (REITs), closed-end investment companies that invest a substantial portion of their assets in the securities of specified foreign countries (closed-end country funds), and with converting non-U.S. Participation in a Program may cost the client more or less than purchasing the services provided in such Program separately. Comparable services may be available at lower aggregate costs on an “unbundled” basis outside of the Programs or through other firms. Factors that bear upon the relative cost of a Program include: 33823_J 11-05-2025 Page 13 of 49  securities into ADRs or GDRs, if applicable, and other fees or taxes required by law. additional compensation from the transaction, but the total cost of the purchase and conversion should not exceed the cost if they had originally purchased the ADR in U.S. markets. Trading Away and Associated Costs f. If the investment in the Portfolio is made through an IRA, any foreign taxes incurred generally would not be creditable against the client’s U.S. income tax liability. The client is urged to consult their tax advisor regarding investment in non-U.S. entities, including whether they may be eligible for a credit against their U.S. income tax liability for any foreign taxes paid and whether they may be eligible for a lower rate or partial refund of non-U.S. withholding taxes pursuant to one or more applicable income tax treaties. Refer to “Foreign Issuers Risk” for more information. Certain Portfolio Managers place all or substantially all of certain types of trades with a broker-dealer other than JPMS for execution, depending on the types of securities traded in an investment strategy. It is not uncommon for investment managers to trade away in fixed income, foreign security and small-cap equity strategies. Investment strategies with such types of securities could be more costly to a client than investment strategies in which Portfolio Managers more commonly place trades with JPMS for execution. h. Mutual Funds/Pooled Investment Fees For any Program in which the services of a portfolio manager are offered, in general, Portfolio Managers place orders in fixed income or debt securities with broker-dealers other than JPMS. For these fixed income trades, the client will incur a mark-up, mark-down or spread charged by the other broker-dealer that is not covered by the Fee. Clients may incur indirect fees and expenses for investments in mutual funds (including money market funds), ETFs, closed-end funds, and other pooled investment vehicles. These fees and expenses are initially paid by the Funds but ultimately are borne by the client as a Fund shareholder. Such fees and expenses are in addition to, and generally will not be deducted from, the Fee. Assets of Program clients may be invested in a share class of a mutual fund with internal fees and expenses that are higher than one or more other share classes of the same mutual fund. JPMS and its affiliates also may receive compensation in addition to the Fee in connection with the operation and/or sale of shares of affiliated or unaffiliated Funds to clients in the Programs. Refer to Item 9.iii for more information. Fixed income securities are primarily traded in dealer markets. These securities are directly purchased from or sold to a financial services firm acting as a dealer (or principal). A dealer executing such trades may include a commission, a markup (on securities it sells), a markdown (on securities it buys), or a spread (the difference between the price it will buy, or “bid,” for the security and the price at which it will sell, or “ask,” for the security) in the net price at which transactions are executed. The bid and ask are prices quoted by the dealer, so the client should understand that a dealer’s bid price would be the price at which a client is selling their security, and the dealer’s ask price would be the price at which a client is buying the security. Certain investment companies may not permit shares to be transferred outside of a Program account and in certain circumstances may, in their sole discretion, redeem fund shares held by clients; the liquidation of these fund shares may have tax consequences to clients. Any such sales charges and applicable redemption fees (including contingent deferred sales charges) incurred by clients in connection with the liquidation of mutual funds or other securities for investment of the proceeds in this Program are in addition to the Fee. Clients should review a Portfolio Manager’s Form ADV Part 2A Brochure, ask about a Portfolio Manager’s trading practices, and consider that information carefully before selecting an investment manager and its investment strategy. In particular, clients should carefully consider any additional trading costs associated with a particular Portfolio Manager and investment strategy before selecting them for their wrap fee program account. Further, to the extent that cash used for investment in such Programs comes from redemptions of investments outside of the Programs, there may be tax consequences or additional cost from sales charges previously paid and/or redemption fees incurred. Clients do not pay any sales charges for purchases of mutual funds in the programs. However, some mutual funds may charge, and not waive, a redemption fee on certain transaction activity in accordance with their prospectuses. General Fee and Compensation Issues i. When Portfolio Managers place orders with broker-dealers other than JPMS, clients that elect to receive trade confirmations will receive a trade confirmation issued by JPMS that will provide details of the trade as follows: (i) for equity trades, the trade confirmation and account statement will generally indicate “traded away” and will list the commission the client incurred as an additional cost in connection with trading away by a Portfolio Manager; and (ii) fixed income trades will generally indicate “traded away” and show a price for the traded security that is inclusive (i.e., net) of the commission, mark-up or mark-down paid by the client to the other broker- dealer, but it does not break out or otherwise show the amount of the commission, mark-up or mark-down separately. Some fixed income trades, due to operational factors, will not indicate “traded away”; however, all fixed income trades are “traded away” whether or not they are indicated as such. For more information on trades away from the Firm, refer to “Trading Practices Disclosures for Wrap Fee Programs” available at chase.com/managed-account-disclosures. g. ADR Fees In valuing assets in Program accounts, JPMS uses information provided by recognized independent quotation and valuation services or will rely on information it receives from other third parties, if applicable. JPMS believes this information to be reliable but does not verify the accuracy of the information provided by these sources. If any information provided by these sources is unavailable or is believed to be unreliable, JPMS will value assets in a manner JPMS determines in good faith to reflect fair market value. JPMS may use different valuation sources for different purposes. As a result, the determination of asset values may differ for different purposes. For example, the account asset values used in the Fee calculation may not match the asset values listed on the account’s custodial statements. Detailed calculations of any account asset values are available upon request. Because the Fee is typically charged on all assets in the account, in a low interest rate environment, a client may earn less interest on assets held in the account as cash or cash alternatives such as money market funds than the amount of the Fee the client is paying JPMS with respect to such assets, and therefore the client’s net yield with respect to such assets may be negative. Special tax rules may apply to investments in foreign issuers, including ADRs. For example, one or more issuers in the Portfolio may qualify as a passive foreign investment company or a controlled foreign corporation for U.S. tax purposes, and non-U.S. withholding tax may be imposed on distributions or gains. Also, in certain cases, additional U.S. tax reporting may be required. Shares of foreign companies on foreign exchanges can be purchased and the shares converted to ADRs for client accounts if the total cost of the purchase and conversion is more advantageous than directly purchasing the ADRs. To the extent that a subsidiary of J.P. Morgan assists in the conversion of foreign stock, J.P. Morgan affiliates will receive JPMS may offer recruiting and retention packages to certain new or existing Wealth Advisor(s). These packages can be substantial and are generally 33823_J 11-05-2025 Page 14 of 49  based on the business serviced by the Wealth Advisor at JPMS or a prior firm. Such incentives may include sign-on bonuses and or/or loan bonus arrangements, equity awards and buyout of forfeited deferred compensation or retention arrangements. We address these conflicts of interest by disclosing them to the client and requiring Wealth Advisors and certain supervisors to review a client’s account at account opening to ensure that it is suitable for the client in light of the client’s Risk Score. Brokerage and Best Execution or “bid,” for the security and the price at which it will sell, or “ask,” for the security) in the net price at which transactions are executed. The bid and ask are prices quoted by the dealer, so CBP clients should understand that a dealer’s bid price would be the price at which a client is selling their security, and the dealer’s ask price would be the price at which a client is buying the security. These transaction fees (i.e., mark-ups, mark-downs or spreads charged by third-party broker-dealers) are not included in the Fee. Clients should carefully consider these costs before selecting a strategy in CBP. Refer to “Trading Away and Associated Costs” above for more information. Interest Earned on Float In keeping with the wrap fee nature of the Programs, JPMS typically provides the following services for client accounts in the Programs: execution of transactions, clearing and settlement services, custody and processing, and the maintenance of securities in good possession and control locations. Typically, in the Client Agreement, the client directs that transactions in the client’s account be executed by JPMS (or its affiliates), or where a client has selected an unaffiliated or affiliated third-party Portfolio Manager in an applicable Program, the client authorizes each selected Portfolio Manager to effect transactions for the client’s account(s) through JPMS (or its affiliates), subject to each Portfolio Manager’s duty under applicable law to seek “best execution” as well as JPMS’ capacity and willingness to execute the transaction. By recommending the Programs to clients, therefore, JPMS also is recommending itself as broker-dealer. Although Portfolio Managers have discretion to select brokers or dealers other than JPMS or its affiliates, Portfolio Managers generally place such trades through JPMS because the Fee paid by each client account only covers execution costs on trades executed through JPMS or its affiliates. Execution costs include fees JPMS pays to exchanges and/or regulatory agencies on certain transactions. Certain securities included in portfolios can be less liquid or are traded infrequently. To fulfill its duty to seek best execution of transactions for client accounts, Portfolio Managers (other than advisers in PM) can select broker-dealers other than JPMS or its affiliates to affect a trade for a client account and any execution costs charged by non-JPMS broker-dealers will be paid by the client account. Refer to “Trading Away and Associated Costs” for more detail. JPMS or its affiliates may retain, as compensation for the performance of services, an account’s proportionate share of any interest earned on aggregate cash balances held by JPMS (or its affiliates) with respect to “assets awaiting investment or other processing.” This amount, known as “float,” is earned by JPMS or its affiliates through investment in a number of short-term investment products and strategies, including, without limitation, loans to customers and investment securities, with the amount of such earnings retained by JPMS or its affiliates, due to the short-term nature of the investments, being generally at the prevailing Federal Funds interest rate (a publicly available average rate of all Federal Funds transactions entered into by traders in the Federal Funds market on a given date), less FDIC insurance and other associated costs, if any. “Assets awaiting investment or other processing” for these purposes include, to the extent applicable, new deposits to the account, including interest and dividends, as well as any uninvested assets held in the account caused by an instruction to purchase and sell securities. JPMS or its affiliates will generally earn float until such time as such assets may be automatically swept into a sweep vehicle or otherwise reinvested. “Assets awaiting investment or other processing” may also arise when JPMS facilitates a distribution from the account. Thus, pursuant to standard processes for check disbursement, cash is generally debited from the account on the date on the face of the check (also called the payable date). Such cash is deposited in a non-interest bearing omnibus deposit account held by JPMS or its affiliates, where it remains until the earlier of the date the check is presented for payment or the date payment on the check is stopped at the client’s instruction (in which case the underlying funds are returned to the account). JPMS or its affiliates derive earnings (float) from their use of funds that may be held in this manner, as described above. Margin A Portfolio Manager’s primary objective in broker-dealer selection is to comply with its duty to seek best execution of orders for clients. Best execution does not necessarily mean the lowest commission or price, but instead involves consideration of a number of factors. In evaluating whether another broker or dealer will provide better execution, Portfolio Managers will take various criteria into consideration in assessing the provider including, but not limited to, its market making ability, net cost or net realization from trade, price per unit of security, reliability and financial stability. JPMS may earn additional compensation through brokerage- related services it provides, such as extending margin loans to clients and holding free-credit balances. Certain Wealth Advisors may receive production- based bonuses that take into account these amounts in addition to investment advisory fees (including the Fee paid by clients in the Programs) and other revenue generated by the Wealth Advisor. These bonuses may create a conflict of interest for those Wealth Advisors in that they have a financial incentive to recommend Program accounts to incur additional or higher fees for these services by, for example, incurring additional or larger margin loans. In addition, because the rate of fees charged for these brokerage-related services is negotiable, this compensation may give these Wealth Advisors a financial incentive to charge clients higher rates for these services. In effecting transactions for client assets in a Program, JPMS or its affiliates will be acting exclusively as a broker-dealer, and trades will be handled by JPMS consistent with its best execution and other regulatory obligations under applicable law. Directing that JPMS or its affiliates execute transactions for Program accounts may deprive the client of any savings on trade execution and other costs that otherwise might be negotiated with other broker-dealers and benefits that may result from using alternative trading systems; may result in less favorable execution than would be obtained through the use of one or more other broker-dealers; and may cost the client more money. Not all investment advisers require their clients to direct brokerage in such a fashion. Clients should consider the costs and disadvantages of directing that JPMS or its affiliates execute transactions for Program accounts. Excluding PA and PM, in general, any margin debit balances held by the client cannot be held in a Program account. For purposes of the calculation of the Fee, the net market value of the client’s assets on which the Fee is based generally will not be reduced by the amount of any margin debit balances held by the client in any account outside of the Programs, even if some or all of the proceeds of the loan represented by the margin debit balances are held in the client’s Program account(s) or were used to purchase securities held in the client’s Program account(s), and even if some or all of the assets in the client’s Program account(s) are used to collateralize or secure the loan represented by the margin balances. Similarly, any interest and fees paid by the client in connection with any In managing the strategies available through CBP, the Portfolio Manager will generally place orders for CBP client accounts with broker-dealers other than JPMS due to the Portfolio Manager’s regulatory requirement to avoid principal transactions and the nature of fixed income and preferred securities. Fixed income and preferred securities are primarily traded in dealer markets. These securities are directly purchased from or sold to a financial services firm acting as a dealer (or principal). A dealer executing such trades may include a mark-up (on securities it sells), a mark-down (on securities it buys), or a spread (the difference between the price it will buy, 33823_J 11-05-2025 Page 15 of 49  margin debit balances held by the client in any account outside of the Programs will not be taken into account in the calculation of the net equity or performance of the client’s Program account(s), as reflected in account statements, written performance reviews or otherwise. other costs associated with the Deposit Account paid by JPMCB, and the interest rate and other income earned by JPMCB on the loans and investments made with the deposits. The income that JPMCB earns through its lending and investing activities is usually significantly greater than the interest earned by clients through the Deposit Account. It is typically also greater than the fee earned by all J.P. Morgan entities from managing and distributing money market mutual funds available to Program clients. Additionally, JPMCB has agreed to pay JPMS a monthly flat fee for each account that uses the Deposit Account; however, JPMS is currently waiving receipt of this fee. Therefore, JPMS and JPMCB have a conflict of interest in offering or utilizing the Deposit Account (and in making it the default “sweep” option for Program clients residing in the U.S.). JPMS believes that the conflict is addressed through: • The fact that Wealth Advisors do not receive any additional compensation for assets held in the Deposit Account as opposed to another cash alternative; • Online disclosure of the available cash options and yields at jpmorgan.com/sweep; In PA and PM, the Wealth Advisor will not receive compensation in respect of interest and fees paid by the client on margin debit balances held in the client’s Program account. Nonetheless, for all of the Programs, JPMS and the Wealth Advisor have a financial incentive for the client to incur margin debit to buy securities in the client’s Program account because: (1) the client will be required to pay JPMS interest and fees on the debt, and they have a further financial incentive for the client’s margin debit balance to be held in an account outside of the Program because in that case; (2) the Fee paid by the client on the Program account will be higher than it would be if the margin debit balance was held in the Program account; (3) the Wealth Advisor may receive compensation from JPMS in respect of the margin interest and fees paid by the client that the Wealth Advisor would not receive if the margin debit balance was held in a Program account; and (4) the net market value of the Program account will be increased by the value of the additional securities purchased with the proceeds of the margin loan (and will not be offset by the amount of the client’s margin debit held in the account outside of the Program), resulting in a higher Fee. Cash Allocations or Balances and the Sweep Feature j. • The client’s ability to affirmatively select another available “sweep” option and to change the “sweep” option selection to an available alternative at any time; • The JPMorgan Chase Deposit Account Disclosure provided to the client; and • The client’s ability to obtain the prospectus for each money market mutual fund that is an available alternative to the Deposit Account. ITEM 5 — ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS JPMS requires that all clients who wish to open and maintain an account in the Programs enter into the applicable JPMS investment advisory Client Agreement, which sets forth the services that JPMS (or, if applicable, the Portfolio Manager(s)) will provide to the client. The specific terms and conditions of the Client Agreement will govern the handling of the client’s Program account(s) and the investment advisory relationship between the client and JPMS and, as applicable, other parties to the agreement with respect to the account(s). A separate account is required for each strategy selected by the client, even if they are managed by the same Portfolio Manager. Clients in the Programs authorize JPMS, to the extent permitted by applicable law, to invest (i.e., sweep) available cash balances in the JPMorgan Chase Deposit Account (the Deposit Account) or one or more money market mutual funds that are managed by affiliates of JPMS and a third-party. The Deposit Account is the default “sweep” option for Program clients who reside in the U.S. and do not select an available “sweep” alternative or if the sweep selected is no longer available. Investment in a non-proprietary model or a Non-Proprietary Strategy Election to exclude J.P. Morgan Funds does not apply to cash balances held in sweep options. Cash “swept” or allocated to the Deposit Account is remitted for deposit by JPMS, acting as the client’s agent, into a demand deposit account maintained at JPMorgan Chase Bank, N.A. (JPMCB). Balances in the Deposit Account are covered by FDIC insurance, subject to applicable limits, terms and conditions, but are not protected by the Securities Investor Protection Corporation. JPMS does not review or monitor FDIC insurance limits for clients. Clients are responsible for monitoring the total amount of deposits that they have with JPMCB to determine the extent of FDIC deposit insurance coverage available to them on their deposits. The JPMorgan Chase Deposit Account Disclosure provides further information about the Deposit Account, including the limits, terms and conditions of FDIC insurance coverage. The client’s Risk Score for an account in any Program will apply to such account while in the Program (unless the client subsequently changes the investment objective or risk tolerance by promptly notifying the client’s Wealth Advisor(s)), notwithstanding any different investment objective or risk tolerance previously identified by the client for the account when it was a brokerage account or an account in one of the other Programs. If the account is terminated and becomes a brokerage account outside the Programs, the investment objective previously identified by the client for the account as a brokerage account will again apply to the account. For ICS, the client must also enter into an Investment Manager (IM) Agreement directly with each selected Portfolio Manager that will manage the client’s ICS assets, giving the manager(s) trading authority over the ICS assets. The IM Agreement(s) will govern the terms of the client’s investment advisory relationship with the Portfolio Manager(s). Outsourced Family Office Services (OFO) The interest rate on the Deposit Account will vary based on business and economic conditions and is reset periodically at JPMCB’s sole discretion. The interest rate on the Deposit Account may be higher or lower than yields on other available cash alternatives (e.g., money market mutual funds). From time to time, JPMS or a Portfolio Manager may deem it in the client’s best interest to maintain a certain percentage of assets in cash or cash alternatives, especially when markets are volatile. However, because the Fee is typically charged on the value of all assets in the account (including cash and cash alternatives), in a low interest rate environment, the net investment return on cash and cash alternatives, including the Deposit Account, will be negative. The current rates and yields for available cash options for Program accounts, including the Deposit Account, can be found online at jpmorgan.com/sweep. These rates and yields change regularly, so it is prudent to check this website periodically. Although there is no charge to clients with respect to the Deposit Account, JPMCB benefits from the Deposit Account because, through the Deposit Account, JPMCB receives a stable, cost-effective source of funding. JPMCB uses customer deposits in the Deposit Account to fund current and new businesses, including lending activities and investments. The profitability on such lending activities and investments is generally measured by the difference, or “spread,” between the interest rate paid on the deposits and Apart from JPMS’ investment advisory services as described in this brochure, JPMS also provides certain administrative services on an outsourced basis to high net-worth families (OFO). OFO services can differ based on the needs of the family members but can include coordination, administration and reporting of the family’s financial affairs; monitoring of private equity investment returns, capital calls and tax reporting document collection; banking and lending coordination; consultation with and coordination of professional consultants; assistance with multi- 33823_J 11-05-2025 Page 16 of 49  iii. Employee Benefit Plans and Retirement Plans including asset-protection considerations, generational tax planning and asset protection techniques; coordination with service providers (including JPMS or its affiliates when engaged in writing to provide investment advisory services); business planning analysis; coordination of risk management analysis by internal and external advisors, cybersecurity considerations, and life and property/casualty insurance coverage; and guidance on a family’s philanthropic goals and causes as well as charitable techniques and structures. Unless otherwise agreed by JPMS in writing, these family office services do not constitute or include investment advice or the provision of fiduciary services. For Program accounts established for retirement plans subject to ERISA and for IRAs (collectively, retirement accounts), when providing services under the Programs, JPMS is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the IRC with respect to the assets of the retirement accounts invested in the Program. Additionally, for retirement accounts that invest in Programs where JPMPI acts as sub- adviser or Portfolio Manager, JPMPI is a “fiduciary” as that term is defined in Section 3(21)(A) of ERISA and/or Section 4975(e)(3)(B) of the IRC with respect to the assets that it manages in those Programs. Program Minimums i. Certain Programs require the client to maintain a minimum amount of assets for opening an account in that Program. JPMS may, in its discretion, waive or reduce the minimum account opening size for certain clients or accounts. If a Program account falls below the Program minimum, JPMS can terminate the Program account at its discretion. The minimum account size typically required in the Programs are listed below. Certain Portfolio Managers may impose minimums that are higher or lower than those specified above. In addition, JPMS may impose a higher minimum account opening size if the client wishes to use a custodian other than JPMS and JPMS, in its discretion, is willing to maintain the account on such a basis (a) PA and PM The accounts of employee benefit plans (as defined in ERISA) and retirement plans (as defined in Section 4975(e)(1) of the IRC), which include IRAs, is subject to certain JPMS policies, restrictions and other terms and conditions that are different from those applicable to other accounts in a Program. Such policies, restrictions and other terms and conditions may affect, for example, the Portfolio Managers that may be available for selection for the management of such accounts (for applicable Programs), the securities that may be available for investment in such accounts, the manner in which transactions may be effected in such accounts, the ability of such accounts to trade on margin, and the fees and expenses that may be charged to such accounts. As a result, in certain circumstances, application of the policies, restrictions and other terms and conditions can result in the performance of employee benefit plan and retirement plan accounts being worse than it would have been absent such policies, restrictions, and terms and conditions. $10,000 (b) STRATIS Fees for certain Portfolio Managers or Model Portfolio Providers that are affiliated with JPMS are waived or rebated to client Program accounts that are IRAs or tax-qualified plans. Refer to Item 4ii.a above for more information. In general, $100,000 for equity strategies; $50,000 for investment strategies in Multi-Manager Strategies; and $250,000 for fixed income strategies, subject to minimum account requirements imposed by the applicable Portfolio Manager. (c) CBP Retirement plan accounts can invest in certain strategies that include affiliated Funds. When applicable, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with the client’s Program account assets will be credited to the relevant account. Refer to Item 4.ii above for more information. $250,000 for municipal portfolios and $100,000 for taxable accounts. Certain corporate bond portfolios are available with a minimum investment of $500,000. (d) UMA For STRATIS and CBP, for certain strategies, JPMS can designate any strategy or Model Portfolio as the replacement for any retirement plan account. There is generally no across-the-board minimum account size to participate in UMA. However, depending on investment selections and allocations, minimums will be applied. ICS (e) For UMA, for retirement plan accounts (including IRAs and accounts subject to ERISA) invested in a Joint Discretion Strategy or Model Portfolio that has been removed from the Program, JPMS will not designate an affiliated Joint Discretion Strategy or Model Portfolio as the default replacement. If such a Joint Discretion Strategy or Model Portfolio has been designated as the default replacement for non- retirement plan accounts, JPMS will designate a different, unaffiliated default replacement. $100,000 subject to any minimum amount requirement imposed by the applicable Portfolio Manager. The account opening minimums imposed by Portfolio Managers in the ICS Universe may often vary substantially. Information about a particular manager’s minimum account opening requirement is available from a client’s Wealth Advisor(s). Certain strategies may not be available to retirement accounts. For instance, certain ESG strategies and US Endowments & Foundations strategies are currently not available to retirement accounts. (f) JPMCAP $10,000 or $250,000 for models containing Liquid Alternative Funds. US Endowments & Foundations investment strategy has a minimum investment of $1,000,000. Retirement accounts can be restricted from investing in Funds that have a certain relationship with J.P. Morgan. As a result, performance of retirement accounts can differ from non-retirement accounts invested in the same strategy. ii. Types of Clients iv. Acceptance of Accounts JPMS and, where applicable, the Portfolio Manager may each decline to accept a particular client or account in the applicable Program at any time and for any reason at their sole discretion. Additionally, in cases where a Portfolio Manager’s strategy is available in two Programs, (i.e., STRATIS and ICS), JPMS may, in its sole discretion, require the client to participate in the strategy through one Program (STRATIS) rather than through the other (ICS). The types of clients generally eligible to participate in the Programs include individuals, trusts, estates, corporations and other business entities, retirement plans (including IRAs and pension plans), foundations and endowments. Not all types of clients are eligible for each Program. Discretionary Programs are not typically intended for investors who seek to maintain control over trading in their accounts, who have a short-term investment horizon (or expect ongoing and significant withdrawals), or who expect to maintain consistently high levels of cash or money market funds. 33823_J 11-05-2025 Page 17 of 49  v. Cash Balances in Program Accounts and advisory client relationships at JPMS. Some Wealth Advisors are put forward as PM candidates by their managers after discussions between them. A portion of Program accounts will be held in cash, cash equivalents or money market funds as part of the overall investment strategy for the account and funds awaiting withdrawal by the client. Cash and cash equivalents, including money market funds, are subject to the Fee. For additional information, refer to “Cash Allocations or Balances and the Sweep Feature” in item 4. Cash raised for withdrawal will be charged both the Fee and the applicable Model Portfolio Provider or Portfolio Manager fee until the cash is removed from the account. For certain Programs, cash that is not removed from an account in a timely manner will be reinvested pursuant to the selected asset allocation or investment strategy. JPMS’ evaluation of a portfolio manager candidate for PM typically involves a review of various factors including nature and length of experience in the securities industry; the types of investment advisory services previously provided to clients by the candidate; proposal of investment approach that the candidate intends to implement in PM; the candidate’s knowledge and understanding of relevant portfolio management concepts and of the markets and securities in which the candidate proposes to invest client assets; and the opinion of the candidate’s manager(s) concerning the candidate’s qualifications for discretionary portfolio management and the growth of their book of business. ITEM 6 — PORTFOLIO MANAGER SELECTION AND EVALUATION For the applicable Programs, JPMS selects Portfolio Managers and specific strategies and/or Model Portfolio Providers and specific Model Portfolios and securities for inclusion in such Programs. i. Please note that JPMS generally requires a prescribed minimum amount of PM assets under management (AUM) for Wealth Advisors to remain in PM, and it reserves the right to remove them from the Program if the AUM falls below this threshold. This requirement creates an incentive for the Wealth Advisors to recommend PM (over other Programs) so that they are able to meet the minimum AUM threshold. Selection of Portfolio Managers, Model Portfolio Providers and/or Program Securities, as applicable PA Wealth Advisors participating in PM are required to complete an internal training that provides an overview of the Program and compliance policies and, in certain circumstances, are required to complete third-party training. STRATIS, UMA and ICS (Portfolio Managers and Strategies in the ICS Universe) JPMS selects Portfolio Managers and certain of their strategies, as well as Model Portfolio Providers and certain of their Model Portfolios and/or Program securities, as applicable, for inclusion in STRATIS, UMA and the ICS Universe. JPMS’ recommendation of UMA is a recommendation of Envestnet as UMA Overlay Manager. Because PA is an investment advisory Program in which the advice provided to clients is exclusively non-discretionary, though the clients authorize JPMS to identify, review and make available a universe of Program securities, the Program does not entail the recommendation, selection, evaluation or use of “Portfolio Managers.” In this Item, therefore, JPMS addresses its selection and evaluation of the Wealth Advisors who individually provide non-discretionary investment advice to clients for their PA accounts on behalf of JPMS. Wealth Advisors participating in PA are required to complete certain internal training that provides an overview of the Program, PA guidelines and policies, and other information essential to administering PA accounts and advising PA clients. JPMS engages affiliates of JPMS (each, a Review Vendor) to perform initial and periodic reviews of Portfolio Managers and their strategies, Model Portfolio Providers and their Model Portfolios, Funds and Program securities (collectively referred to herein as Researched Products) and/or to perform such periodic reviews itself, as described in more detail below. Currently, Researched Products are reviewed by the manager solutions and operational due diligence teams of JPMPI or its affiliates as described in “Reviews of Researched Products in all Programs (excluding ICS Non- Researched Portfolio Managers and Strategies).” Typically, JPMS does not affirmatively seek to identify Wealth Advisors to participate in the Program. In general, Wealth Advisors are themselves responsible for expressing an interest in advising client accounts in the Program, either in connection with their transition to JPMS from other firms where they might have advised client accounts in investment advisory Programs or arising out of their existing brokerage and advisory client relationships at JPMS. Accordingly, JPMS ordinarily does not recommend or select Wealth Advisors in the Program for particular clients — even if a different Wealth Advisor or their investment style or strategy may be better suited for the achievement of the investment objective of a particular client or prospective client than the Wealth Advisor with whom the investor has a relationship or who has marketed their Program services to that investor. PM JPMS identifies to clients only Researched Products from those it has made available through the Programs. JPMS identifies suitable Researched Products for a client based on the investment objective(s) and other information the client has provided. Other factors that may affect identification for a particular client include asset size, any investment restrictions and/or guidelines the client may wish to impose, or other factors that may make a particular Researched Product more desirable to the client. UMA — Wealth Advisor Discretion In certain circumstances, Wealth Advisors are required to complete a third- party training that is essential to administering and managing the accounts. In the Client Agreement, PM clients authorize JPMS itself — not a specific Wealth Advisor — to manage the clients’ PM accounts on a discretionary basis. In that sense, JPMS is the sole Portfolio Manager in PM. In this Item, therefore, JPMS addresses its initial evaluations and periodic reviews of the Wealth Advisors who seek to manage, and those who are approved and therefore do manage, PM accounts on a discretionary basis on behalf of JPMS. Approved Wealth Advisors, each as agent for JPMS, manage client accounts on a discretionary basis. To become approved to manage accounts in the Program, Wealth Advisors are required to meet certain criteria used by JPMS in its evaluation of potential candidates. Typically, JPMS does not affirmatively seek to identify Wealth Advisors to participate in and for selection to manage accounts in UMA. In general, Wealth Advisors are solely responsible for expressing an interest in advising and managing client accounts with discretion in UMA, either in connection with their transition to JPMS from other firms where they might have advised and managed client accounts in investment advisory Programs or arising out of their existing brokerage and advisory client relationships at JPMS. In PM, approved Wealth Advisors, each as agent for JPMS, act as Portfolio Managers and manage PM client accounts on a discretionary basis. To become approved to manage accounts in the Program, Wealth Advisors are required to meet certain criteria used by JPMS in its evaluation of potential candidates. Typically, JPMS does not affirmatively seek to identify Wealth Advisors to participate in and for selection as Portfolio Managers to manage accounts in PM. In general, Wealth Advisors are solely responsible for expressing an interest in advising and managing client accounts on discretion in PM, either in connection with their transition to JPMS from other firms where they might have advised and managed client accounts in investment advisory Programs or arising out of their existing brokerage 33823_J 11-05-2025 Page 18 of 49  ii. Review of Portfolio Managers, Model Portfolio Providers and/or Program Securities, as applicable Reviews of Researched Products in all Programs (excluding ICS Non- Researched Portfolio Managers and Strategies) The manager solutions team is responsible for researching and selecting Researched Products to be included in a Program and for subjecting them to a review process. The due diligence process is designed to subject both JPMIM and non-J.P. Morgan investment strategies to the same process. However, JPMPI and its strategies are reviewed through different processes which are described below. JPMS’ evaluation of a Wealth Advisor candidate for UMA typically involves a review of various factors, including nature and length of experience in the securities industry, the types of brokerage and investment advisory services previously provided to clients by the candidate, proposal of investment approach that the candidate intends to implement in UMA, the candidate’s knowledge and understanding of relevant Wealth Advisors’ concepts and of the markets and securities in which the candidate proposes to invest client assets, the nature and size of the candidate’s existing clientele and the anticipated number and size of the candidate’s client accounts expected to participate in the Program, and the opinion of the candidate’s advisor(s) concerning the candidate’s qualifications for discretionary portfolio management and the growth of their book of business. Certain Wealth Advisors manage the same securities across different Programs and clients in the different Programs can have different execution experiences depending on the nature of the Program. ICS Non-Researched Portfolio Managers and Strategies oversight, information security and The manager solutions team applies its discretion when reviewing the Researched Products and is not required to apply all factors equally to each Researched Product in the search universe. J.P. Morgan maintains certain capacity limitations on investment positions in non-J.P. Morgan Funds due to liquidity concerns, regulatory requirements and related internal policies. In circumstances where these limitations mean that JPMS would not be able to invest all desired client assets in a particular non-J.P. Morgan Fund, the manager solutions team will likely recommend a J.P. Morgan Fund. The manager solutions team will begin the search process by defining an applicable universe of investment strategies, which typically will include J.P. Morgan investment strategies when there is one in the desired asset class. The manager solutions team utilizes both quantitative and qualitative factors during its initial review process. There will also be a review of a Researched Product’s infrastructure from a non-investment perspective. This review includes the organizational structure, trade life cycle, legal/compliance systems infrastructure. In certain circumstances, a client may be permitted to maintain assets in ICS with a Portfolio Manager or in a strategy that has been removed from, or never was in, the ICS Universe. Such cases typically involve a client invested in a Portfolio Manager’s strategy through a wrap fee program sponsored by another firm who wishes to move their account to a JPMS wrap fee program but remains invested in the same or a substantially similar strategy, or a client who identifies a Portfolio Manager’s strategy to JPMS. In all cases, it is in JPMS’ sole discretion whether to permit the client to maintain an ICS account managed by a Portfolio Manager or in a strategy outside of the ICS Universe. JPMS may also determine that it will no longer permit clients to maintain ICS assets with an ICS Non-Researched Portfolio Manager and/or strategy. In such cases, clients may select a Portfolio Manager or strategy that is part of the ICS Universe or JPMS may terminate the Program account. CBP and JPMCAP The manager solutions and operational due diligence teams then make a formal presentation recommending particular Researched Products, as applicable, to an internal governance committee, which is responsible for approving or rejecting them. The manager solutions team is also responsible for monitoring and re-evaluating approved Researched Products, as applicable, as part of its ongoing review process. The Portfolio Manager for CBP and the Portfolio Manager for JPMCAP are both affiliates of JPMS. Because there is only one Portfolio Manager in each Program, JPMS’ recommendation of such Program is a recommendation of that Portfolio Manager for the client and assets at issue. The following disclosures are for all Programs, as applicable: As part of the due diligence process, the manager solutions team of JPMPI or its affiliates applies an eligibility framework that establishes minimum criteria for determining the universe of ESG strategies offered to clients. Strategies that satisfy the 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. For all Programs, if a Wealth Advisor leaves the firm or the Program, or goes on leave of absence, JPMS will typically reassign any affected Program account to one or more other Wealth Advisors, as JPMS deems suitable and appropriate. The manager solutions and operational due diligence teams utilize 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). The selection of replacement Wealth Advisors is typically made by the Regional Director(s) of the replaced Wealth Advisor in consultation with the team responsible for administration of the Programs. Typically, when possible, JPMS endeavors to reassign the Programs accounts to one or more suitable Wealth Advisors in the same branch office or geographical area. Additionally, Researched Products are reviewed via an internally developed quantitative screening process on an ongoing basis (the Systematic Research Process). This Systematic Research Process reviews the portfolio manager’s organization, investment process, investment philosophy and performance using only quantitative criteria. Researched Products may be removed from a Program or, for certain Programs, as it relates to Funds, can no longer be eligible for purchase if it is determined that they do not meet the criteria set forth in the Systematic Research Process. Additionally for PM, JPMS generally also considers the similarity between the investment strategies implemented by the prior and replacement Wealth Advisors; whether multiple replacement Wealth Advisors will be needed to accommodate different subsets of accounts invested in different investment strategies by the prior Wealth Advisor; and the qualifications and resources of other available Wealth Advisors to assume responsibility for the PM accounts of the prior Wealth Advisor. Researched Products subject to the Systematic Research Process may also go through the Qualitative Research Process. To the extent that Researched Products are reviewed through both processes, the results of the Qualitative Research Process will override the results of the Systematic Research Process. Alternatively, JPMS may terminate an account from the Programs, in which event any such account is no longer investment advisory in nature and will revert to a client-directed, non-discretionary brokerage account. Additionally, for ICS, there may be certain products or asset classes that have not been included in the manager solutions teams’ due diligence process (Non-Researched Products). Non-Researched Products will 33823_J 11-05-2025 Page 19 of 49  generally be treated similarly to those Researched Products that do not meet the criteria of the Systematic Research Products. metrics. However, the JPMPI strategy review process does not include a search process to identify a universe and core peer set of strategies from which to select. From time to time, this governance committee may place the relevant programs on probation or terminate them as part of its ongoing monitoring and oversight responsibilities. This committee considers analysis and recommendations from an internal due diligence team separate from the manager solutions team. Refer to the JPMPI Form ADV Part 2A for more information about the applicable research process and its methods of analysis. An internal governance committee is responsible for the ongoing monitoring and oversight of Researched Products as approved and available for the Programs. This committee considers analysis and recommendations from the manager solutions team. From time to time, this internal governance committee may place them on probation or terminate them as part of its ongoing monitoring and oversight responsibilities. The internal governance committee review process is generally the same for J.P. Morgan and non–J.P. Morgan investment strategies. If a Researched Product that is in the Programs is placed on probation, the manager solutions and operational due diligence teams will continue to review the Researched Product during the probation period. Generally, during this time, only those clients already holding or invested in an affected Researched Product when it was closed to new investors are permitted to contribute additional assets to their account(s) invested in that Researched Product, but such clients will generally be notified (in writing) for certain Programs that the Researched Product has been closed to new investors. Further review of an affected Researched Product by JPMS and/or the manager solutions team may result in a re-opening to new investors. JPMS may provide clients with important information about Researched Products. The information is typically prepared by JPMS (or a third-party) and is based on and/or incorporates information provided by Portfolio Managers, Model Portfolio Providers and other third-party sources. JPMS believes that this information is accurate; however, JPMS does not independently verify or guarantee the accuracy or completeness of the information. JPMS shall have no liability with respect to information provided by third parties. Performance information may be included in the information provided by JPMS. This performance is calculated by the Portfolio Managers themselves or by third parties, and neither JPMS nor a third-party (except when JPMS acts as implementation manager for certain Model Portfolios in STRATIS) engaged by it reviews such performance information to determine or verify its accuracy or its compliance with presentation standards. The performance information may not be calculated on a uniform and consistent basis. Clients will be provided with the Portfolio Manager’s Form ADV Part 2A and/or other applicable disclosure document(s). Clients should review such disclosure document(s) carefully for important information about the Portfolio Manager, including risks associated with the selected strategy (if applicable). Each Portfolio Manager is solely responsible for the truthfulness, completeness and accuracy of its own Form ADV or other applicable disclosure document(s). Before investing in a Fund, clients should review the Fund’s prospectus carefully and consider all of the information in it. A Fund’s prospectus contains important information about the Fund, including the Fund’s investment objectives, risks, charges and expenses. Each Fund is solely responsible for the truthfulness, completeness and accuracy of its own prospectus. In the event a particular Researched Product is removed from a Program, JPMS will notify affected clients of the removal and for certain Programs, may designate a default replacement in the Program. (JPMS generally does not recommend a replacement for a particular client unless JPMS removes a Researched Product from the Program.) If JPMS designates such a default replacement, each affected client will be notified in writing that, unless the client affirmatively selects, in writing, a different replacement in the Program by the date specified by JPMS, the client’s assets in the removed Researched Product will be re-invested into the designated replacement without further notice to or consent of the client. In designating a default replacement, JPMS will consider the appropriateness of the Researched Products available in a Program as suitable replacements. JPMS also may assist the client in identifying a suitable replacement in cases where JPMS does not designate a default replacement or where the client wishes to consider alternatives to the default designated by JPMS; such assistance is typically based on the same types of factors used by JPMS to identify Researched Products for clients in the first instance. For UMA, if a Researched Product is removed from the Program and JPMS does not designate a default replacement, the client’s assets invested according to the removed Researched Product will automatically be re- invested into an ETF available in the Program, selected by JPMS, that is in an asset class or employs an investment strategy similar (as determined by JPMS) to that of the removed Researched Product, unless the client affirmatively selects a replacement of the client’s own choosing prior to the date specified by JPMS in the removal notice. Regardless of whether JPMS designates a default replacement, the sale of the client’s assets in the removed Researched Product may have tax consequences for the client. Wealth Advisors who learn of JPMS’ decision to remove a Researched Product from the Program may take or recommend action on the basis of such knowledge (i) with respect to certain clients and accounts (inside or outside of the Program) before others or (ii) before JPMS’ written notice of the removal decision has been sent to all affected Program clients. JPMS is not responsible for the performance of any Researched Product or any Portfolio Manager’s, Model Portfolio Provider’s or Fund issuer’s compliance with applicable laws and regulations or other matters within their control (except when JPMS acts as implementation manager for certain Model Portfolios in STRATIS). Each Portfolio Manager, Model Portfolio Provider or Program security’s adviser is solely responsible for the management of that designated account(s) or security. If a client selects more than one Portfolio Manager or Model Portfolio Provider, they may engage in contrary transactions with respect to the same security. JPMS will effect transactions for a Program account only if and to the extent instructed by a Portfolio Manager. Without limiting the generality of the foregoing, JPMS shall not be responsible for any act or omission of any Portfolio Manager, Model Portfolio Provider or any Program security or party acting on behalf of the Program security, or any misstatement or omission contained in any document prepared by or with the approval of any of them or any loss, liability, claim, damage or expense whatsoever, as incurred, arising out of or attributable to such misstatement or omission. JPMS’ periodic reviews of Portfolio Managers and their respective investment strategies by Review Vendors does not substitute for each client’s ongoing monitoring of their account(s) and the performance of their investments. ICS Non-Researched Portfolio Managers and Strategies JPMIM and its strategies or Model Portfolios are subject to the same selection and review processes conducted by the manager solutions team as the unaffiliated Portfolio Managers and strategies or Model Portfolio Provider and Model Portfolios in the Program, though the manager solutions team applies its discretion and is not required to apply all factors equally to each Fund in the search universe. JPMPI’s strategies are subject to the separate though similar review process incorporating similar quantitative and qualitative assessments and implemented by an internal governance committee which provides ongoing oversight of the relevant programs to review compliance with strategy-specific guidelines and In certain circumstances, subject to approval by JPMS, a client in ICS may be permitted to remain invested with, or invest with, a Portfolio Manager and in such Portfolio Manager’s strategy that has been removed from, or never was in, the ICS Universe (ICS Non-Researched). While clients permitted to maintain such accounts in ICS will typically receive the other 33823_J 11-05-2025 Page 20 of 49  party conduct) periodic reviews of them in the Programs, in identifying them in the Programs to specific clients; and/or in designating them as default replacements for account assets invested in Researched Products that are removed from the Program because if a client selects (or is automatically re-invested into) an affiliated Researched Product, JPMS and its affiliates will receive greater aggregate compensation than if the client selected (or was automatically re-invested into) an unaffiliated Researched Product. services customarily provided by JPMS and its affiliates to ICS clients, JPMS will generally not perform periodic reviews of any such Portfolio Manager or strategy. In addition, JPMS and its affiliates may have access to or may collect information about Portfolio Managers and strategies that are in the ICS Non-Researched universe but have no obligation to share any such information with any ICS client, even if such information is negative or reflects poorly on the relevant Portfolio Manager or strategy. Notwithstanding that JPMS and its affiliates will not perform any such reviews, or be obliged to communicate any information it may have about the ICS Non-Researched Portfolio Managers and strategies to the client, the client will pay the same Fee to JPMS as other clients who do receive such services and will not be entitled to any discount or reduced Fee as a result. PA JPMS believes that this conflict is addressed by the fact that neither the persons responsible for the initial and periodic review of Researched Products for inclusion in the Programs and for possible designation as default replacements for Researched Products removed from the Program nor the Wealth Advisors who recommend or identify specific Researched Products to clients receive any direct financial benefit (such as additional compensation) from the investment of assets with an affiliated Researched Product instead of than in an unaffiliated one. Moreover, because Wealth Advisors are typically compensated in the Program through the receipt of a portion of JPMS’ component of the Fee, which is typically tied to or calculated based on the value of Program accounts, Wealth Advisors are to that extent incentivized to identify Researched Products they believe will increase the value of an account, regardless of whether or not they are affiliated with JPMS. Primary responsibility for the supervision of each Wealth Advisor advising accounts in PA lies with the head of the JPMS business and each Wealth Advisor’s Regional Director. Certain aspects of the day-to-day supervision of the Wealth Advisors is delegated by the head of the JPMS business (on behalf of the head of the JPMS business and Regional Directors) to Wealth Management Supervision. Ongoing reviews of Wealth Advisors in PA and the accounts they advise typically include reviewing PA accounts presenting a certain risk level, PA accounts with little or no trading activity and PA accounts holding a concentration of securities. iv. Use of J.P. Morgan Funds and Model Portfolio Providers and PM Potential Conflicts of Interest JPMS’ periodic reviews of Wealth Advisors and their respective investment strategies in PM do not substitute for each client’s ongoing monitoring of their account(s) and the performance of their investments. The standards applied to the periodic performance and other reviews of a Wealth Advisor’s strategy or strategies in PM vary from the reviews applicable to third-party Portfolio Managers in the other Programs (e.g., STRATIS, UMA etc.). investment strategy or strategies, generally JPMS reviews all applications for initial and additional modifications to strategies in PM. In addition, JPMS monitors all accounts in PM for adherence to internal Program guidelines and the performance of each Wealth Advisor’s in comparison to a relevant benchmark. For information relating to the day-to-day supervision of Wealth Advisors and the PA and PM accounts they advise generally, refer to Item 9.iv below. Conflicts of interest will arise whenever J.P. Morgan has an actual or perceived economic or other incentive in its management of clients’ portfolios to act in a way that benefits J.P. Morgan. Conflicts will result, for example (to the extent the following activities are permitted in the account): (1) when J.P. Morgan invests in an investment product, such as a mutual fund, structured product, separately managed account, or hedge fund issued or managed by a J.P. Morgan affiliate, such as JPMIM or JPMPI; (2) when a J.P. Morgan entity obtains services, including trade execution and trade clearing, from an affiliate; (3) when J.P. Morgan receives payment as a result of purchasing an investment product for a client’s account; or (4) when J.P. Morgan or an affiliate receives payment for providing services (including shareholder servicing, recordkeeping or custody) with respect to investment products purchased for a client’s portfolio. Other conflicts will result because of relationships that J.P. Morgan has with other clients or when J.P. Morgan acts for its own account. iii. Related Person Portfolio Managers, Model Portfolio Providers and/or Program Securities, as applicable Investment strategies are selected from both J.P. Morgan and third-party asset managers and are subject to a review process by the manager solutions team. From this pool of strategies, J.P. Morgan portfolio construction teams select those strategies J.P. Morgan believes fits its asset allocation goals and forward-looking views in order to meet the portfolio’s investment objective. As a general matter, J.P. Morgan prefers J.P. Morgan managed strategies. J.P. Morgan expects the proportion of J.P. Morgan managed strategies will be high (in fact, up to 100 percent) in strategies, such as, for example, cash and high- quality fixed income, subject to applicable law and any account- specific considerations. J.P. Morgan may allocate a significant portion of the assets in JPMCAP or certain strategies of STRATIS to J.P. Morgan Funds. That portion varies depending on market or other conditions. As described above, other than the Wealth Advisors in PM and when JPMS acts as implementation manager for certain Model Portfolios in STRATIS, JPMS does not act as a Portfolio Manager or Model Portfolio Provider in the other Programs. Each Wealth Advisor in the Program is an employee, registered representative and investment advisory representative of JPMS and is subject to substantially the same selection and review processes and criteria described above. For PA, certain Wealth Advisors in the Program may also act as discretionary Portfolio Managers of client accounts in PM. Clients should understand that, to the extent a Wealth Advisor has clients in both Programs and intends to buy or sell a security for clients in PM at or about the same time he intends to recommend the same transaction to clients in PA, the Wealth Advisor will generally execute the transaction for the discretionary accounts in PM before executing it for non-discretionary investment accounts in PA. This could have a negative effect on the performance of accounts in PA. While J.P. Morgan’s internally managed strategies generally align well with J.P. Morgan’s forward-looking views, and J.P. Morgan is familiar with the investment processes as well as the risk and compliance philosophy of J.P. Morgan, it is important to note that J.P. Morgan receives more overall fees when internally managed strategies are included. In certain programs, J.P. Morgan offers the option of choosing to exclude J.P. Morgan managed strategies (other than cash and liquidity products) in certain portfolios. In certain of the other Programs, some of the Portfolio Managers are affiliates of JPMS. In addition, certain securities and their issuers and/or advisers are affiliated with JPMS. More specifically, some of the Funds available to clients in the Programs are sponsored by affiliates of JPMS and/or have engaged investment advisers affiliated with JPMS, including JPMIM, to manage their investment. The Six Circles Funds are mutual funds advised by JPMPI and sub-advised by third parties. Although considered internally managed strategies, JPMS has a conflict of interest in including affiliated Researched Products in the Programs, conducting (or having an affiliated Review Vendor/third- 33823_J 11-05-2025 Page 21 of 49  neither JPMPI nor its affiliates retain a fee for fund management or other fund services. Separately Managed Accounts. Portfolios invested in individual equity or fixed income securities may be managed by JPMS affiliates or by a third- party manager. When an affiliate manages these investments, there is a benefit to J.P. Morgan since it increases the overall revenue of J.P. Morgan. Additionally, a manager of a separately managed account may invest in products that may result in additional revenue to J.P. Morgan. portfolio and are not intended to be standalone investments, each Six Circles Fund may underperform as a standalone investment, even in instances where the overall portfolio performs as intended. Further, the overall performance and liquidity of a Six Circles Fund may be negatively affected, and additional transaction costs may be incurred by the Six Circles Fund, as a result of (i) allocation decisions made by JPMC to shift discretionary client assets among the Six Circles Funds and other investments; and (ii) allocation decisions made by JPMC to shift Six Circles Fund assets among different investment strategies and sub-advisors, which may negatively affect the value of Six Circles Fund shares even if they are no longer held through a JPMC portfolio. IMPORTANT INFORMATION ABOUT MUTUAL FUNDS AND EXCHANGE- TRADED FUNDS REGISTERED UNDER THE INVESTMENT COMPANY ACT OF 1940, AS AMENDED risks, charges and expenses, go For more information about the Six Circles Funds, including the funds' objectives, to sixcirclesfunds.com/literature or contact your Wealth Advisor for a prospectus. Read the prospectus carefully. Affiliated Model Portfolio Providers With respect to Model Portfolio Providers, if an affiliate serves as a Model Portfolio Provider in the applicable Programs, there is a benefit to J.P. Morgan since it increases the overall revenue of J.P. Morgan. Additionally, both affiliated and unaffiliated Model Portfolio Providers can invest in products that can result in additional revenue to J.P. Morgan. J.P. Morgan Funds — Management Fees. J.P. Morgan and its affiliates are the sponsor or manager of Funds, including ETFs, that can be purchased for accounts. In such case, J.P. Morgan or its affiliates will receive a fee for managing such Funds or for providing other services to such Funds based on the value of the assets invested in the Funds. As such, J.P. Morgan and its affiliates will receive more total revenue when the client’s portfolio is invested in such Funds than when it is invested in third- party Funds. When a retirement account is invested in J.P. Morgan Funds, the retirement account will be credited an amount equal to the account’s pro rata share of all such fees paid to J.P. Morgan or its affiliates in connection with the account’s investments in J.P. Morgan Funds. Allocation of Affiliated Funds in JPMCAP J.P. Morgan Funds and Third-Party Funds—Other Fees and Expenses. All Funds have various internal fees and other expenses that are paid by managers or issuers of the Funds or by the Fund itself but that ultimately are borne by the investor. J.P. Morgan may receive administrative and servicing and other fees for providing services to both J.P. Morgan Funds and third-party funds that are held in the client’s portfolio (except for when the fund is held in a client’s account that is an IRA or is governed by ERISA). These payments may be made by sponsors of the Funds (including affiliates of JPMS) or by the Funds themselves and may be based on the value of the Funds in the client’s portfolio. Funds or their sponsors may have other business relationships with J.P. Morgan outside of its portfolio management role or with the broker-dealer affiliates of J.P. Morgan, which may provide brokerage or other services that pay commissions, fees and other compensation. JPMPI can allocate a portion of the assets in JPMCAP to J.P. Morgan Funds. That portion varies depending on market or other conditions. There are multiple models in each of the investment strategies available in JPMCAP. Certain models invest only in Funds, while other models can also invest in Liquid Alternative Funds and municipal securities. The prior composition of investment strategies in JPMCAP is not intended to predict the future composition of investment strategies or use of J.P. Morgan Funds in JPMCAP. The use of J.P. Morgan Funds, non–J.P. Morgan Funds and J.P. Morgan cash in a client’s account will depend on the client’s asset level, the model selected, reasonable restrictions placed by the client on the management of an account, and other factors. Each client should review account opening documentation, confirmations, and quarterly and annual statements for more information about the actual allocation in their account. Six Circles Funds J.P. Morgan developed the J.P. Morgan Six Circles Funds (Six Circles Funds) exclusively for use in J.P. Morgan investment advisory accounts. Since October 2018, the Six Circles Funds have been available in Program accounts where JPMPI is sub-adviser. The following chart for JPMCAP show the allocation of J.P. Morgan Funds (excluding Six Circles Funds), non–J.P. Morgan Funds, Six Circles Funds and J.P. Morgan cash for JPMCAP taxable models. The chart does not reflect models that elect not to use J.P. Morgan Funds, models that elect only Index-Oriented Vehicles, or models that utilize Liquid Alternative Funds (other than the Aggressive Growth investment strategy because all Aggressive Growth investment strategies include Liquid Alternative Funds) or municipal fixed income options. The charts show the difference between the taxable and retirement models in each investment strategy (except for a U.S. Focused model). Allocations shown here are illustrative only, do not necessarily represent actual use of J.P. Morgan Funds and third-party issuers and managers represented in any particular client’s account, and can change without notice. In JPMCAP, JPMPI has full discretionary authority to select securities and investment vehicles and is not required to adhere to the illustrative allocations pictured here. Six Circles Funds are specifically designed for use in discretionary Program accounts as completion funds to align with J.P. Morgan’s core portfolio views. JPMPI acts as investment adviser to the Six Circles Funds and engages third-party investment managers as sub- advisers to the Six Circles Fund investment portfolios. J.P. Morgan will have certain benefits and efficiencies from investing account assets in the Six Circles Funds instead of unaffiliated Funds; however, J.P. Morgan does not retain investment advisory fees for managing the Six Circles Funds through an agreement to waive any investment advisory fees that exceed the fees owed to Six Circles Fund third-party sub-advisers. Six Circles Funds do not pay fees to J.P. Morgan for any other services to the Six Circles Funds. Services to the Six Circles Funds are provided by third-party service providers and are generally paid by the Six Circles Funds or J.P. Morgan. (The market value of assets invested in the Six Circles Funds will be included in calculating the advisory fees paid on the overall portfolio.) Six Circles Fund shares may only be purchased in Program accounts for which JPMC has investment discretion. Should the client choose to close its discretionary Program account but retain the interest in Six Circles Funds, Six Circles Fund shares must be held through an eligible brokerage account and no new purchases into the Six Circles Funds will be permitted (other than dividend reinvestment). Since the Six Circles Funds are completion portfolios designed to complement and work as part of the overall discretionary 33823_J 11-05-2025 Page 22 of 49  October 6, 2025 — Taxable Models October 6, 2025 — J.P. Morgan Multi-Manager Strategies JPMCAP Investment Strategy J.P. Morgan Funds Non- J.P. Morgan Funds Six Circles Funds J.P. Morgan Cash J.P. Morgan Multi- Manager Strategies J.P. Morgan Funds Non- J.P. Morgan Funds Six Circles Funds J.P. Morgan Cash 13.00% 57.00% 29.00% 1.00% 10.00% 88.00% 0.00% 2.00% Aggressive Growth 7.00% 57.00% 35.00% 1.00% Growth Dynamic Multi-Asset Strategy 6.00% 52.00% 41.00% 1.00% Balanced 0.00% 98.00% 0.00% 2.00% 4.00% 59.00% 36.00% 1.00% Conservative Dynamic Multi- Asset Strategy – Non-Prop 8.00% 26.00% 65.00% 1.00% 28.00% 71.00% 0.00% 1.00% Managed Equities Dynamic Yield Strategy 9.00% 61.00% 29.00% 1.00% 0.00% 99.00% 0.00% 1.00% Managed Fixed Income 0.00% 99.00% 0.00% 1.00% U.S. Focused 4.00% 95.00% 0.00% 1.00% Emerging Markets Growth and Income Strategy Balanced ESG 29.00% 70.00% 0.00% 1.00% 3.00% 96.00% 0.00% 1.00% US Endowments & Foundations Liquidity Management Strategy 29.00% 70.00% 0.00% 1.00% October 6, 2025 — Retirement Models Liquidity Management Strategy Retirement J.P. Morgan Funds Six Circles Funds J.P. Morgan Cash Non- J.P. Morgan Funds 9.00% 90.00% 0.00% 1.00% Sustainable Equity Strategy 13.00% 57.00% 29.00% 1.00% JPMCAP Investment Strategy Aggressive Growth 0.00% 99.00% 0.00% 1.00% Growth 7.00% 57.00% 35.00% 1.00% Balanced 6.00% 52.00% 41.00% 1.00% Sustainable Fixed Income Strategy Conservative 4.00% 59.00% 36.00% 1.00% 8.00% 26.00% 65.00% 1.00% Managed Equities 9.00% 61.00% 29.00% 1.00% Managed Fixed Income U.S. Focused 0.00% 99.00% 0.00% 1.00% Balanced ESG 4.00% 95.00% 0.00% 1.00% Allocation of Affiliated Funds in J.P. Morgan Multi-Manager Strategies in STRATIS The prior composition of investment strategies in J.P. Morgan Multi- Manager Strategies is not intended to predict the future composition of investment strategies or use of J.P. Morgan Funds in J.P. Morgan Multi- Manager Strategies. Allocations shown here are illustrative only, do not necessarily represent actual use of J.P. Morgan Funds and non-J.P. Morgan Funds represented in any particular client’s account, and may change without notice. JPMPI is not required to adhere to the illustrative allocations pictured here. The allocations in any particular client’s account will depend on, among other things, the investment strategy selected, client elections, client asset level, reasonable restrictions placed by clients on the management of an account, and other factors. Each client should review account opening documentation, confirmations, and quarterly and annual statements for more information about the actual allocation in their account. Credits for Retirement Accounts holding J.P. Morgan Funds JPMPI can allocate a significant portion of the assets in a J.P. Morgan Multi- Manager Strategy to J.P. Morgan Funds. That portion varies depending on market or other conditions. There are multiple investment strategies available in the J.P. Morgan Multi-Manager Strategies. Certain investment strategies invest only in Funds, while other investment strategies also utilize Model Portfolio Providers. If a Program account owned by an IRA, or other client that is a qualified retirement plan subject to the prohibited transaction provisions of Section 4975 of the IRC, holds any J.P. Morgan Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with Program account assets will be credited to the account. Refer to “Credit of Certain Fees to IRAs and Certain Other Retirement Plan Accounts” above. The following chart illustrates, as of the date indicated, the allocation of J.P. Morgan Funds (excluding Six Circles Funds), non–J.P. Morgan Funds, Six Circles Funds and J.P. Morgan cash for the J.P. Morgan Multi-Manager Strategies. The chart does not reflect strategies that utilize Model Portfolio Providers. v. Allocations of Client Assets to J.P. Morgan Funds (Including New Funds) in JPMCAP and the J.P. Morgan Multi-Manager Strategies in STRATIS J.P. Morgan has an incentive to allocate assets to new J.P. Morgan Funds to help it develop new investment strategies and products. J.P. Morgan has an incentive to allocate assets of the portfolios to a J.P. Morgan Fund that is small, or to which J.P. Morgan has provided seed capital. In addition, J.P. Morgan benefits when JPMPI does not sell or withdraw assets from a J.P. Morgan Fund in order to avoid or delay the sale or withdrawal’s adverse impact on the fund. Accounts managed by J.P. Morgan have significant ownership in certain J.P. Morgan Funds. J.P. Morgan faces conflicts of 33823_J 11-05-2025 Page 23 of 49  directly to JPMS. When acting as an implementation manager, JPMS generally purchases and sells in the accounts investments that are consistent with the Model Portfolios provided by the Model Portfolio Provider, though JPMS retains investment discretion over the account investments. c. Risk of Loss interest when considering the effect of sales or redemptions on such funds and on other fund shareholders in deciding whether and when to redeem its shares. A large sale or redemption of shares by J.P. Morgan acting on behalf of its clients could result in the underlying J.P. Morgan Fund selling securities when it otherwise would not have done so, potentially increasing transaction costs and adversely affecting fund performance. A large sale or redemption could also significantly reduce the assets of the fund, causing decreased liquidity and, depending on any applicable expense caps, a higher expense ratio, or liquidation of the fund. J.P. Morgan has policies and controls in place to govern and monitor its activities and processes for identifying and managing conflicts of interest. vi. Methods of Analysis, Investment Strategies and Risk of Loss a. Methods of Analysis and Investment Strategies (PA and PM) 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. In addition to various methods of analysis used by Wealth Advisors in PM and/or PA as discussed below, refer to Item 6.ii above for a discussion of the research and review processes that the manager solutions team conducts on Researched Products used in the Programs. In formulating investment advice, managing assets, and recommending or effecting (as applicable) transactions in PA and PM, JPMS (through its Wealth Advisors) uses various methods of analysis, including: Set forth below are certain material risk factors associated with all of the Programs. There are certain other risk factors described elsewhere in this Brochure. For a more complete summary of material risk factors and conflicts of interest associated with the Programs, refer to the applicable Portfolio Manager’s Form ADV Part 2A and/or any applicable prospectuses or other relevant disclosure documents. Each client is urged to consult with their own Wealth Advisor to discuss the risks associated with the particular investment strategy or strategies, investments and/or transactions recommended or effected for the client’s account(s). • Fundamental analysis, typically an effort to measure the intrinsic value of a security through analysis of the issuer itself, its financial statements and condition, its management and competitive advantages, and its competitors and markets; GENERAL RISKS • Technical analysis, typically involving the study of data generated by market activity, such as past security prices and volume, in an effort to identify patterns and trends that may suggest a security’s future price performance; and involving • Cyclical analysis, generally the examination of macroeconomic and market trends as a guide to forecasting security prices. The method(s) of analysis used for a PA or PM Program client/account varies among and depends on the individual practice and investing philosophy of the Wealth Advisor. There is no assurance that a particular Wealth Advisor will use any of the methods of analysis identified above. 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 underperform 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, embargoes, tariffs, sanctions and other trade barriers, regulatory events, other governmental trade or market control programs, and related geopolitical events. 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, pandemics or endemics. JPMS typically does not provide investment advice in PA and PM with respect to futures and commodities. JPMS may provide advice with respect to, and may invest or recommend that Program accounts invest in, other types of investments and securities, including U.S. equity and income- oriented securities, shares of open and closed end Funds (including those that invest in futures and commodities), interests in master limited partnerships and other pooled investment vehicles, derivatives, certain structured notes (in PA), options, REITs, and cash. Descriptions of some of the particular types of investments and investment tactics that may be recommended by certain Wealth Advisors in their implementation of certain investment strategies, and some of the risks presented by such investments are provided below. The information provided below is meant to summarize certain risks and is not inclusive of each and every potential risk associated with each investment type or applicable to a particular client account. Therefore, clients should not rely solely on the descriptions provided below and are urged to speak with their Wealth Advisor and ask questions regarding risk factors applicable to a particular investment strategy or product, read all product-specific risk disclosures and determine whether a particular investment strategy or type of security is suitable for their account in light of their specific circumstances, investment objectives and financial situation. Infectious Disease Risk. The effects of any future pandemic or other global event to business and market conditions may have a significant negative impact on the performance of the separately managed accounts and J.P. Morgan Fund investments; increase separately managed account and fund volatility; exacerbate preexisting political, social and economic risks to separately managed accounts and J.P. Morgan Funds; 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 pandemic or other global events that affect the instruments in which a separately managed account or J.P. Morgan Funds invest, 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 pandemic or other global events and the extent to which the associated conditions and governmental responses impact a separately managed account or J.P. Morgan Fund will also depend on future developments, which are highly uncertain, difficult to accurately predict and subject to frequent changes. b. Methods of Analysis and Investment Strategies (Model Portfolios of STRATIS) JPMS acts as implementation manager for certain Model Portfolios in STRATIS that are provided by non-discretionary Model Portfolio Providers Regulatory Risk. There have been legislative, tax, and regulatory changes and proposed changes that may apply to the activities of JPMS that may require legal, tax and regulatory changes, including requirements to provide additional information pertaining to a client account to the Internal 33823_J 11-05-2025 Page 24 of 49  Revenue Service (IRS) or other taxing authorities. Regulatory changes and restrictions imposed by regulators, self-regulatory organizations and exchanges vary from country to country and may affect the value of client investments and their ability to pursue their investment strategies. Any such rules, regulations and other changes, and any uncertainty in respect of their implementation, may result in increased costs, reduced profit margins, and reduced investment and trading opportunities, all of which would negatively impact performance. 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 cybersecurity defenses or plans of its service providers, financial 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. 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, or be otherwise harmful. J.P. Morgan typically incorporates human oversight to reduce the risk of acting on potentially defective outputs. AI Tools present Data Sources Risk, Cybersecurity Risk and Model Risk (as further 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 J.P. Morgan’s implementation of AI Tools and increase compliance costs and the risk of non-compliance. Further, 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. Model Risk. Some strategies can include the use of various proprietary quantitative or investment models. Investments selected using models may perform differently than expected as a result of changes from the factors’ historical — and predicted future — trends and technical issues in the implementation of the models, including, for example, issues with data feeds. Moreover, the effectiveness of a model may diminish over time, including as a result of changes in the market and/or changes in the behavior of other market participants. A model’s return mapping is based partially on historical data regarding particular economic factors and securities prices. The operation of a model, similar to other fundamental, active investment processes, may result in negative performance, including returns that deviate materially from historical performance, both actual and pro-forma. For a model-driven investment process — and again similar to other, fundamental and active investment processes, there is no guarantee that the use of models will result in effective investment outcomes for clients. Additionally, client accounts with lower asset levels can experience some dispersion from the established models. Data Sources 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 accuracy 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 the data to J.P. Morgan 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. 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. AI Tools often use data feeds from a number of sources. If those data feeds or formats become corrupted, compromised, or discontinued in any material manner, or become undeliverable or inaccessible in a timely manner, the tools will be unable to properly function or its operation may be adversely impacted. The tool’s ability to use the data may also be adversely impacted by any change in the format of data delivered or acquired by the tools. 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. 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 (IBOR) are no longer representative of the underlying markets. New or alternative reference 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 J.P. Morgan 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 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, improper release, corruption and destruction of, or unauthorized access to, confidential 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 can 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, the 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 33823_J 11-05-2025 Page 25 of 49  market volatility may also disrupt the ability of market participants to create and redeem shares in ETFs. Further, 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 would vary substantially from the NAV per share of such ETF, and the client may incur significant losses from the sale of ETF shares. 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. Exchange-Traded Funds 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, an ETF trades like a 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 funds, there are specific risks to consider with respect to an investment in ETFs, including, but not limited to: • Variance from Benchmark Index. ETF and index mutual fund performance may 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 mutual funds (such as mergers and spin-offs) may impact the variance between the performances of the funds and applicable indices. • Tracking the Index. Certain funds track financial indices in which J.P. Morgan retains various intellectual property rights. As a result, J.P. Morgan may be entitled to receive index licensing fees from unaffiliated licensees of these indices. Affiliates of JPMS may develop or own and operate stock market and other indices based on investment and trading strategies developed by such affiliates. Affiliates of JPMS may also assist unaffiliated entities in creating indices that are tracked by certain ETFs or certain client accounts utilized by J.P. Morgan. Some of the ETFs advised by affiliates of JPMS (J.P. Morgan ETFs) seek to track the performance of certain of these indices. In addition, J.P. Morgan may manage client accounts that track the same indices used by the J.P. Morgan ETFs or that may be based on the same, or substantially similar, strategies that are used in the operation of the indices and the J.P. Morgan ETFs. The operation of the indices, the J.P. Morgan ETFs and client accounts in this manner may give rise to potential conflicts of interest. For example, client accounts that track the same indices used by the J.P. Morgan ETFs may engage in purchases and sales of securities relating to index changes to a time different to the implementation of index updates or J.P. Morgan ETFs engaging in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the J.P. Morgan ETFs’ 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 or less favorable performance relative to that of the index and the J.P. Morgan ETFs or other client accounts that track the index. Furthermore, JPMS may, from time to time, manage client accounts that invest in these J.P. Morgan ETFs. 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 coordinating the development and governance of the indices and those involved in decision-making for the ETFs and index mutual funds. Risks That Apply Primarily to ESG/Sustainable Investing Strategies • 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. Investment approaches that incorporate ESG considerations or sustainable investing can include additional risks. ESG or sustainable investing strategies (together, ESG Strategies), including ESG separately managed accounts, 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 or sectors that share common characteristics and are often 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 or investment adviser selected by J.P. Morgan, will align with the beliefs or values of the client. Additionally, other investment managers and investment advisers, including JPMIM, 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 • Secondary Market Risk. ETF shares are bought and sold in the secondary market at market prices. Although ETFs are required to calculate their 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 33823_J 11-05-2025 Page 26 of 49  belong to the restricted category, such security will be sold and could trigger a taxable event for that client. respect to the same theme or topic. In addition to the ESG Strategies, J.P. Morgan also offers investment products that utilize ESG criteria in developing the product while seeking to maximize financial return. When evaluating investments, an investment manager or investment adviser is dependent upon information and data that might be incomplete, inaccurate or unavailable, which could cause the manager/adviser to incorrectly assess an investment’s ESG or sustainable attributes. In making investment decisions, the Portfolio Manager uses 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 or programs 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 judgment of a data provider that might not reflect J.P. Morgan’s views or values and/or the views or values of the client. Further, 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 could be discontinued or changed at any time, including, but not limited to, changes to industry sector definitions, parameters, ownership categories, revenue calculations and estimations that could result in 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. ESG and sustainable investing are not uniformly defined concepts, and scores or ratings may vary across data providers that use similar or different screens based on their process for evaluating ESG characteristics. Investments identified by the Portfolio Manager 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 sustainability-related practices and the Portfolio Manager’s assessment of such practices could change over time. The application of category restrictions varies by asset class. Restrictions are not available for all strategies, and J.P. Morgan or the Portfolio Manager can reject a restriction if it deems the restriction to be unreasonable or not in line with the strategy. The number of restrictions that a client can select are limited based on the potential impact to the applicable strategy and potential deviation from the strategy’s model. Only those restrictions that can be applied by J.P. Morgan or the Portfolio Manager will be applied to the client’s portfolio. 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. 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 minimum criteria for determining the universe of ESG Strategies offered to clients. Strategies that satisfy the 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. For client portfolios that can hold Funds, the client cannot prohibit or restrict a Portfolio Manager from investing in specific securities or types of securities that are held within any Fund. Category restrictions will not be applied to strategies that invest only in Funds, nor will they be applied to investments made by Funds, so it is possible that client restrictions would not have any practical effect on an account comprised primarily of Fund investments. finance regulations and the The evolving nature of sustainable 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 difference in 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 an investment to be classified as a “sustainable investment.” Liquid Alternative Funds. Programs that make Liquid Alternative Funds available do so subject to asset threshold requirements. Liquid Alternative Funds refer to Funds that may hold more non-traditional investments, trade more frequently, employ more complex trading strategies, and have higher total expense ratios (plus higher annual operating expenses) than traditional mutual funds. Unless otherwise specified and where permitted by applicable law, 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 including any repayment of principal, Risks of Investing in Structured Products. In certain Programs, clients may invest in, or allocate assets among, various unaffiliated structured products, which are generally unsecured debt obligations of the companies that issue them (each, an issuer). As such, any payment on a structured is subject to the product, creditworthiness of the issuer. 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, J.P. Morgan or the Portfolio Manager may rely on information about a company, industry classification, industry grouping and/or issuer screening provided by J.P. Morgan, an affiliated service provider or a third-party. Structured products may not be suitable for all clients. Investing in structured products involves the use of derivatives and a higher degree of risk factors substantially different than those associated with other traditional investments, including risk of adverse or unanticipated market developments; issuer credit quality risk; risk of counterparty or issuer default; risk of lack of uniform standard pricing; risk of adverse events involving any underlying reference obligations, entity or other measure; risk of high volatility; and risk of illiquidity. The return on a structured product, including the amount paid at maturity, if any, is linked to the Category restrictions aim to screen companies that engage in certain behaviors or earn revenue derived from a restricted category; however, they do not exclude all companies with any tie or revenue derived from such restricted category. If a client holds an investment that is perceived to 33823_J 11-05-2025 Page 27 of 49  large capitalization companies, especially over the short term. Because smaller companies may have limited product lines, markets or financial resources or may depend on a few key employees, they may be more susceptible to particular economic events or competitive factors than large capitalization companies. This may cause unexpected and frequent decreases in the value of an account’s investments. Finally, emerging companies in certain sectors may not be profitable and may not realize earning profits in the foreseeable future. RISKS THAT APPLY PRIMARILY TO FIXED INCOME INVESTMENTS performance of an underlying asset (e.g., single stocks, indices, currencies, commodities or interest rates) and thus exposed to market and other risks related to the underlying asset(s). Therefore, it is possible that the return may be zero or significantly less than what investors could have earned on an ordinary, interest-bearing debt security. Past performance of an underlying asset class is not indicative of the profit and loss potential on any particular structured product. The value of the underlying assets can experience significant periods of fluctuation and prolonged periods of underperformance. Structured products are not FDIC insured and are not listed on any securities exchange. There may be little or no secondary market for a structured product, and information regarding independent market pricing for a structured product may be limited. This is true even if the product has a ticker symbol or has been approved for listing on an exchange. The price, if any, at which structured products can be purchased in secondary market transactions, if at all, will likely be lower than the original issue price and any sale prior to the maturity date could result in a substantial loss. Structured products are not designed to be short-term trading instruments; clients who purchase structured products should be willing to hold until maturity. The tax treatment of a structured product may be very different than that of a traditional investment or of the underlying asset, and significant aspects of the tax treatment of a structured product may be uncertain. It is important that before investing in a structured product, investors should review the accompanying prospectus and prospectus supplement to understand the actual terms of the risks associated with specific structured products. In certain transactions, investors may lose their entire investment, i.e., incur an unlimited loss. RISKS THAT APPLY PRIMARILY TO EQUITY INVESTMENTS Interest Rate Risk. “Interest rate risk” refers to the risk associated with market changes in interest rates. Interest rate changes may affect the value of a debt instrument indirectly (especially in the case of fixed rate securities) and directly (especially in the case of instruments whose rates are adjustable). Fixed rate securities increase or decrease in value based on changes in interest rates. If rates increase, the value of these investments generally declines. On the other hand, if rates fall, the value of these investments generally increases. Securities with greater interest rate longer maturities generally are subject to greater sensitivity and fluctuations in value. Variable and floating rate (i.e., adjustable) securities are generally less sensitive to interest rate changes than fixed rate instruments, but the value of variable and floating rate securities may decline if their interest rates do not rise as quickly, or as much, as general interest rates. Many factors can cause interest rates to rise. Some examples include governmental and tax policies, central bank monetary policy (such as an interest rate increase by the Federal Reserve), domestic and international economic and political considerations, fiscal deficits, trade surpluses or deficits, regulatory requirements, rising inflation rates, general economic conditions and other factors beyond the control of JPMS. It is difficult to accurately predict the pace at which interest rates will change or the timing, frequency or magnitude of any such changes. Any such changes could be sudden and could expose debt markets to significant volatility and reduced liquidity for securities. Equity Securities. Strategies that invest in equity securities (such as stocks) will be more or less volatile and carry more risks than some other forms of investment. The price of equity securities may rise or fall because of changes in the broad market or changes in ad company’s financial condition, sometimes rapidly or unpredictably. These price movements will generally result from factors affecting individual companies, sectors or industries selected or recommended for a portfolio or the securities market as a whole, such as changes in economic or political conditions. Interest rate sensitivity is generally more pronounced and less predictable in instruments with uncertain payment or prepayment schedules. This risk will be greater for long-term securities than for short-term securities. While for certain accounts JPMS may from time to time seek to hedge interest rate risks (including through investments in treasury securities or derivative instruments), there is no assurance that such measures, to the extent implemented, will be effective. Equity securities that are included or recommended for inclusion in growth strategies are generally those that the Wealth Advisor or Portfolio Manager believes will experience rapid earnings growth relative to value or other types of stocks. The value of these stocks generally is much more sensitive to current or expected earnings than stocks of other types of companies. Short-term events such as a failure to meet industry earnings expectations can cause dramatic decreases in the growth stock price compared to other types of stock. Growth stocks generally trade at higher multiples of current earnings compared to value or other stocks, leading to inflated prices and thus potentially greater declines in value. Equity securities that are included or recommended for inclusion in value strategies are generally those that the Wealth Advisor or Portfolio Manager believes the market has undervalued according to the Wealth Advisor’s or Portfolio Manager’s estimate of the company’s true worth. A Wealth Advisor or Portfolio Manager that engages in value investing selects stocks at prices that it believes are temporarily low relative to factors such as the company’s earnings, cash flow or dividends. A value stock can decrease in price or not increase in price as anticipated by the Wealth Advisor or Portfolio Manager if other investors fail to recognize the company’s value or the factors that the Wealth Advisor or Portfolio Manager believes will cause the stock price to increase do not occur. Credit Risk. There is a risk that issuers and/or counterparties will not make payments on securities and instruments when due or will default completely. Such default could result in losses. In addition, the credit quality of securities and instruments may be lowered if an issuer’s or a counterparty’s financial condition changes. Lower credit quality may lead to greater volatility in the price of a security or instrument, affect liquidity and make it difficult to sell the security or instrument. Certain strategies may invest in securities or instruments that are rated in the lowest investment grade category. Such securities or instruments are also considered to have speculative characteristics similar to high yield securities, and issuers or counterparties of such securities and instruments are more vulnerable to changes in economic conditions than issuers or counterparties of higher-grade securities and instruments. Prices of fixed income securities will be adversely affected and credit spreads will increase if any of the issuers of or counterparties to such investments are subject to an actual or perceived deterioration in their credit quality. Credit spread risk is the risk that economic and market conditions or any actual or perceived credit deterioration of an issuer may lead to an increase in the credit spreads (i.e., the difference in yield between two securities of similar maturity but different credit quality) and a decline in price of the issuer’s securities. Certain strategies or Portfolio Managers may invest or may recommend investments in securities of smaller companies. Investments in smaller companies are generally riskier than investments in larger companies. Securities of smaller companies tend to be less liquid than securities of larger companies. In addition, small companies are generally more vulnerable to economic, market and industry changes. As a result, the changes in value of their securities may be more sudden or erratic than in Government Securities Risk. Some strategies invest in securities issued or guaranteed by the U.S. government or its agencies and instrumentalities (such as the Government National Mortgage Association (Ginnie Mae), the Federal National Mortgage Association (Fannie Mae) or the Federal Home 33823_J 11-05-2025 Page 28 of 49  important to the management of the portfolio’s assets, the portfolio could suffer material adverse effects, including substantial share redemptions that could require the portfolio to sell portfolio securities at times when markets are not favorable. Loan Mortgage Corporation (Freddie Mac)). U.S. government securities are subject to market risk, interest rate risk and credit risk. Securities, such as those issued or guaranteed by Ginnie Mae or the U.S. Treasury, that are backed by the full faith and credit of the United States are guaranteed only as to the timely payment of interest and principal when held to maturity. Notwithstanding that these securities are backed by the full faith and credit of the United States, however, circumstances could arise that would prevent the payment of principal and interest. Securities issued by U.S. government-related organizations, such as Fannie Mae and Freddie Mac, are not backed by the full faith and credit of the U.S. government and no assurance can be given that the U.S. government will provide financial support. Liquidity Risk. Investments in some equity and privately placed securities, structured notes or other instruments can be difficult to purchase or sell, possibly preventing the sale of these illiquid securities at an advantageous price or when desired. A lack of liquidity can also cause the value of investments to decline, and the illiquid investments can also be difficult to value. Additionally, there may be no market for a fixed income instrument, and the holder may not be able to sell the security at the desired time or price. Even when a market exists, there may be a substantial difference between the secondary market bid and ask prices for a fixed income instrument. High Yield Securities Risk. Certain strategies invest in securities and instruments that are issued by companies that are highly leveraged, less creditworthy or financially distressed. These investments (commonly known as junk bonds) are considered speculative and are subject to greater risk of loss, greater sensitivity to interest rate and economic changes, valuation difficulties and potential illiquidity. Active Trading. Certain strategies engage in active and frequent trading leading to increased portfolio turnover, higher transaction costs, and the possibility of increased capital gains, including short-term capital gains that are generally taxable as ordinary income. Equity Investment Conversion Risk. A non-equity investment such as a convertible debt obligation may convert to an equity security. Alternatively, equity securities may be acquired in connection with a restructuring event related to non-equity investments. An investor may be unable to liquidate the equity investment at an advantageous time from a pricing standpoint. Geographic and Sector Focus Risk. Certain strategies and funds concentrate their investments in a region, small group of countries, an industry or economic sector, and as a result, the value of the portfolio will generally be subject to greater volatility than a more geographically or sector diversified portfolio. Investments in issuers within a country, state, geographic region, industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio may affect the overall value of the portfolio and may cause greater losses than it would in a portfolio that holds more diversified investments. Diversification Risk. Certain asset allocation and model portfolio construction processes assume that diversification is beneficial. This concept is a generally accepted investment principle, although no amount of diversification can eliminate investment risk, and the investment returns of a diversified portfolio may be lower than a more concentrated portfolio or a single investment over a similar period. Focused Portfolio Risk. A focused portfolio investment strategy’s portfolio will generally have more volatility risk than a strategy that invests in securities of a greater number because changes in the value of an individual security will have a more significant effect, either negative or positive, on the portfolio’s value. To the extent that the portfolio invests its assets in fewer securities, the portfolio is subject to greater risk of loss if any of those securities lose value. in securities of foreign Municipal Obligations Risk. The risk of a municipal obligation generally depends on the financial and credit status of the issuer. Changes in a municipality’s financial health may make it difficult for the municipality to interest and principal payments when due. A number of make municipalities have had significant financial problems recently, and these and other municipalities could, potentially, continue to experience significant financial problems resulting from lower tax revenues and/or decreased aid from state and local governments in the event of an economic downturn. Under some circumstances, municipal obligations might not pay interest unless the state legislature or municipality authorizes money for that purpose. Some securities, including municipal lease obligations, carry additional risks. For example, they may be difficult to trade or interest payments may be tied only to a specific stream of revenue. Municipal bonds may be more susceptible to downgrades or defaults during recessions or similar periods of economic stress. Factors contributing to the economic stress on municipalities may include lower property tax collections as a result of lower home values, lower sales tax revenue as a result of consumers cutting back spending, and lower income tax revenue as a result of a higher unemployment rate. In addition, since some municipal obligations may be secured or guaranteed by banks and other institutions, the risk to an investor could increase if the banking or financial sector suffers an economic downturn and/or if the credit ratings of the institutions issuing the guarantee are downgraded or at risk of being downgraded by a national rating organization. If such events were to occur, the value of the security could decrease or the value could be lost entirely, and it may be difficult or impossible for an investor to sell the security at the time and the price that normally prevails in the market. Foreign Issuers Risk. Investments issuers denominated in foreign currencies are subject to risks in addition to the risks of securities of U.S. issuers. These risks include political and economic risks, civil conflicts and war, greater volatility, expropriation and nationalization risks, sanctions or other measures by the United States or other governments, currency fluctuations, higher transactions costs, delayed settlement, possible foreign controls on investment, liquidity risks, and less stringent investor protection and disclosure standards of some foreign markets. Events and evolving conditions in certain economies or markets may alter the risks associated with investments tied to countries or regions that historically were perceived as comparatively stable becoming riskier and more volatile. These risks are magnified in countries in “emerging markets,” which may have relatively unstable governments and less-established market economies than those of developed countries. Interest on municipal bonds is generally exempt from federal income tax. The interest payments may also be exempt from state and local taxes if you reside in the state where the bond is issued. If a client invests in municipal bonds in a state other than the state of the client’s residence, the client may not receive the state income tax benefits. Additionally, the interest rate for municipal bonds is usually lower than on taxable fixed- income securities such as corporate bonds. Clients investing in municipal bonds should consider consulting a tax professional to discuss the tax implications of investing in municipal bonds, including the possibility that the bonds may be subject to the federal alternative minimum tax and may not be eligible for state income tax benefits. OTHER MISCELLANEOUS RISKS Emerging Markets Risk. International investing bears greater risk due to social, economic, regulatory and political instability in countries in “emerging markets.” Emerging market securities can be more volatile and less liquid than developed market securities. Changes in exchange rates and differences in accounting and taxation policies outside the U.S. can also affect returns. Investments in foreign currencies and foreign issuers are subject to additional risks, including political and economic risks, greater Key Personnel Risk. If one or more key individuals become unavailable, including any of the portfolio managers of an investment strategy, who are 33823_J 11-05-2025 Page 29 of 49  the accounts might benefit from the use of Hedging Instruments, unanticipated changes in interest rates, securities prices or currency exchange rates could result in a poorer overall performance for the accounts than if they had not used such Hedging Instruments. volatility, civil conflicts and war, currency fluctuations, higher transaction costs, delayed settlement, possible foreign controls on investment, expropriation and nationalization risks, and less stringent investor protection and disclosure standards. These risks are magnified in countries in “emerging markets.” Hedging against a decline in the value of a portfolio position does not eliminate fluctuations in the values of portfolio positions or prevent losses if the values of those positions decline, but establishes other positions designed to gain from those same developments, thus offsetting the decline in the portfolio positions’ value. While these transactions can reduce the risks associated with an investment, the transactions themselves entail risks that are different from, and possibly greater than, the risks associated with other portfolio investments. Counterparty Risk. An account may have exposure to the credit risk of counterparties with which it deals in connection with the investment of its assets, whether engaged in exchange traded or off-exchange transactions or through brokers, dealers, custodians and exchanges through which it engages. In addition, many protections afforded to cleared transactions, such as the security afforded by transacting through a clearing house, might not be available in connection with over-the-counter (OTC) transactions. Therefore, in those instances in which an account enters into OTC transactions, the account will be subject to the risk that its direct counterparty will not perform its obligations under the transactions and will sustain losses. This includes where accounts enter into uncollateralized covered agency transactions and derivatives transactions. Cash or Margin Transactions. JPMS is responsible for compliance with federal margin rules. With a cash account, if securities are sold before the payment for their purchase has settled, an event known as a “free-riding” violation has occurred. Freeriding is prohibited under Federal Reserve Board Regulation T and our Program guidelines. Having a “free-riding” violation may result in a client’s account being restricted for 90 days or “frozen.” The imposition of such a freeze could have a negative effect on a client’s account and performance. Under certain circumstances and for certain Program strategies, clients may use margin in respect of a client’s account assets. For such accounts, clients must have executed the relevant margin agreement. Currency Risk. Changes in foreign currency exchange rates will affect the value of certain portfolio securities. Generally, when the value of the U.S. dollar rises in value relative to a foreign currency, an investment impacted by that currency loses value because that currency is worth less in U.S. dollars. Currency exchange rates may fluctuate significantly over short periods of time for a number of reasons, including changes in interest rates. Devaluation of a currency by a country’s government or banking authority also will have a significant impact on the value of any investments denominated in that currency. Currency markets generally are not as regulated as securities markets, may be riskier than other types of investments, and may increase the volatility of a portfolio. As disclosed in a client’s securities account agreement, if clients use margin to purchase securities, the collateral for the margin debit will be the assets in a client’s portfolios and other accounts at JPMS. The costs, risks and other features and conditions of margin and other types of securities-based lending are fully described in the securities account agreement. Disclosure Statement Before opening an account, a client should carefully review the FINRA Margin at finra.org/sites/default/files/InvestorDocument/p005895.pdf. Derivatives Risk. Funds in a client portfolio may use derivatives. Derivatives, including forward currency contracts, futures, options and commodity-linked derivatives and swaps, may be riskier than other types of investments because they may be more sensitive to changes in economic and market conditions, and could result in losses that significantly exceed the investor’s original investment in the derivative. Many derivatives create leverage thereby causing a portfolio to be more volatile than it would have been if it had not been exposed to such derivatives. Derivatives also expose a portfolio to counterparty risk (the risk that the derivative counterparty will not fulfill its contractual obligations), including the credit risk of the derivative counterparty. Certain derivatives are synthetic instruments that attempt to replicate the performance of certain reference assets. With regard to such derivatives, an investor does not have a claim on the reference assets and is subject to enhanced counterparty risk. Derivatives may not perform as expected, so an investor may not realize the intended benefits. The possible lack of a liquid secondary market for derivatives and the resulting ability to sell or otherwise close a derivatives position could expose a portfolio to losses. Additionally, certain derivatives are subject to position limits imposed by regulators, and JPMS will not be able to obtain additional exposure if these limits are reached. When used for hedging, the change in value of a derivative may not correlate as expected with what is being hedged. In addition, given their complexity, derivatives expose an investor to risks of mispricing or improper valuation. investments Options. Clients may invest assets in or trade options on specific securities and indices. Assets may be used to buy or sell (write) both call options and put options. Options may be written on either a “covered” or “uncovered” basis. A covered option is an option position that is fully hedged by a long or short position in the underlying asset. Covered options transactions may be part of a hedging strategy (i.e., offsetting the risk involved in another securities position). Uncovered options are unhedged options positions. Uncovered options transactions are generally a speculative use of leverage whereby a client’s portfolio has the right to benefit from price movements in a large number of securities with a small commitment of capital. Trading uncovered options involves significant risks. Buying uncovered options may result in a total loss of the purchase price if the options expire “out-of-the- money.” The potential loss of uncovered call writing is unlimited. The writer of an uncovered call is in an extremely risky position and may incur large losses if the value of the underlying instrument increases above the exercise price. Investing or trading in uncovered options is therefore appropriate only for the knowledgeable investor who understands the risks, has the financial capacity and willingness to incur potentially substantial losses, and has sufficient liquid assets to meet applicable margin requirements. The risk of writing uncovered put options is substantial and may far exceed the premiums received. The writer of an uncovered put option bears a risk of loss if the value of the underlying instrument declines below the exercise price. The writer of uncovered options must post margin. If the value of the underlying instrument moves against an uncovered writer’s options position, additional margin payments may be required. If the client is unable to meet such margin calls, positions in the account may be liquidated at substantial losses with little or no prior notice and render the client unable to benefit from any rebound in the value of the investments that were liquidated. Clients assume full responsibility for writing uncovered options and selling stock short, including the possibility of incurring unlimited losses, and may discontinue writing options and short selling at any time. Options overlay strategies may be adversely affected by market behavior or unexpected events. Like with any Hedging Risk. Hedging strategies could involve a variety of derivative transactions, including transactions in forward, swap, and option contracts or other financial instruments with similar characteristics, including, without limitation, forward foreign currency exchange contracts, currency and interest rate swaps, options and short sales (collectively, Hedging Instruments). The use of Hedging Instruments could require investment techniques and risk analyses different from those associated with other including securities and currency hedging portfolio transactions. The risks posed by these transactions include, but are not limited to, interest rate risk; market risk; the risk that these complex instruments and techniques will not be successfully evaluated, monitored or priced; the risk that counterparties will default on their obligations; liquidity risk; and leverage risk. Changes in liquidity can result in significant, rapid and unpredictable changes in the prices for derivatives. Thus, while 33823_J 11-05-2025 Page 30 of 49  strategy, no assurances can be given that options overlay strategies will accomplish their objectives. economic or other conditions. Also, MLPs may have limited financial resources, their securities may trade infrequently and in limited volume, and they may be subject to more abrupt or erratic price movements than securities of larger or more broadly-based companies. Additional risks involved with investing in an MLP are risks associated with the specific industry or industries in which the partnership invests, such as the risks of investing in real estate or oil and gas industries. Before investing or trading in options, an investor should read and understand the JPMS Options Account Application and Agreement (including the “Special Statement for Uncovered Option Writers” contained in that Agreement, and a current copy of the “Characteristics and Risks of Standardized Options” Disclosure Document, which are available from your Wealth Advisor or at theocc.com/company-information/documents-and- archives/options-disclosure-document.) Exchange-Traded Funds and Index Mutual Funds. Refer to Item 6.vi for details on ETFs and Index Mutual Funds. Leveraged, Inverse and Other Non-Traditional ETFs and Mutual Funds. Although JPMS does not generally permit the recommendation and/or purchase of leveraged, inverse and volatility Funds for Program accounts, certain Program clients may have already been invested in or may wish to invest in such non-traditional Funds. Like traditional Funds, non-traditional Funds may track broad indices, specific sectors, or be linked to commodities or currencies. Some Funds are both short and leveraged, meaning that they seek to achieve a return that is a multiple of the inverse performance of the underlying index or benchmark. Most non-traditional ETFs “reset” daily, meaning that they are designed to achieve their stated objective on a daily basis. Due to the effects of compounding and “decay,” their performance over longer periods of time can differ significantly from the performance (or inverse of the performance) of the underlying index or benchmark during the same period of time, especially in volatile markets. Concentration of Investments. Clients may concentrate account assets in a region, a small group of countries, or an industry or economic sector. In addition to the potential concentration of accounts in one or more sectors, certain accounts may or may be advised to hold concentrated positions in specific securities. Therefore, at times, an account may or may be advised to hold a relatively small number of securities positions, each representing a relatively large portion of assets in the account. As a result, the value of the account may be subject to greater volatility than a more geographically or sector diversified portfolio. Investments in issuers within a country, state, geographic region, industry or economic sector that experiences adverse economic, business, political conditions or other concerns will impact the value of such a portfolio more than if the portfolio’s investments were not so concentrated. A change in the value of a single investment within the portfolio may affect the overall value of the portfolio and may cause greater losses than it would in a portfolio that holds more diversified investments. If the Portfolio Manager assembles a concentrated position in an account, the client assumes the risk of a substantial loss in value to the entire account if there is a decline in the concentrated position or industry sector. Other risks of holding concentrated positions include substantial loss in an account based upon the loss in value of a single security or industry sector and the impact that a large, concentrated position will have on the manager’s ability to diversify the account. Private Placements. Investments in private placements can entail significant risks and generally are not permitted in the Programs. The securities offered through private placements are not available for sale to the general public and are therefore illiquid. The federal securities laws heavily restrict the resale of private placement securities and a public market may never develop for such securities. Therefore, clients may have difficulty disposing of private placement securities. Because private placement issuers are typically not required to register with the SEC or to publicly report financial information and other important company information, the amount of information available about private placement issuers may be limited. Master Limited Partnerships (MLPs). Certain strategies may invest in MLPs which are limited partnerships that issue publicly traded investment units. The partnership structure of MLPs and other factors give rise to unique tax treatment and investment risks. MLPs could generate taxable income in retirement accounts. The following are some of the risks that clients should consider before investing in MLPs: • Smaller, thinly traded MLPs may be price sensitive in the event of a large position sale or purchase. Short Sales. Clients may sell securities short as a regular part of their investing activities. In a short sale, an individual sells securities it does not own. Clients may sell short in the hope that the market price will decline and that the client will be able to buy replacement securities later at a lower price. To accomplish this, the client borrows the securities from JPMS, and “closes” the position by “returning” the security (buying a replacement security on behalf of the lender) whenever the lender chooses. As collateral for this obligation to “close” its short position, the client is required to leave the proceeds of its short sale with JPMS and deliver an additional amount of cash or other collateral required by margin regulations. Because of the repayment obligation, a short sale theoretically involves the risk of unlimited loss: the price at which the client must buy “replacement” securities could increase without limit. There can be no assurance that the client will not experience losses on short positions and, if such losses occur, that those losses will be offset by gains on any long positions to which they may relate. Short sales also may be effected by causing an account to deliver borrowed securities to settle a sale of securities already in the account (so-called selling “short against the box”). One purpose of selling short “against the box” is to lock in the value of securities owned when selling the securities owned is not permitted. • Equity offerings by an issuer have tended to cause a drop in the price of the issuer’s MLP units. • MLPs may experience negative correlation to rising interest rates. • MLPs typically pay their partners from operating cash flows, and therefore rely on capital markets for access to equity and debt financing in order to fund projects and acquisitions. • Tax deferral and tax liabilities vary by MLP. • A more restrictive tax policy can change the attractiveness and value of MLPs. • Holders of MLP units have limited voting rights on matters affecting the MLP. • Holders of MLP units could be exposed to liability for the obligations of the MLP as a result of certain legal proceedings relating to the rights of unit holders or compliance with state partnership laws. Leverage. Certain PA clients may seek to leverage their investment positions by borrowing funds (e.g., through the use of margin) from JPMS, other broker-dealers, banks or others. Or, certain Wealth Advisors in PM may seek to leverage client investment positions by borrowing funds on the client’s behalf (e.g., through the use of margin) from JPMS, other broker- dealers, banks or others. In PM, the client typically authorizes JPMS to borrow funds on the client’s behalf for the purpose of employing such leverage in the client’s Program account as stated in the Client Agreement or another written instrument. Use of leverage increases both the possibilities for profit and the risk of loss. Borrowings will usually be from JPMS and typically will be secured by the client’s securities and other assets. Under certain circumstances, JPMS (as the lending broker-dealer) may demand an increase in the collateral that secures the client’s obligations (commonly known as a “margin call”) and, if the client is unable to provide additional collateral, JPMS may liquidate assets held in the client’s account to satisfy the client’s obligations. Liquidation in that In addition, investments held by an MLP may be relatively illiquid, limiting the MLP’s ability to vary its portfolio promptly in response to changes in 33823_J 11-05-2025 Page 31 of 49  manner could result in significant losses and render the client unable to benefit from any rebound in the value of the investments that were liquidated. In addition, the amount of the client’s borrowings (if any) and the interest rates on those borrowings, which may fluctuate, will have a significant effect on account performance. Short-Term Trading. Certain Wealth Advisors may or may recommend that Program clients engage in short-term (i.e., active and frequent) trading of securities, leading to increased portfolio turnover, higher transaction costs and the possibility of increased capital gains, including short-term capital gains that are generally taxable as ordinary income. Tax Harvesting (as defined below) will cause your account holdings to differ from those accounts that do not utilize Tax Harvesting; therefore, your account performance will differ. There is no guarantee that Tax Harvesting will perform as expected or that specific benefits will be obtained for any particular client. The implementation of Tax Harvesting may have an adverse effect on investment performance and result in adverse tax consequences including, but not limited to, gains derived from the sale of the security held during the wash sale period. Further, the tax consequences of Tax Harvesting may be challenged by the Internal Revenue Service or any other tax authority. In addition, Tax Harvesting may not achieve the intended reduction in tax liability for non-U.S. and tax-exempt investors. Idle Assets. While Wealth Advisors generally recommend that Program clients keep their account assets invested, at any time and for a substantial length of time, a Wealth Advisor may recommend that the client hold a significant portion of assets in cash, money market mutual funds and other short-term securities. Investments in such assets may cause a client to miss out on upswings in the markets. Unless JPMS expressly agrees otherwise in writing, Program account assets consisting of cash, money market mutual funds and other short-term securities are included in the net market value of the account’s assets for purposes of calculation of the Fee. Neither J.P. Morgan nor its representatives or affiliates offer tax or accounting advice or services, and the client should not solicit or rely upon any such advice from them. J.P. Morgan and its affiliates do not provide tax advice and clients should consult their own tax professional with respect to the impact of Tax Harvesting and federal, state and local tax consequences of investing in any portfolio, including, without limitation, the potential application and impact of Section 1091 of the Internal Revenue Code and the corresponding Treasury regulations (the wash sale rules) with respect to their portfolio and their accounts with or outside of J.P. Morgan. The client agrees that they are responsible for complying with all applicable tax rules, including, but not limited to, the wash sale rules, and clients are responsible for all tax consequences attributable to the disallowance of any losses under the wash sale rules. Further, certain investments may generate unwanted excise taxes, income taxes and penalties under the Internal Revenue Code of 1986, as amended, any or all of which may affect the client’s return on investment and, if applicable, a client’s tax-exempt status. A Wealth Advisor’s implementation of an investment strategy in the PM Program may be constrained by certain investment limitations on the positions in securities including Funds, or other financial instruments, that JPMS or its affiliates will take on behalf of its clients in the aggregate due to, among other things: (i) liquidity concerns; (ii) regulatory requirements applicable to JPMS or its affiliates; and (iii) internal policies related to such concerns or requirements, in light of the management of multiple portfolios and businesses by JPMS and its affiliates. Such policies preclude JPMS or its affiliates from purchasing certain securities for clients and may cause JPMS to sell certain securities held in client accounts. to certain Clients have the ability to select tax-managed or tax-aware strategies (each such strategy, a Tax-Managed strategy), which can include strategies managed by affiliates of JPMS. There are risks and limitations associated with all Tax-Managed strategies, and these limitations may result in tax- inefficient trades and wash sales. Tax management is not tax advice and may not achieve the intended results. Although a tax-aware or Tax- Managed strategy may reduce client’s taxable income, it will not eliminate it. A Tax-Managed strategy may require trade-offs that reduce pre-tax income. Managing a strategy to maximize after-tax returns may also potentially have a negative effect on a strategy’s performance. As a result of tax considerations, the portfolio may dispose of certain securities or fail to acquire certain securities, which could adversely impact pre-tax returns. In addition, the deductibility of losses recognized within the Portfolio may be subject limitations depending on your particular circumstances, such as investments you make outside the portfolio and the aggregate net capital losses you recognize during the year. You should speak with your own tax professional regarding the proper treatment of transactions in the portfolio. To the extent tax consequences are considered in managing a strategy, the strategy’s or fund’s pre-tax performance may be lower than that of a similar strategy that is not tax managed. Special Purpose Acquisition Companies (SPACs). To the extent that investments in SPACs are permitted and/or utilized in certain Programs, clients should be aware that investments in SPACs are speculative and entail significant potential risks. SPACs are companies formed to raise capital in an initial public offering (IPO) with the purpose of using the proceeds to acquire one or more unspecified businesses or assets to be identified after the IPO, typically within 24 months from formation. SPACs typically have no revenue or operating history. The SPAC must use at least 80% of its net assets for any such acquisition, and if it fails to do so, then it must dissolve. SPACs present unique risks, such as the risk that SPAC managers are unqualified or inexperienced and the risk that no acquisition will occur and the SPAC will be liquidated. SPACs do not "pre-identify" possible acquisition targets and the underwriters and do not perform any due diligence on acquisition targets. While some SPACs are specific about the industries or regions in which they will seek an operating company, others are open-ended. If the SPAC dissolves, it returns to investors their pro rata share of the invested assets in escrow. In most of these cases, investors will receive nearly all of their principal invested, but will not share in any of the returns generated from the funds held in escrow as such proceeds are used to cover the operating expenses of the SPAC (therefore tying up client cash unnecessarily and, in turn, possibly missing out on other opportunities). There is also no guarantee with respect to any potential returns on investments in SPACs. Due diligence requirements may also be lower for SPACs than those required by the SEC for ordinary IPOs. Clients should consult the applicable offering documents to become familiar with SPACs and should fully understand the risks associated with SPACs prior to investing. Tax Risks and Risks That Apply to Tax-Aware or Tax-Managed Strategies Tax Harvesting. As part of its investment management services, J.P. Morgan has the ability to sell certain investments at a gain or loss to potentially offset a client’s tax liability (Tax Harvesting) at its discretion. Additionally, for certain strategies on certain platforms, clients can request that J.P. Morgan engage in Tax Harvesting on a client’s behalf. While utilizing Tax Harvesting, client account holdings can differ from those accounts that do not utilize Tax Harvesting, and therefore, a client’s performance will likely differ. J.P. Morgan has limitations on the Tax Harvesting requests that it can accommodate and may or may not accept a client’s request for Tax Harvesting, in whole or in part, at their discretion. Account transactions may give rise to tax liability for which the client is responsible. Funds may make large distributions of income and capital gains to investors at various times in a calendar year, and the client will be liable for taxes on such distributions without regard to the date of the client’s investment in a portfolio. In a Tax-Managed strategy, the manager can engage in Tax Harvesting from positions which have experienced a capital loss. In certain market conditions, or when portfolio positions have not otherwise experienced 33823_J 11-05-2025 Page 32 of 49  capital losses during the relevant tax period, Tax Harvesting opportunities will be limited. legal proceedings, including class actions or bankruptcies, related to securities or other investments held in Program accounts, or the issuers thereof. Clients retain the right and obligation to take such legal action relating to the securities held in their accounts. PM Clients may elect to vote proxies for the securities and other property in their account(s), or clients may delegate proxy voting authority to JPMS. As stated in the Client Agreement, the proxy voting authority that clients delegate to JPMS also authorizes JPMS to further delegate these proxy voting rights to, or otherwise use services provided by, a third-party proxy voting or advisory service, subject to JPMS’ oversight. The manager of a Tax-Managed strategy may change the strategy’s parameters, including the manner and frequency of Tax Harvesting, at any time without notice. Generally, such strategy entails a repurchase of the sold security or vehicle after the “wash sale” (i.e., 30-day) period. Generally, under the wash sale rules, if a client sells a security for a loss and the client repurchases the same (or a substantially identical) security either 30 days before or 30 days after the date of the sale, the loss is disallowed. However, the wash sale rules apply to transactions in not only that account but also to transactions in all other accounts held by the client, the client’s spouse and certain entities controlled by them (related parties), whether these accounts are held with JPMS or its affiliates for other financial institutions. Tax-Managed strategies will not necessarily consider trading activity in all of these other securities accounts, and it is the client’s responsibility to comply with the wash sale rules with respect to such accounts. Additionally, Tax-Managed strategies are not customized to a client’s specific tax circumstances; incorrect assumptions about tax attributes and transactions outside of the strategy may lead to inefficient tax management. Assets will generally be invested in Funds during the wash sale period. Funds are investment companies and have certain embedded costs, including portfolio management fees, of which the client will bear a proportionate share while invested in the Fund. Such costs are in addition to other advisory or management fees charged to the client. The client is responsible for understanding the merits and consequences of Tax Harvesting. When a Program client has delegated proxy voting authority to JPMS, a potential conflict of interest arises because JPMS’ and the client’s interests with respect to the subject matter of the proxy may conflict or otherwise differ. This conflict is addressed in part by Rule 206(4)–6 under the Investment Advisers Act of 1940, as amended (the Advisers Act), which requires JPMS to adopt and implement written procedures designed to ensure that it votes client securities in the best interests of clients and the general fiduciary responsibilities associated with acting in the capacity of investment adviser. Therefore, to minimize conflicts of interest, JPMS has engaged as its delegate Institutional Shareholder Services Inc. (ISS), an independent service provider, for purposes of voting proxies for any securities and other property in Program client accounts for which JPMS has been granted proxy voting authority, in accordance with ISS’ proxy voting guidelines in effect from time to time, copies of which are available on request. All such activities of ISS are subject to the oversight and supervision of JPMS, and to JPMS’ proxy voting policies and procedures applicable to accounts in the Program, a copy of which of is available to Program clients upon request. Information relating to ISS and its services is available on the ISS website at issgovernance.com and the ISS Form ADV Part 2A Brochure is available on the SEC’s website at adviserinfo.sec.gov. JPMS relies upon ISS to maintain proxy voting records and has obtained an undertaking from ISS to provide copies of such records promptly upon JPMS’ request. Therefore, a client who wishes to obtain the proxy voting records with respect to the securities held in their PM accounts should contact their Wealth Advisor(s). JPMS can, in its discretion, change the proxy voting service provider at any time. JPMS will not be deemed to have or exercise proxy voting responsibility by virtue of any authority to hire or change the proxy voting service provider. REITs Risk. The value of real estate securities in general, and REITs in particular, are subject to similar risks as direct investments in real estate and mortgages, and their value will be influenced by many factors including the value of the underlying properties or the underlying loans or interests. The underlying loans may be subject to the risks of default or of prepayments that occur later or earlier than expected and such loans may also include so-called "subprime" mortgages. The value of these securities will rise and fall in response to many factors, including economic conditions, the demand for rental property, interest rates and, with respect to REITs, the management skill and creditworthiness of the issuer. In particular, the value of these securities may decline when interest rates rise and will also be affected by the real estate market and by the management of the underlying properties. There is no public trading market for private or public non-traded REITs; therefore, such REITs may be more volatile and/or more illiquid than publicly traded REITs and other types of equity securities. vii. Performance-Based Fees and Side by Side Management Pursuant to the terms of the Client Agreement, in delegating proxy voting authority to JPMS, who in turn delegates such authority to ISS, clients are also authorizing JPMS to provide to ISS all proxy-related materials it receives for securities in the client’s Program account(s). Accordingly, clients who delegate proxy voting authority to JPMS will generally not receive proxy materials or annual reports relating to securities and other property that clients hold in their applicable PM accounts. JPMS does not charge performance-based fees in connection with Program accounts. However, certain Funds available in the Programs may be subject to performance-based fees or varying Fund expense charges imposed by the Fund manager or adviser (or another party). viii. Voting Client Securities PA The delegation of proxy voting authority to JPMS and from JPMS to ISS applies only to proxies that ISS generally votes and does not apply to proxies which ISS declines to vote (which will not be voted). With respect to such proxies, in limited circumstances, such as when ISS does not cover the issuer of a particular security or securities or otherwise does not recommend a vote, no action will be taken with respect to the voting of any such proxies. In such circumstances, it is also important to note that JPMS will not vote or take any action with respect to the proxy on behalf of the affected Program clients. If the client has delegated proxy voting authority to JPMS, either JPMS or the client may subsequently terminate the authorization at any time by written notice to the other party. Once a client revokes their delegation, the client will receive all proxy materials and annual reports related to securities and other property in the client’s account(s) and will be responsible for voting proxies directly, or instructing any third-party custodian that holds such securities and other property, as applicable. JPMS does not have, and will not accept, authority to vote client securities held in Program accounts. In accordance with applicable law, JPMS will forward to the client all proxy-related materials, annual reports and other issuer-related materials that they receive pertaining to securities held in the client’s Program account. In cases where the client has chosen to use a custodian other than JPMS, the client may receive proxies and other solicitations from that custodian. The client may contact their Wealth Advisor with questions about a particular proxy solicitation but JPMS is expressly precluded from taking any action or rendering any advice to any client in PA with respect to the voting of proxies solicited by, or with respect to, the issuers of any securities held in the client’s Program account. JPMS is not responsible for initiating any legal action or rendering any advice to or taking any action on behalf of clients in the Program with respect to any 33823_J 11-05-2025 Page 33 of 49  CBP, UMA and ICS, as well as certain Strategies in the STRATIS Program with a Portfolio Manager providing discretionary investment management in separately managed accounts corporate actions with respect to securities in a client’s account. Corporate actions for a client’s account can include any conversion option; execution of waivers; consents and other instruments; and consents to any plan of reorganization, merger, combination, consolidation, liquidation or similar plan. Except to the extent the client specifically reserves the right to vote proxies in writing in accordance with applicable law, the client (i) authorizes the selected Portfolio Manager(s) to receive the proxy-related materials, annual reports and other issuer-related materials for securities in client account(s); and (ii) delegates to the Portfolio Manager the proxy voting rights for those securities (and, thereby, authorizes the Portfolio Manager(s) to further delegate these proxy voting rights to, or otherwise use services provided by, a third-party proxy voting or advisory service), in accordance with proxy voting policies and procedures that each such Portfolio Manager may, from time to time, establish. The client may revoke this delegation of proxy voting authority at any time by notice to JPMS. In accordance with applicable law, JPMS will forward to the Portfolio Manager(s) any proxy-related materials, annual reports and other issuer- related materials received by JPMS that pertain to securities held in the account. JPMCAP and certain Strategies in the STRATIS Program for which JPMS acts as implementation manager implementing a Model Portfolio Each client has the right and responsibility to take any actions with respect to any legal proceedings, including, without limitation, bankruptcies and shareholder litigation, and the right to initiate or pursue any legal proceedings, including without limitation, shareholder litigation, including with respect to transactions, securities or other investments held in the client’s account or the issuers thereof. Neither JPMS nor the Portfolio Manager is obligated to render any advice or take any action on a client’s behalf with respect to securities or other property held in the client’s account, or the issuers thereof, which become the subject of any legal proceedings, including, without limitation, bankruptcies and shareholder litigation, to which any securities or other investments held or previously held in the account, or the issuers thereof, become subject. In addition, neither JPMS nor the Portfolio Manager is obligated to initiate or pursue any legal proceedings, including, without limitation, shareholder litigation, on behalf of a client’s account, including, with respect to transactions, securities or other investments held or previously held in the client’s account, or the issuers thereof. and Issuer-Related Material Delivery ix. Prospectus for Discretionary Accounts (PM, JPMCAP, J.P. Morgan Multi- Manager Strategies in STRATIS, UMA - Wealth Advisor Discretion) JPMS and JPMPI will not vote proxies (or give advice about how to vote proxies) relating to securities and other property currently or formerly held in a client’s account. JPMS and its affiliates will not be responsible or liable for: (1) failing to notify a client of proxies; or (2) failing to send to the Proxy Service (defined below) or a client, as applicable, proxy materials or annual reports where JPMS or its affiliates have not received proxies or related shareholder communications on a timely basis or at all. liabilities with respect to such A discretionary investment adviser can receive prospectuses and other issuer-related materials on behalf of a client for any mutual funds and ETFs in a client’s account with client authorization. JPMS or JPMPI, as a client’s agent, will have access to the prospectuses and issuer-related materials and can rely upon them to make mutual fund and ETF investments on the client’s behalf; however, clients will no longer receive such prospectuses or issuer-related materials directly but can access them via the issuer’s website or request copies from the adviser at any time. Prospectuses and issuer-related materials contain important information and detailed descriptions of additional fees and expenses, investment minimums, risk factors and conflicts of interest disclosures, as well as client’s rights, responsibilities and investments. Additionally, this Brochure contains other general information regarding fees and expenses, risk factors and conflicts of interest. ITEM 7 — CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Each client has the right to vote, and is responsible for voting, proxies for any securities and other property in the client’s account. Clients can appoint an independent services provider designated by JPMS for purposes of voting proxies (Proxy Service) as the client’s agent and attorney-in-fact, and clients can authorize the Proxy Service, in its discretion, to vote proxies for any securities and other property in the client’s account in accordance with the Proxy Service’s proxy voting guidelines in effect from time to time (or other guidelines that the Proxy Service has been instructed to use for particular investment strategies), copies of which are available on request. The Proxy Service is currently ISS. Information relating to ISS’ services is available on the ISS website at issgovernance.com. The ISS advisory brochure is available at the SEC’s website at adviserinfo.sec.gov. The Proxy Service’s role as the agent of clients applies only to proxies that the Proxy Service generally votes and does not apply to proxies with respect to which the Proxy Service declines to vote. A client who appoints the Proxy Service will not receive proxy materials or annual reports relating to securities and other property for which the Proxy Service has accepted responsibility for voting related proxies. In limited circumstances, the Proxy Service will not vote proxies. A client can revoke its appointment of the Proxy Service upon written notice to JPMS at J.P. Morgan Securities LLC, Attn: Proxy Voting Opt Out, Mail Code: IL1-0291, PO Box 1762, Chicago, IL 60690. If a client revokes their appointment of the Proxy Service, the client will receive all proxy materials and annual reports related to securities and other property in the client’s account, and they will be responsible for voting such proxies directly or instructing any custodian that holds such securities and other property. JPMS can, in its discretion, change the Proxy Service. JPMS will not be deemed to have or exercise proxy voting responsibility or authority by virtue of any authority to hire or change the Proxy Service. Corporate Actions To open an account in any of the Programs, clients must provide JPMS with certain information about a client’s financial circumstances, investment objective, risk tolerance and any other relevant information relating to the account. A change in the information provided to JPMS or other circumstances can warrant a change to the client’s investment objective, risk tolerance or other information. In PM, a client’s Wealth Advisor acts as Portfolio Manager and will receive and have access to the information clients provide to enroll and maintain an account in the Program. For the other Programs that involve affiliated and unaffiliated third-party Portfolio Managers, JPMS will generally provide the Portfolio Manager(s) with the information that clients provide during the account opening process (and otherwise) and any changes to such information. However, for ICS, JPMS is not obliged to provide information about clients to the clients’ Portfolio Managers; rather, clients are solely responsible for providing their Portfolio Managers with such information, including any client-specified investment guidelines and/or restrictions. For UMA, JPMS and the UMA Overlay Manager do not provide the Model Portfolio Providers or the securities or their issuers and investment managers with any client information. For clients in PM, the Wealth Advisor may, in its discretion (but is not required), act on voluntary corporate actions with respect to securities in the client’s account. For clients in CBP, STRATIS and ICS, the Portfolio Manager shall take appropriate action with respect to corporate actions in the client’s Account. For clients utilizing UMA, the Overlay Manager or Joint Discretion Manager shall take appropriate action with respect to corporate actions for securities in the portion of the client’s account allocated to such manager. For clients in JPMCAP, JPMPI will receive and respond to To manage and/or provide services to each client’s account(s), JPMS (and the Wealth Advisors) and the Portfolio Managers rely on the accuracy and completeness of the information clients provide for that purpose. Accordingly, to ensure that a Program and the selected investments/ investment strategy remain suitable for a client, clients are responsible for 33823_J 11-05-2025 Page 34 of 49  promptly notifying JPMS of any changes to the information previously provided to JPMS and/or their financial situation or circumstances and for providing JPMS with additional information as requested. At least once annually, JPMS contacts clients in the Programs and notifies, at least quarterly, to determine whether there have been any changes in the client’s financial situation, investment objective(s), investment restrictions or other information for the account that may require a change to the account or the management of the accounts. JPMS will have no liability for any client’s failure to provide JPMS with accurate or complete information or to inform JPMS promptly of any change in the information a client previously provided. ITEM 8 — CLIENT CONTACT WITH PORTFOLIO MANAGERS Concurrently, on December 18, 2015, JPMCB reached a settlement agreement with the Commodity Futures Trading Commission (CFTC) to resolve its investigation of JPMCB’s disclosure of certain conflicts of interest to discretionary account clients of J.P. Morgan Private Bank’s U.S.-based wealth management business. In connection with the settlement, the CFTC issued an order (CFTC Order) finding that JPMCB violated Section 4o(1)(B) of the Commodity Exchange Act (CEA) and Regulation 4.41(a)(2) by failing to fully disclose to certain clients its preferences for investing certain discretionary portfolio assets in certain commodity pools or exempt pools, namely (a) investment funds operated by J.P. Morgan Asset Management and (b) third-party managed hedge funds that shared management and/or performance fees with an affiliate of JPMCB. The CFTC Order directs JPMCB to cease- and-desist from violating Section 4o(1)(B) of the CEA and Regulation 4.41(a)(2). Additionally, JPMCB shall pay $40 million as a civil penalty to the CFTC and disgorgement of $60 million satisfied by disgorgement to be paid to the SEC by JPMCB and an affiliate in a related and concurrent settlement with the SEC. For a copy of the Order, go to sec.gov/litigation/admin/2015/33-9992.pdf. For those Programs that involve third-party unaffiliated and affiliated Portfolio Managers, JPMS places no restrictions on clients contacting and consulting directly with the Portfolio Managers. However, unlike the Portfolio Managers selected by the client, the Model Portfolio Providers do not have investment advisory relationships directly with clients and may themselves restrict such contact and consultation. Clients should review the Form ADV Part 2A brochure(s) or other similar disclosure documents of applicable Portfolio Manager(s) for any restrictions placed by the Portfolio Manager(s). With respect to PM, the Wealth Advisors responsible for managing client accounts in the Program may be freely contacted by, and are reasonably available for consultation with, clients during normal business hours. ITEM 9 — ADDITIONAL INFORMATION i. Disciplinary Information JPMS has been involved in the following material legal or disciplinary events during the last ten years. 2) On or about July 28, 2016, JPMS and JPMCB entered into a Consent Agreement (Agreement) with the 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 Chase Strategic Portfolio (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. 3) In October 2018, JPMS submitted an 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) reasonably 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 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 1) On December 18, 2015, JPMS and JPMCB (together, Respondents) entered into a settlement with the SEC resulting in the SEC issuing an order (Order). The Respondents consented to the entry of the order that finds that JPMS violated Sections 206(2), 206(4) and 207 of the Advisers Act and Rule 206(4)-7, and JPMCB violated Sections 17(a)(2) and 17(a)(3) of the Securities Act of 1933. The Order finds that JPMCB negligently failed to adequately disclose (a) from February 2011 to January 2014, a preference for affiliated mutual funds in certain discretionary investment portfolios (the Discretionary Portfolios) managed by JPMCB and offered through J.P. Morgan’s U.S. Private Bank (the U.S. Private Bank) and the Chase Private Client lines of business; (b) from 2008 to 2014, a preference for affiliated hedge funds in certain of those portfolios offered through the U.S. Private Bank; and (c) from 2008 to August 2015, a preference for retrocession-paying third-party hedge funds in certain of those portfolios offered through the U.S. Private Bank. With respect to JPMS, the Order finds that, from May 2008 to 2013, JPMS negligently failed to adequately disclose, including in documents filed with the SEC, conflicts of interest associated with its use of affiliated mutual funds in the Chase Strategic Portfolio (CSP) program, specifically, a preference for affiliated mutual funds, the relationship between the discounted pricing of certain services provided by an affiliate and the amount of CSP assets invested in affiliated products, and that certain affiliated mutual funds offered a lower-cost share class than the share class purchased for CSP. In addition, the Order finds that JPMS failed to implement written policies and procedures adequate to ensure disclosure of these conflicts of interest. Solely for the purpose of settling these proceedings, the Respondents consented to the Order, admitted to the certain facts set forth in the Order, and acknowledged that certain conduct set forth in the Order violated the federal securities laws. The Order censures JPMS and directs the Respondents to cease-and-desist from committing or causing any violations and any future violations of the above-enumerated statutory provisions. Additionally, the Order requires the Respondents to pay a total of $266,815,000 in disgorgement, interest and civil penalty. 33823_J 11-05-2025 Page 35 of 49  and evaluate the performance of the vendor that handled certain functions on behalf of the Firm. 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. 4) 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 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. 7) 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. 5) 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 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 J.P. Morgan Funds; (ii) there was an economic incentive to invest CSP assets in J.P. Morgan 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 J.P. Morgan Fund share classes. Solely for the purpose of settling these proceedings, JPMS consented to the March 2020 Order, with no admissions as to liability. JPMS agreed to pay a total of $325,000 to resolve the KDFI investigation. 6) 8) 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. ii. Other Financial Industry Activities and Affiliations a. Broker-Dealer Registrations JPMS is registered with the SEC as a broker-dealer and investment adviser. Some of JPMS’ management personnel and all of the Wealth Advisors in the Programs and their supervisors are registered with FINRA as registered representatives of JPMS in its capacity as a broker-dealer. 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 33823_J 11-05-2025 Page 36 of 49  b. Futures/Commodities-Related Registrations into, affiliated Funds rather than unaffiliated Funds. Moreover, because Wealth Advisors and Portfolio Managers are typically compensated on the basis of the net market value of Program accounts, they are to that extent incentivized to recommend or select Funds they believe will increase the value of an account, regardless of whether the Funds are affiliated or unaffiliated with JPMS; and 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 Wealth Advisors and/or their supervisors, are registered with the CFTC as associated persons of JPMS in its capacity as a futures commission merchant. c. Material Relationships with Related Persons • When retirement plan accounts can invest in strategies that include affiliated Funds, the actual amount of the J.P. Morgan Funds’ underlying fees paid to J.P. Morgan and associated with the client’s Program account assets will be credited to the relevant client account. In addition, the only “sweep” vehicle other than the Deposit Account (discussed in Item 4.ii) that is available to retirement plan accounts in the Programs is an unaffiliated money market mutual fund from which JPMS and its affiliates receive no additional compensation. For more information about such fees and expenses, clients should review the applicable prospectuses for Funds in their Program accounts. JPMS has several relationships or arrangements with related persons that are material to its investment advisory business or to clients in the Programs. Below is a description of such relationships and some of the conflicts of interest that arise from them. JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest that may arise between JPMS and its affiliates. These policies and procedures include information barriers designed to prevent the flow of information between JPMS and certain other affiliates, as more fully described below. JPMorgan Chase & Co. and Other Affiliated Issuers of Securities 2. The use of affiliates to provide services to clients creates certain conflicts of interest for JPMS, JPMIM and JPMPI. Among other things, there are financial incentives for JPMS, JPMIM and JPMPI (and their affiliates), including their parent company, JPMC, to favor affiliated service providers over non-affiliated service providers, and compensation of supervised persons of JPMS, JPMIM and JPMPI generally is directly or indirectly related to the financial performance of J.P. Morgan. 1. Affiliated Portfolio Managers, Model Portfolio Providers, Sponsors, Distributors and Advisers of Funds In addition to the Funds sponsored and managed by affiliates of JPMS, other affiliates of JPMS also may issue securities through public or private distributions. JPMS’ ultimate parent company, JPMC, is a publicly traded corporation the common stock of which is listed and trades on the NYSE. It is also a bank holding company registered with the Board of Governors of the Federal Reserve System (the Federal Reserve), subject to the supervision and regulations of the Federal Reserve, as well as certain restrictions imposed by the Bank Holding Company Act and other related regulations. Refer to Item 6.iii for a discussion of the conflicts of interest raised by the inclusion of affiliated Portfolio Managers, Model Portfolio Providers and Funds in the Programs, as applicable, and how that conflict is addressed. Portfolio Managers or JPMS can invest or recommend clients invest Program account assets in J.P. Morgan Funds rather than unaffiliated Funds, and in certain account types and Programs, JPMS can designate affiliated Funds as default replacements for strategies or securities removed from the Program. In addition, affiliated Funds can be selected as the vehicle for the temporary investment (i.e., sweeping) of available cash balances. Funds, including money market funds, pay fees and expenses, ultimately borne by clients. The sponsors and/or general partners of certain Funds are affiliated with JPMS (potentially including those in which JPMS or its affiliates have a minority and/or non-controlling interest), and JPMS and its affiliates may provide investment management and other services to, and receive compensation from or in connection with such Funds, including the receipt of an investment management fee. Refer to Item 9.iii for more information. The affiliates of JPMS that provide such investment management services to Funds in which Program accounts assets may be invested include JPMIM and JPMPI. its affiliates will JPMS, its affiliates and other related persons, could have an interest in JPMS’ investment advisory clients buying (or not selling) securities that JPMC and other affiliates of JPMS (including entities in which JPMS or its affiliates have a minority and/or non-controlling interest) have issued. For example, JPMS, its affiliates and other related persons (including Wealth Advisors in the Programs who personally own or may own shares of JPMC common stock, through the issuance of shares and/or stock options to them as part of their employment compensation or otherwise) could benefit in certain respects from an increase in the securities’ market price resulting from increased demand for the securities. These financial interests conflict with the interest of Program clients in buying and holding securities issued by affiliates of JPMS based solely on the furtherance of the clients’ investment objectives in a Program. JPMS addresses this conflict through disclosure and in the ways described in 9.ii.c.1 above. In addition, for those Programs in which the Wealth Advisors have investment discretion over or recommend the specific securities transactions that are effected for Program accounts, JPMS’ policy prohibits Wealth Advisors from effecting or soliciting purchases of equity and fixed income securities issued by JPMS’ affiliates (including JPMC common stock) in Program accounts. As a result of this policy described above, Wealth Advisors will typically be unable to recommend or effect purchases of equity and fixed income securities issued by an affiliate of JPMS in Program accounts even when based solely on the furtherance of the client’s investment objective for the account. Accordingly, this policy could have a negative impact on the performance of Program accounts. in the aggregate receive more Since JPMS and compensation when Program accounts are invested in affiliated Funds than they would receive if the Program accounts were invested in unaffiliated Funds, JPMS has a conflict of interest. JPMS addresses these conflicts in the following ways: • For Programs with a discretionary third-party Portfolio Manager, except for JPMIM and JPMPI with respect to the Program accounts they manage, neither JPMS nor any of its other affiliates controls or recommends specific securities transactions for Program accounts; • Affiliated Funds are generally subject to the same selection and review criteria as other Funds; For PA and PM, if, notwithstanding JPMS’ policy, an equity or fixed income security issued by an affiliate of JPMS came to be held in a Program account (because, for example, a client transfers the security into a Program account from a non-Program account, the security was purchased in the account before it became a Program account, or the client purchased the security in the Program account on an unsolicited basis) for the first time prior to October 1, 2009, JPMS consented to the security being held in the Program account and typically treats the security as an ineligible security (however, fees can still be applied). In such cases, JPMS’ treatment of the security is communicated to the Program client. • Wealth Advisors responsible for providing investment advice to clients do not receive any direct financial benefit from the investment of Program assets in, or the “sweeping” of available cash balances 33823_J 11-05-2025 Page 37 of 49  JPMorgan Chase Bank, N.A. (JPMCB) 3. JPMCB is a national banking association affiliated with JPMS and is subject to supervision and regulation by the U.S. Department of Treasury’s Office of the Comptroller of the Currency. JPMCB provides investment management, trustee, custody and other services to institutional and non- institutional clients. Refer to Item 4 for additional conflicts of interest and other information relating to the sweep Deposit Account. in certain circumstances, J.P. Morgan persons All (or substantially all) Wealth Advisors are employees of JPMCB. In their capacities as employees of JPMCB and outside of the Programs, Wealth Advisors may market and sell products and services of JPMCB to clients and be compensated in connection with such sales. Wealth Advisors may act as a representative of a J.P. Morgan investment adviser, Registered Representative and/or bank employee at the same time depending on, for example, the types of accounts a client holds. The fact that they do so does not mean that our brokerage or banking relationships are advisory ones or that our fiduciary duty as an investment adviser extends to brokerage accounts or to products or services facilitated or offered by JPMCB. Wealth Advisors may also receive compensation in connection with JPMCB bank deposit products held outside of the Programs, such as checking accounts, savings accounts and bank certificates of deposits (CDs), which is typically based on a fixed percentage of the balance of the bank deposit product. Depending on the rate of the Program Fee, a Wealth Adviser’s compensation from JPMCB bank deposit products may be more or less than the compensation the Wealth Advisor would receive from an equivalent balance in a Program account. The amount of compensation paid to a Wealth Advisor on JPMCB bank products will typically be more than the amount of compensation paid to a Wealth Advisor on an equivalent balance in a deposit sweep, J.P. Morgan Premium Deposit or money market fund held in a brokerage account. 4. Revenue Sharing Arrangements with Affiliates the global currency, equity, commodity, fixed income and other markets in which Program client accounts can directly or indirectly invest. J.P. Morgan is typically entitled to compensation in connection with these activities and the Program’s clients will not be entitled to any such compensation. In providing services and products to clients other than JPMS’ clients, J.P. Morgan from time to time faces conflicts of interest with respect to activities recommended to or performed for JPMS’ clients on one hand and for J.P. Morgan’s other clients on the other hand. For example, J.P. Morgan has, and continues to seek to develop, banking and other financial and advisory relationships with numerous U.S. and non-U.S. persons and governments. J.P. Morgan also advises and represents potential buyers and sellers of businesses worldwide. Client accounts have invested in, or may wish to invest in, such entities represented by J.P. Morgan or with which J.P. Morgan has a banking, advisory or other financial relationship. issue Furthermore, recommendations on securities held in accounts advised or sub-advised by JPMS that are contrary to the investment activities of JPMS. In addition, certain clients of J.P. Morgan may invest in entities in which J.P. Morgan holds an interest, including a collective investment trust, or other pooled investment vehicle managed by a J.P. Morgan affiliate. In providing services to its clients and as a participant in global markets, J.P. Morgan from time to time recommends or engages in activities that compete with or otherwise adversely affect a program client account or its investments. It should be recognized that such relationships can preclude Program clients from engaging in certain transactions and can also restrict investment opportunities that would otherwise be available to Program clients. For example, J.P. Morgan is often engaged by companies as a financial adviser, or to provide financing or other services, in connection with commercial transactions that are indirectly potential investment opportunities for Program clients. There are circumstances in which advisory accounts are precluded from participating in such transactions as a result of J.P. Morgan’s engagement by such companies. J.P. Morgan reserves the right to act for these companies in such circumstances, notwithstanding the potential adverse effect on Program clients. In addition, J.P. Morgan derives ancillary benefits from providing investment advisory, custody, administration and other services to Program clients, and providing such services to program clients may enhance J.P. Morgan’s relationships with various parties, facilitate additional business development, and enable J.P. Morgan to obtain additional business and generate additional revenue. In addition, 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 Wealth Advisors in the Programs) to the affiliates for the provision by the affiliates of products and services to the investors. The investors referred to affiliates may be existing investment advisory clients of JPMS. When JPMS makes 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: • 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; The following are descriptions of certain additional conflicts of interest and potential conflicts of interest that are associated with the financial or other interests that JPMS and J.P. Morgan have in transactions effected by, with or on behalf of its clients. In addition to the specific mitigants described further below, JPMS has adopted policies and procedures reasonably designed to appropriately prevent, limit or mitigate conflicts of interest. In addition, many of the activities that create these conflicts of interest that are limited and/or prohibited by law and are conducted under an available exception. • 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; and J.P. Morgan or JPMS’ related persons may provide financial, consulting, investment banking, advisory, brokerage (including prime brokerage) and other services to, and receive customary compensation from, an issuer of equity or debt securities held by client accounts. Any fees or other compensation received by J.P. Morgan in connection with such activities will not be shared with clients or used to offset fees charged to clients. Such compensation could include financial advisory fees, monitoring fees, adviser fees or fees in connection with restructuring or mergers and acquisitions, as well as underwriting or placement fees, financing or commitment fees, trustee fees and brokerage fees. • 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. J.P. Morgan Acting in Multiple Capacities 5. Additionally, from time to time, directors, officers and employees of JPMC serve on the board of directors or hold another senior position with a corporation, investment fund manager or other institution which may desire to sell an investment to, acquire an investment from or otherwise engage in a transaction with, clients. The presence of such persons in such circumstances may require the relevant person to recuse themselves from participating in a transaction or cause JPMS, a corporation, investment J.P. Morgan is a diversified financial services firm that provides a broad range of services and products to its clients and is a major participant in 33823_J 11-05-2025 Page 38 of 49  fund manager or other institution to determine that it (or its client) is unable to pursue a transaction because of a potential conflict of interest. In such cases, the investment opportunities available to clients and the ability of such clients to engage in transactions or retain certain investments or assets will be limited. 6. J.P. Morgan’s Policies and Regulatory Restrictions Affecting Client Accounts same or a related activity or transaction to that being considered on behalf of the client account; (iii) when J.P. Morgan or a client account has an interest in an entity involved in such activity or transaction; or (iv) when such activity or transaction on behalf of or in respect of the client account could affect J.P. Morgan, JPMS, their clients or their activities. J.P. Morgan may also become subject to additional restrictions on its business activities that could have an impact on Program client accounts’ activities. In addition, JPMS may restrict its investment decisions and activities on behalf of particular client accounts and not other accounts. 7. Conflicts of Interest Related to Ownership Interest in J.P. Morgan Stock As part of a global financial services firm, JPMS will be precluded from effecting or recommending transactions in certain client accounts and will restrict its investment decisions and activities on behalf of its clients due to applicable law, regulatory requirements, other conflicts of interest, information held by JPMS or J.P. Morgan, JPMPI’s and/or J.P. Morgan’s roles in connection with other clients and in the capital markets, J.P. Morgan’s internal policies, and/or potential reputational risk. As a result, client accounts managed by JPMS may be precluded from acquiring, or disposing of, certain securities or instruments at any time. This includes the securities issued by J.P. Morgan. Certain unaffiliated asset management firms (each, an unaffiliated asset manager) through their funds and separately managed accounts currently hold a 5% or more ownership interest in J.P. Morgan publicly traded stock. Ownership interests in this range or of greater amounts present a conflict of interest when J.P. Morgan purchases publicly traded securities of the unaffiliated asset manager or invests in funds that are advised by such unaffiliated asset manager on behalf of client accounts or J.P. Morgan Funds. J.P. Morgan does not receive any additional compensation for client accounts’ or J.P. Morgan Funds' investments in publicly traded securities or funds of an unaffiliated asset manager as a result of its ownership interest in JPMC stock. 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 February 26, 2025, the Vanguard Group, Inc. and BlackRock, Inc. hold more than a 5% interest in J.P. Morgan. J.P. Morgan’s Use of Index Products 8. In addition, potential conflicts of interest also exist when J.P. Morgan maintains certain overall investment limitations on positions in securities or other financial instruments due to, among other things, investment restrictions imposed upon J.P. Morgan by law, regulation, contract or internal policies. These limitations have precluded and, in the future could preclude, JPMS from including particular securities or financial instruments in its portfolios, even if the securities or financial instruments would otherwise meet the investment objectives of such portfolio. For example, there are limits on the aggregate amount of investments by affiliated investors in certain types of securities within a particular industry group that cannot be exceeded without additional regulatory or corporate consent. If such aggregate ownership thresholds are reached, the ability of a client to purchase or dispose of investments, or exercise rights or undertake business transactions, will be restricted. Potential conflicts of interest may also arise as a result of JPMS’ current policy to seek to manage its clients’ accounts so that the various requirements and liabilities imposed pursuant to Section 16 of the Securities Exchange Act of 1934 (Section 16 and the Exchange Act, respectively) are not triggered. Section 16 applies to, among other things, “beneficial owners” of 10% or more of any security subject to reporting under the Exchange Act. In addition to certain reporting requirements, Section 16 also imposes on such “beneficial owner” a requirement to disgorge of “short-swing” profits derived from the purchase and sale or sale and purchase of the security, executed within a 6-month period. JPMS may be deemed to be a “beneficial owner” of securities held by its advisory clients. Consequently, and given the potential ownership level of the various accounts and funds managed by JPMS for its clients, JPMS may limit the amount, or alter the timing, of purchases of securities, in order not to trigger the foregoing requirements. As a result, certain contemplated transactions that otherwise would be consummated by JPMS on behalf of its clients will not take place, will be limited in their size, or will be delayed. JPMS or one of its affiliates develop or own and operate stock market and other indexes based on investment and trading strategies developed by JPMS or its affiliates or assist unaffiliated entities in creating indexes that are tracked by certain ETFs utilized by JPMS or an affiliate. Some of the ETFs for which an affiliate of JPMS acts as investment adviser (the JPM ETFs) seek to track the performance of these indexes. JPMS and its affiliates from time to time manage client accounts that invest in these JPM ETFs. In addition, JPMS and its affiliates manage client accounts which track the same indexes used by the JPM ETFs or which are based on the same, or substantially similar, strategies that are used in the operation of the indexes and the JPM ETFs. The operation of the indexes, the JPM ETFs and the client accounts in this manner gives rise to potential conflicts of interest. For example, client accounts that track the same indexes used by the JPM ETFs may engage in purchases and sales of securities relating to index changes prior to the implementation of index updates or the time as of which the JPM ETFs engage in similar transactions because the client accounts may be managed and rebalanced on an ongoing basis, whereas the JPM ETFs’ portfolios are only rebalanced on a periodic basis corresponding with the rebalancing of an index. These differences can result in the client accounts having more favorable performance relative to that of the index and the JPM ETFs or other client accounts that track the index. Other 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 JPM ETFs. JPMS and its affiliates have established certain information barriers and other policies to address the sharing of information between different businesses within JPMS and its affiliates, including with respect to personnel responsible for maintaining the indexes and those involved in decision-making for the JPM ETFs. 9. Other Compensation from ETFs Furthermore, JPMS has adopted policies and procedures reasonably designed to ensure compliance with economic and trade sanctions-related obligations applicable to its activities (although such obligations are not necessarily the same obligations that its clients are subject to). Such economic and trade sanctions prohibit, among other things, transactions with and the provision of services to, directly or indirectly, certain countries, territories, entities and individuals. These economic and trade sanctions, and the application by JPMS of its compliance policies and procedures in respect thereof, may restrict or limit a client’s account’s investment activities. In addition, J.P. Morgan from time to time subscribes to or otherwise elects to become subject to investment policies on a firm- wide basis, including policies relating to environmental, social and corporate governance. JPMS may also limit transactions and activities for reputational or other reasons, including (i) when J.P. Morgan provides or may provide advice or services to an entity involved in such activity or transaction; (ii) when J.P. Morgan or a client is or may be engaged in the Certain ETFs in which account assets are invested in execute transactions for their portfolios through JPMS or an affiliate as broker-dealer, and JPMS or an affiliate receives traditional brokerage compensation and fees from the ETFs in connection with these transactions. Such compensation presents a conflict of interest between JPMS and clients because JPMS has a financial incentive to invest Program account assets in such ETFs: (1) in the hope or expectation that increasing the amount of assets invested with the ETFs will increase the number and/or size of transactions placed by the ETFs for execution by JPMS or an affiliate or other related person, and 33823_J 11-05-2025 Page 39 of 49  that the referred client will be charged by the other adviser for the cost of obtaining the client’s business; and thereby result in increased compensation to JPMS and its affiliates and other related persons in the aggregate; and (2) to benefit the ETFs and thereby preserve and foster valuable brokerage relationships with the ETFs. d. Recommendation or Selection of Other Investment Advisers • Clients referred to other advisers by JPMS have no obligation to become clients of those advisers, and their declining to do business with the adviser to which they were referred will not affect their relationship with JPMS. iii. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading a. Code of Ethics Certain Portfolio Managers, Model Portfolio Providers and/or Program securities that JPMS may identify for clients in the Programs have business relationships outside of the Program with JPMS and/or its affiliates, including relationships in which JPMS and/or its affiliates provide one of them with trading, lending, prime brokerage and/or custody services for compensation. As a result of these relationships, JPMS has a conflict of interest in including those Portfolio Managers, Model Portfolio Providers and/or Program securities in the applicable Program and recommending them to clients because JPMS may have a financial incentive to favor them. JPMS has adopted a Code of Ethics (the Code of Ethics) pursuant to Rule 204A-1 under the Advisers Act. The Code of Ethics is designed to ensure that JPMS and its supervised persons comply with applicable federal securities laws and place the interests of clients first in conducting personal securities transactions. The Code of Ethics imposes certain restrictions on securities transactions in the personal accounts of supervised persons to help avoid or mitigate conflicts of interest, as described more fully below. A copy of the Code of Ethics is available free of charge to any client or prospective client upon request by contacting your Wealth Advisor. General The Code of Ethics contains policies and procedures relating to: • Account holding reports and personal trading, including reporting and pre-clearance requirements for all personnel of JPMS; • Confidentiality obligations to clients set forth in the JP Morgan privacy notices; interest, which • JPMS believes that this conflict is addressed by the fact that neither the persons responsible for the initial and periodic review of the Portfolio Managers, Model Portfolio Providers and/or Program securities (and therefore, for deciding to include them in a Program, initially and on an ongoing basis), nor the Wealth Advisors who identify specific Portfolio Managers, Model Portfolio Providers and/or Program securities to particular clients, receive any direct financial benefit (such as additional compensation) from the investment of Program assets with certain Portfolio Managers, Model Portfolio Providers and/or Program securities instead of others. Moreover, because Wealth Advisors are typically compensated in a Program through the receipt of a portion of JPMS’ component of the Fee, which is typically tied to the value of Program accounts, Wealth Advisors are to that extent incentivized to identify Portfolio Managers, Model Portfolio Providers and/or Program securities they believe will increase the value of the account, regardless of whether or not the Portfolio Managers, Model Portfolio Providers and/or Program securities have other business relationships with JPMS and/or its affiliates. Conflicts of include guidance relating to restrictions on trading on material non-public information (MNPI). In addition, separate from any Program, JPMS acts as a solicitor (sometimes also called a “finder” or “referrer” or “promoter”) of prospective clients for certain other investment advisers, which may include one or more advisers acting as Portfolio Managers in a Program, in accordance with Rule 206(4)-(1) of the Advisers Act. Under its solicitation agreements with those advisers, JPMS is entitled to a specified portion of the advisory fees received by the advisers from the investors that were referred to them by JPMS. The clients JPMS refers may be existing investment advisory clients of JPMS. When JPMS makes a referral of one of its existing investment advisory clients to another adviser under a solicitation arrangement, the arrangement creates a material conflict of interest with the client because: • JPMS has a financial incentive to make the referral because it will be entitled to compensation from the other adviser if the referred client becomes a client of the other adviser; • In general, the personal trading rules under the Code of Ethics require that accounts of JPMS personnel be maintained with an approved broker and that certain trades in reportable securities for such accounts be precleared and monitored by compliance personnel. The Code of Ethics also prohibits certain types of trading activity, such as short-term and speculative trades. JPMS personnel must obtain approval prior to engaging in all covered security transactions, including those issued in private placements. In addition, JPMS personnel are not permitted to buy or sell securities issued by JP Morgan during certain periods throughout the year. Certain Access Persons (defined as persons with access to nonpublic information regarding JPMS’ recommendations to clients, purchases, or sales of securities for client accounts and advised funds) are prohibited from executing personal trades in a security at certain times. In addition, Access Persons are required to disclose household members’ personal security transactions and holdings information. These disclosure obligations and restrictions are designed to mitigate conflicts of interest that arise if Access Persons transact in the same securities as advisory clients. JPMS does not base such referrals on any review, due diligence or assessment of the other advisers, their personnel, investment strategies or services; • JPMS does not conduct an assessment of the suitability of the other advisers’ services for referred clients; and • It may not be in the referred client’s best interest to become a client of the other adviser. JPMS addresses this conflict in the following ways: Additionally, all JPMS personnel are subject to the JP Morgan firm-wide policies and procedures including those found in the JP Morgan Code of Conduct (the Code of Conduct). The Code of Conduct sets forth restrictions regarding confidential and proprietary information, information barriers, private investments, outside business activities and personal trading. All JP Morgan employees, including JPMS personnel, are required to familiarize themselves with, comply with and attest annually to their compliance with the provisions of the Code of Conduct’s terms as a condition of continued employment. Where appropriate, JPMS and its affiliates generally address the conflicts disclosed in this Brochure through policies and procedures. • The other advisers’ payments of solicitation fees to JPMS are typically subject to certain legal requirements and conditions, including the delivery by JPMS to the referred client, at the time of the referral, of a written document that discloses, among other things, the relationship between JPMS and the other adviser, the fact that JPMS will be compensated for the referral, the terms of the compensation arrangement, and the amount (if any) in addition to the advisory fee 33823_J 11-05-2025 Page 40 of 49  b. Securities in which JPMS or a Related Person Has a Material Financial Interest of PA and PM when the proposed transaction cannot readily be effected on an agency basis, the Wealth Advisor has determined that the transaction is in the best interests of the client and all legal disclosure and consent requirements are satisfied; • In some cases, JPMS or a related person recommends to investment advisory clients, or buys or sells for investment advisory client accounts (including accounts in PA, PM and certain strategies of STRATIS), securities in which JPMS or a related person has a material financial interest. For UMA, JPMS can recommend to clients Program securities in which JPMS or a related person has a material financial interest. In addition, for JPMS or any of its affiliates knowingly to act as principal in connection with a transaction for a Program account managed by a Portfolio Manager, the law generally requires that before the completion of each such transaction, JPMS must disclose to the client in writing that it or its affiliate will be acting in a principal capacity and obtain the client’s consent to the transaction; • While JPMS and its affiliates may receive a dealer spread in the net price when acting as principal in connection with a transaction for a client in the Program, they will not receive commissions, “mark- ups” or “mark-downs;” and • For all other Programs, JPMS does not recommend specific securities or securities transactions to clients; the Portfolio Managers make all investment decisions in their sole discretion. However, JPMS’ affiliates are Portfolio Managers in certain Programs that make the investment decisions for the accounts that have selected one or more of their respective strategies. JPMS’ affiliates may also act as Model Portfolio Providers that provide non-discretionary advice for the accounts that have selected one or more of their respective Model Portfolios. JPMS prohibits principal transactions for retirement plan accounts in the Programs (including IRAs and accounts subject to ERISA) under any circumstances where JPMS or any of its affiliates will act as principal. In certain cases, JPMS or a related person, acting as broker or dealer, may effect transactions for, or engage in transactions with, Program accounts in securities in which JPMS or a related person has a material financial interest. When acting as agent for both the client in the Program and the party on the other side of the transaction (known as an “agency cross transaction”), JPMS and its affiliates may receive compensation from both parties and therefore may have a conflicting division of loyalties and responsibilities. To address this conflict: • As a matter of policy, when practicable and consistent with best execution obligations, JPMS prohibits the effecting of transactions for Program clients where JPMS or its affiliate acts as agent for the other side of the transaction; Wealth Advisors may also receive financial incentives to join and/or remain at JPMS. These incentives, which are in addition to the compensation received in connection with total revenue attributable to them, may take various forms, including an up-front loan, annual cash payment, Restricted Stock Units (RSUs) and performance awards. Performance awards can be revenue–based, asset–based or a hybrid of both and will be contingent upon meeting requirements set forth in the respective Wealth Advisor's employment contract and provided to the adviser in an agreed upon split percentage between cash and RSUs. 1. Principal and “Agency Cross” Transactions • For JPMS or any of its affiliates knowingly to effect a transaction for a Program account managed by JPMIM or JPMPI where JPMS or its affiliate acts as agent for the other side of the transaction, the law generally requires that JPMS satisfy certain conditions, including the client’s prospective written authorization of such agency cross transactions, the right of the client to revoke such authorization at any time in writing, and the provision of certain written disclosure to the client; and • Certain securities such as over-the-counter stocks and fixed income securities are traded primarily in “dealer” markets. In such markets, securities are purchased directly from, or sold directly to, a financial institution acting as a dealer, or “principal.” Dealers executing principal trades typically include a “mark-up” (an increase in the price paid to the dealer when the dealer is selling a security), “mark-down” (a decrease in the price paid by the dealer when the dealer is buying a security) and/or “dealer spread” (the difference between the bid price and offer price for a security) in the net price at which the transactions are executed. JPMS also prohibits agency cross transactions for retirement plan accounts in the Program (including IRAs and accounts subject to ERISA) under any circumstances. In order to comply with principal trade restrictions, orders for the Programs are routed for agency execution. In connection with transactions executed for Program accounts, when permitted by applicable law and JPMS policy, JPMS, acting on behalf of client accounts, enters into transactions in securities and other instruments with or through JPMC and causes accounts to engage in principal transactions. A “principal transaction” occurs if JPMS, acting on behalf of client accounts, knowingly buys a security from, or sells a security to, JPMS or its affiliate's own account. The restrictions on the ability of JPMS and its affiliates to effect principal and agency cross trades for Program accounts mean that JPMS will typically execute transactions in “dealer market” securities solely as agent for the client, with a dealer unaffiliated with JPMS on the other side of the transaction. Clients should understand that the restrictions may result in the accounts being precluded from investing in certain securities or in the accounts paying or receiving a less favorable price for certain securities. Generally, the likelihood that there will be such an effect will depend on the particular security in question and the nature of the market for that security. These restrictions could have a negative effect on the performance of Program accounts. When acting as principal in accordance with applicable law, JPMS and its affiliates may charge the Program client a “dealer spread,” which will be incorporated into the net price paid (for purchases) or received (for sales) by the client in the transaction. Dealer spreads paid by the client and received by JPMS and its affiliates are not covered by and are in addition to the Fee. Therefore, because by acting in a principal capacity JPMS and its affiliates may earn additional amounts at the expense of the client, JPMS and its affiliates have a financial interest in acting in such capacity in connection with transactions in Program accounts that conflicts with the client’s interest in avoiding the payment of dealer spreads. JPMS addresses this conflict in several ways, including: In PA, for FINRA reporting purposes, JPMS maintains a “house” or facilitation account (the Facilitation Account) through which client trades in structured products are routed prior to allocation into or out of a client’s Program account. The Facilitation Account does not hold any proprietary positions of JPMS or its affiliates. When a client instructs JPMS to purchase or sell a structured product in the client’s Program account, the structured product will be sent to the Facilitation Account, and then either be settled into the client’s Program account (for buys) or sent to the purchasing dealer (for sells). JPMS does not impose a mark- up, mark-down or any other additional fee or charges on such transactions; the price at which JPMS buys or sells the structured product on behalf of a client is the price that such client will pay or receive. In connection with the offering of any • As a matter of policy, JPMS generally prohibits the effecting of transactions for Program clients where JPMS or any of its affiliates will act as principal. In certain circumstances, exceptions may be permitted, typically for non-retirement plan accounts only; or in case 33823_J 11-05-2025 Page 41 of 49  structured product, an affiliate of JPMS may provide services to the sponsor of the structured product and will receive fees for their services. assets to pay the costs of marketing and distribution of the fund’s shares. If JPMS receives 12b-1 Distribution Fees, it will rebate these fees to its advisory clients. 2. Time and Price Discretion In PA, JPMS and/or its affiliates can exercise limited discretion as to the price or time at which they can execute an order for a transaction in an account (“time and price discretion”), so long as such discretion is exercised on the same day that that the order is given and is consistent with JPMS’ duty to seek best execution. In addition, JPMS and/or its affiliates may aggregate orders for the sale or purchase of securities in such accounts with orders for the same security for JPMS’ and/or its affiliates’ other clients without prior authorization, if the transaction is effected on the same day in which the order was received, and in accordance with the law and with the obligation to seek the best execution. Generally, each affected account in the aggregated transaction will be provided with the average price per share or unit, and, when applicable, it’s pro rata shares of any fees. 3. Affiliated Sponsors and Advisers of Funds JPMS and Portfolio Managers may recommend that Program clients invest or invest account assets in Funds that have various internal fees and expenses, which are paid by the Funds but which are ultimately borne by the client as investor. The sponsors and/or general partners of certain such Funds are affiliated with JPMS (including those in which JPMS or its affiliates have a minority and/or non-controlling interest), and JPMS and its affiliates may provide investment management and other services to, and receive compensation from or in connection with, such Funds. In addition, in certain Programs, JPMS may designate such J.P. Morgan- affiliated Funds as default replacements for strategies, Models Portfolios or Program securities removed from the Program. • Other Fees: JPMS enters into agreements with the funds, their investment managers, distributors, principal underwriters, shareholder servicing agents and/or other affiliates of the funds (Service Providers). The funds or their Service Providers pay J.P. Morgan fees for providing certain administrative services, which include maintaining and updating separate records for each client, preparing and delivering client statements, tax reporting, proxy voting and solicitation, processing purchase and redemption orders, processing dividends, distributing prospectuses and other fund reports, and responding to client inquiries. These fees for these services are typically called “shareholder servicing fees” when paid for by the fund; however, these fees can be referred to as “revenue sharing” when they are paid by the fund Service Provider from its own resources (together referred to as Servicing Fees). As of December 31, 2024, the Servicing Fees that JPMS received for non- money market funds were up to 25 basis points annually of the fund assets, or a rate of up to $20 per year per fund position; however, these amounts can change. The receipt by JPMS of these fees creates a conflict of interest in the selection of funds for accounts because the fees are different among funds. Similarly, JPMS has a conflict to recommend mutual funds that pay Servicing Fees instead of ETFs or other securities or products that do not typically pay any Servicing Fee. The Portfolio Managers or Wealth Advisors who are responsible for managing or recommending investments for Program accounts do not receive any direct financial benefit from the Servicing Fees. To that extent, such Portfolio Managers or Wealth Advisors are incentivized to invest in or recommend securities they believe will increase the value of the account. JPMS does not retain any portion of those fees for retirement advisory accounts. When evaluating the fees for, and cost of, the Program, clients should consider the Servicing Fees that JPMS receives in addition to the investment advisory fee. Clients can also request a fund prospectus for additional information regarding fund fees. A client’s investment of assets in affiliated Funds or selection of an affiliated Fund as the vehicle for the temporary investment (i.e., sweeping) of available cash balances benefits those Funds and their affiliated sponsors and/or general partners. In addition, several affiliates of JPMS manage affiliated Funds and receive an investment management fee for doing so. Although the management fee is paid by the Fund itself, ultimately it is borne by investors in the Fund. For additional information on the investment of client assets in affiliated Funds or investment vehicles, refer to Item 9 above. 4. Other Compensation from Affiliated and Unaffiliated Mutual Funds and Other Pooled Investment Vehicles Once a particular share class is made available for a particular fund in a Program, only that share class can be purchased for that fund. Mutual funds will be purchased in the account at net asset value (no-load or load-waived) and ETFs at their market price. JPMS periodically reviews the share classes offered by funds in a Program but also relies on the fund families to inform JPMS when and if these share classes will be made available. If JPMS identifies and makes available a class of shares for a fund more appropriate than the class of shares previously made available for the fund, to the extent allowed, JPMS can convert client shares of the fund to that more appropriate share class of the same fund. Operational and other considerations can affect the timing of the conversion of shares and can cause the timing or implementation of such conversions to differ between clients. Some of the fund share classes available through certain Programs are not necessarily available outside of such Programs. To the extent an account is terminated, clients may not be eligible to continue to hold or purchase certain share classes offered in the Programs outside of the Programs, as well as outside the Firm. Mutual funds typically offer different ways to buy shares with different share classes that may assess different fees and expenses. JPMS strives to make available the most appropriate share class on the platform for each fund, with the goal of generally obtaining the lowest cost share class. However, for certain funds, the share classes with the lowest fee structures are not available in a Program (e.g., (1) the fund family restricts access to these share classes or (2) JPMS does not have an agreement with the fund to distribute the share class in the Program). Clients should be aware that the share class of a fund available through a Program can differ from the share class available to similar accounts managed by or held at JPMS or its affiliates and that certain lower cost fund share classes can be available outside of the Program. Clients should contact their Wealth Advisor(s) for information about any limitations on share classes available through the Programs. JPMS, through its brokerage accounts, has other arrangements with fund companies that are described in the relevant brokerage documents. in their capacity as JPMS and its affiliates receive fees or other forms of compensation from the funds (including money market funds) or their affiliates. JPMS believes that this conflict is addressed in the following ways: • 12b-1 Distribution Fees: JPMS receives fees from certain funds pursuant to Rule 12b-1 under the Investment Company Act of 1940 (12b-1 Distribution Fees). Rule 12b-1 allows funds to use fund Certain affiliated and unaffiliated funds in which Wealth Advisors invest or recommend to clients for the investment of Program account assets may execute transactions for their portfolios through JPMS or an affiliate as broker-dealer, and JPMS or an affiliate or other related person (including investment advisory Wealth Advisors acting representatives of JPMS as broker-dealer) may receive compensation from the funds in connection with these transactions. Such compensation presents a conflict of interest between JPMS and Program clients because JPMS and/or Wealth Advisors may have a financial incentive to invest or recommend that Program clients invest Program account assets in such funds: 33823_J 11-05-2025 Page 42 of 49  1) thereby result in accounts that JPMS or its affiliates have issued. These financial interests conflict with the interest of Program clients in buying and holding securities based solely on the furtherance of the clients’ investment objectives in the Program. JPMS addresses this conflict in the following ways: 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 increased compensation to JPMS and its affiliates and other related persons in the aggregate; and • Because the Portfolio Manager is typically compensated on the basis of the net market value of Program accounts, the Portfolio Manager is to that extent incentivized to exercise their discretion to select investments it believes will increase the value of the account, regardless of whether JPMS, the Portfolio Manager or its affiliates are acting as a manager, co-manager, underwriter or other fees; and 2) To benefit the funds and thereby preserve and foster valuable brokerage relationships with the funds. Assuming that a Program client’s Wealth 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: • When JPMS, the Portfolio Manager or its affiliates is the sole underwriter of an initial or secondary offering, the Portfolio Manager is the sole underwriter of an initial or secondary offering, the Portfolio Manager cannot purchase securities in the offering for its clients. • Unless the Wealth Advisor is individually involved in the execution of portfolio transactions for a fund, the Wealth Advisor does not financial benefit (such as additional receive any direct compensation) from the investment of Program assets in funds that execute transactions through JPMS or an affiliate or other related person. Moreover, because Wealth Advisors are compensated in the Program through the receipt of a portion of the Fee which is typically tied to the value of Program accounts, Wealth Advisors are to that extent incentivized to invest Program account assets in funds or recommend funds they believe will increase the value of the account, regardless of whether or not the funds execute transactions through JPMS or an affiliate or other related person; and As discussed in Item 6.vi, SPAC securities have unique additional risks that clients should consider before investing. In particular, in a SPAC structure, the SPAC’s ability to successfully effect a business combination and to be successful thereafter will be particularly dependent, in whole or in part, upon the efforts of the SPAC’s key personnel. Although JPMS (or its affiliates) will not receive any special compensation (other than customary underwriting compensation) in connection with a SPAC IPO, JPMS may potentially provide other services and products to the SPAC and/or the SPAC’s key personnel, which may enhance JPMS’ relationships with such parties, and enable J.P. Morgan to obtain additional business and generate additional revenue from such parties. 8. Securities Allocations and Limitations • Wealth Advisors’ advising or management of Program accounts is subject to supervision designed to ensure that the accounts are advised or managed in accordance with clients’ investment objectives for the accounts and that Wealth Advisors are acting in accordance with their fiduciary duty to place the interests of Program clients before their own and those of JPMS. 5. Other Securities Issued by JPMS and Its Affiliates Refer to “JPMorgan Chase & Co. and Other Affiliated Issuers of Securities” in Item 9.ii.c.2 above for information on other securities issued by JPMS and its affiliates. 6. Clients’ Investments in Affiliated Companies JPMS is part of a large financial services firm. In connection with providing investment advisory services to its clients, JPMS uses the products or services of its affiliates or other related persons, as described both above and below. JPMS and/or its affiliates can receive more compensation from certain accounts that use strategies similar to those used by Program Accounts (Similar Accounts) than it or its affiliates receive from Program Accounts. JPMS or its affiliates has a conflict of interest to the extent that JPMS or an affiliate has a proprietary investment in Similar Accounts, the Portfolio Managers have personal investments in Similar Accounts, or the Similar Accounts are investment options in JPMS’ or its affiliates’ employee benefit plans. Subject to applicable law, from time to time, JPMS will include Funds, equity instruments or other securities in Model Portfolios, and therefore client accounts will represent an indirect interest in securities of J.P. Morgan, including J.P. Morgan stock. JPMS will receive advisory fees on the portion of client holdings invested in such instruments or other securities and is entitled to vote or otherwise exercise rights and take actions with respect to such instruments or other securities on behalf of its clients. Generally, such activity occurs when a client account includes an index strategy that targets the returns of certain indices in which J.P. Morgan securities are a key component. JPMS and its affiliates maintain certain investment limitations on the positions in securities, or other financial instruments, that JPMS or its affiliates will take on behalf of its various clients due to, among other things: (i) liquidity concerns; (ii) operational considerations; (iii) regulatory requirements applicable to JPMS or its affiliates; and (iv) internal policies related to such concerns or requirements, in light of the management of multiple portfolios and businesses by JPMS and its affiliates. Such policies preclude JPMS or its affiliates from purchasing certain securities for clients and can cause JPMS to sell certain securities held in client accounts. 7. Client Participation in Offerings where JPMS and its Affiliates act as Underwriter or Placement Agent A potential conflict of interest also can arise if transactions in one account closely follow related transactions in a different account, such as when a purchase increases the value of securities previously purchased by another account or when a sale in one account lowers the sale price received in a sale by a second account. 9. Conflicts of Interest Related to Aggregation and Allocation In addition to the Funds sponsored and managed by affiliates of JPMS, JPMS, and its other affiliates also may act as a manager, co-manager, underwriter or placement agent for securities offered through public or private distributions. For CBP, if permitted by a client’s investment objectives and subject to compliance with applicable law, regulations and exemptions, the Portfolio Manager may purchase securities for client accounts, including new issues, during an underwriting or other offering of such securities in which JPMS or its affiliates act as a manager, co-manager, underwriter or placement agent and for which JPMS or its affiliates receives a benefit in the form of management, underwriting or other fees. JPMS and its affiliates also act in other capacities in such offerings and may receive fees, compensation or other benefit for such services. JPMS and its affiliates and other related persons could have an interest in the Portfolio Manager buying (or not selling) securities in Program Conflicts of interest can arise with both the allocation of investment opportunities, including trading opportunities and pricing of trading generally, and the aggregation of orders and allocation of executed transactions specifically, because of market factors or investment restrictions imposed upon JPMS and its affiliates by law, regulation, contract or internal policies. Allocations of transactions resulting from aggregated orders, particularly orders that are only partially completed (due to limits on availability, capacity constraints and other factors) and allocation of investment opportunities generally, would raise a conflict of 33823_J 11-05-2025 Page 43 of 49  fees and, in some cases, pay rebates for the provision or removal of liquidity. In addition, JPMS receives marketing fees from options exchanges under marketing fee programs sponsored by some exchanges. Under some circumstances, the amount received by JPMS from a trading center over a period of time may exceed the amount that JPMS is charged by a trading center. These practices are one of many factors that may impact routing decisions and do not alter JPMS’ policy to route customer orders in securities to the trading centers where it believes customers will receive the best execution, taking into account, among other factors, price, transaction cost, volatility, reliability, market depth and speed. interest where JPMPI or its affiliates have an incentive to allocate investment opportunities or securities that are expected to increase in value to favored accounts, including affiliated accounts and accounts that pay higher fees. JPMS mitigates this conflict by using guidelines designed by JPMS and affiliates to allocate investment and trading opportunities among similarly situated Program accounts on a fair and equitable basis over time. A conflict of interest also would arise if transactions in securities in one account closely follow transactions in the same securities in different accounts, especially when the transactions or series of transactions are large in relation to the securities’ trading volume and potentially have market impact, such as when a purchase increases the value of securities previously purchased by the other accounts, or when a sale in one account lowers the sale price received in a sale by other accounts. available in Rule 606 reports Affiliates of JPMS have ownership interests in some trading centers. Accordingly, JPMS stands to share in any profits that these trading centers earn from the execution of JPMS customer orders on those trading centers. Additional information on the material aspects of JPMS’ relationships with the primary trading centers to which JPMS routes, including descriptions of arrangements for payment for order flow and profit-sharing relationships, is at SEC JPMS’ jpmorgan.com/OrderExecution. 12. J.P. Morgan’s Use and Ownership of Trading Systems JPMS and its affiliates have intercompany arrangements whereby one or more affiliates share personnel for one or more purposes, including the construction and implementation of trade orders for multiple programs and affiliated entities. Any such shared personnel are subject to the policies and procedures of the applicable affiliate when acting on its affiliate’s behalf. Any such shared personnel will have potentially conflicting interests when playing these various roles. Such personnel splitting time and attention between one or more JPMS affiliates creates conflicts of interest in that the time and effort of these shared personnel will not necessarily be devoted exclusively, or even predominately, to JPMS. While the affected affiliates have adopted policies, procedures or guidelines to address conflicts of interest associated with personnel sharing, such policies, procedures or guidelines can differ and there can be no assurance that such policies, procedures or guidelines will successfully eliminate or mitigate all such conflicts in every case. 10. Conflicts Related to the Advising of Multiple Accounts JPMS may effect trades on behalf of Program accounts through exchanges, electronic communications networks, alternative trading systems, and similar execution systems and trading venues (collectively, Trading Systems), including Trading Systems in which J.P. Morgan has a direct or indirect ownership interest. J.P. Morgan will receive indirect proportionate compensation based upon its ownership percentage in relation to the transaction fees charged by such Trading Systems in which it has an ownership interest. Such Trading Systems (and the extent of J.P. Morgan’s ownership interest in any Trading System) may change from time to time. JPMS addresses this conflict by disclosure to its clients. Also, it is JPMS’ policy, to the extent practicable, to allocate, within its reasonable discretion, investment opportunities among clients over a period of time on a fair and equitable basis. One or more of JPMS’ other client accounts may at any time hold, acquire, increase, decrease, dispose of, or otherwise deal with positions in investments in which another client account would have an interest. For instance, due to differences in investment strategies, JPMS might sell a security for a client at the same time that it might hold or purchase the same security for a different client. c. When JPMS or a Related Person Invests in the Same Securities That It Recommends to or Buys/Sells for Clients strategies. For example, For Programs with a discretionary third-party Portfolio Manager, except for PM and certain strategies of STRATIS, JPMS does not recommend specific securities or securities transactions to clients; the Portfolio Managers make all investment decisions in their sole discretion. However, JPMS’ affiliates JPMIM and JPMPI are Portfolio Managers in certain Programs that make the investment decisions for the accounts that have selected one or more of their respective strategies. In certain Programs, JPMS and its related persons (including Wealth Advisors) may recommend that clients buy or sell securities or may buy or sell securities for clients (including clients in a Program), that it or a related person buys or sells for itself. Certain portfolio managers of JPMS manage or advise multiple client accounts, investment vehicles or portfolios. These portfolio managers are not required to devote all or any specific portion of their working time to specific client accounts or investment vehicles. Conflicts of interest do arise in allocating management time, services or functions among such clients, including clients that have the same or similar type of investment strategies. JPMS addresses these conflicts by disclosing them to clients and through its review of portfolio managers and their teams. Responsibility for managing JPMS’ client accounts is organized according to investment strategies within asset classes. Generally, client accounts with similar strategies are managed by portfolio managers in the same portfolio management team using the same or similar objectives, approach and philosophy. Therefore, client account holdings, relative position sizes, and industry and sector exposures generally tend to be similar across client accounts with similar strategies. However, JPMS faces conflicts of interest when JPMS’ portfolio managers manage accounts or portfolios with similar investment investment objectives and opportunities that are appropriate for certain clients may also be appropriate for other clients, including the clients of JPMS, other affiliated investment advisers, and related persons, and, as a result, client accounts would have to compete for positions. There is no specific limit on the number of accounts which will be managed or advised by JPMS or its related persons. Once held by a client account, certain investments compete with other investments held by other client accounts of JPMPI and its related persons. The conflict associated with managing assets on behalf of different clients that compete with each other are heightened when JPMS retains certain management, control or consent rights over such assets. JPMS has controls in place to monitor and mitigate these potential conflicts of interest. 11. Payment for Order Flow In some cases, JPMS or a related person, acting as broker or dealer, may effect transactions for Program accounts in the same securities that it or a related person invests in. In addition, JPMS and its related persons (including the Portfolio Manager(s)), can buy or sell securities for Program accounts; recommend that clients buy or sell securities; include securities as Program securities in certain Programs; or, in certain Programs, designate securities as default replacements for Model Portfolios, Program securities or Portfolio Manager strategies removed from the Program that JPMS or a related person invests in. In such circumstances, the interests of JPMS and its related persons conflict with those of Program clients in several respects: JPMS does not receive payment for order flow from market makers for customer orders in equity securities. JPMS receives rebates from and pays fees to some registered securities exchanges for providing or taking liquidity on those exchanges, according to those exchanges’ published fee schedules approved by the SEC. Alternative trading systems also charge 33823_J 11-05-2025 Page 44 of 49  • JPMS or a related person may benefit from (1) clients buying securities that JPMS or the related person then sells or (2) clients selling securities that JPMS or the related person then buys, because client purchases may increase the market price of a security JPMS or the related person owns or borrows and then sells, and client sales may reduce the market price of a security JPMS or the related person then buys. • Clients should understand that Wealth Advisors typically are not required, except as described in Item 6.vi. above, 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 Wealth Advisors to clients in the Program or the Wealth Advisor’s management of Program accounts may differ from (and be diametrically opposed to) the content of such reports, analyses and opinions. JPMS or a related person may benefit from (1) buying securities that clients will later buy (because the subsequent client purchases may increase the market price of the security JPMS or the related person already bought and owns) or (2) selling securities that clients will later sell (because subsequent client sales may decrease the market price of the security JPMS or the related person already sold). • JPMS or a related person may benefit from principal transactions in which it sells a security directly from its own account to a client account or buys a security into its own account directly from a client account. JPMS addresses these conflicts in the following ways: JPMS, J.P. Morgan and any of their directors, partners, officers, agents or employees also buy, sell or trade securities for their own accounts or the proprietary accounts of JPMS and/or J.P. Morgan. JPMS and/or J.P. Morgan, within their discretion, and can make different investment decisions and take other actions with respect to their proprietary accounts than those made for client accounts, including the timing or nature of such investment decisions or actions. Further, JPMS is not required to purchase or sell for any client account securities that it, J.P. Morgan and any of their employees, principals or agents may purchase or sell for their own accounts or the proprietary accounts of JPMS or J.P. Morgan. JPMS, J.P. Morgan and their respective directors, officers and employees face a conflict of interest as they will have income or other incentives to favor their own accounts or the proprietary accounts of JPMS or J.P. Morgan. • For Programs with a discretionary third-party Portfolio Manager, except for JPMIM and JPMPI with respect to the Program accounts they manage, neither JPMS nor other related persons (including the Wealth Advisors) controls or recommends specific securities transactions for Program accounts; d. When JPMS or a Related Person Buys/Sells Securities for Itself at or About the Same Time It Recommends or Buys/Sells the Same Securities to/for Clients • 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; • 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, including JPMS; and For PA, JPMS or a related person may recommend to investment advisory clients, or buy or sell for PM client accounts, securities in which JPMS or a related person has a material financial interest. For the other Programs, JPMS does not recommend specific securities or securities transactions to clients; the Portfolio Managers make all investment decisions in their sole discretion. However, JPMS’ affiliates JPMIM and JPMPI are Portfolio Managers in certain Programs that make the investment decisions for the accounts that have selected one or more of their respective strategies. • The policy and legal restrictions on principal transactions with Program accounts described in Item 9.iii.b above. The following are for PA and PM: In some cases, however, JPMS or a related person, acting as broker or dealer, may effect transactions for Program accounts at or about the same time that it or a related person buys or sells the same securities for its (or a related person’s) own account. In addition, Portfolio Managers may buy or sell or recommend that clients buy or sell or identify for clients securities for Program accounts or designate as a default replacement for Model Portfolios, Portfolio Manager strategies and Program securities removed from a Program at or about the same time that JPMS or a related person (including the Portfolio Managers) buys or sells the same securities for its (or a related person’s) own account. • The general prohibition in the Code of Ethics on the personal trading by any Wealth Advisor in the PM or PA Program on the same day in the same security or derivative or on the opposite side of the market in the same security or derivative that was traded for any of the Wealth Advisor’s PM or PA client accounts. PM or PA Wealth Advisors may trade in their own accounts (and related person accounts) for the same security for their PM or PA client accounts, as long as they do not receive a better price than their PM or PA clients, subject to a de minimis exception. PM or PA Wealth Advisors are prohibited from trading opposite (including derivatives) their PM or PA clients on the same day; In such circumstances, the interests of JPMS and its related persons conflict with those of JPMS’ clients 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. Refer to Item 9.iii.c above for a description of those conflicts and how they are addressed. • Review of Wealth Advisors’ handling or management of Program accounts designed to ensure that the accounts are advised or managed in accordance with clients’ investment objectives for the accounts and that Wealth Advisors are acting in accordance with their fiduciary duty to place the interests of Program clients 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 Wealth Advisors) from unfairly benefiting from unreleased research reports and recommendations; and Portfolio Managers and/or JPMS may, but are not required to, aggregate orders for the sale or purchase of a security for a client’s account with orders for the same security for other clients, including orders for Portfolio Managers or JPMS’ or their affiliates’ employees and related persons. Aggregated orders will generally be filled at an average price, with a pro rata share of transaction costs (if applicable). A client order that is not aggregated with one or more other client orders may be executed at a less favorable price and incur greater transaction costs than an aggregated order. JPMS generally will not aggregate orders of client accounts in PM managed by different Wealth Advisors or of client accounts in PA advised by different Wealth Advisors. • The requirement in the Code of Ethics that Wealth Advisors in the Program periodically report personal securities holdings and transactions to JPMS compliance personnel. In PA and PM, however, the aggregation of different clients’ orders also may be to the detriment of a particular client. The execution of aggregated orders may be subject to delay for certain reasons. Accordingly, the 33823_J 11-05-2025 Page 45 of 49  affiliates hold exclusivity rights to certain investments and therefore, other clients are prohibited from pursuing such investment opportunities. iv. Review of Accounts aggregation of the client’s order with other client orders may cause the client’s order to be executed later, and at a different price, than it would have been had the client’s order not been aggregated with other client orders. a. Nature and Frequency of Program Account Reviews In addition, a Portfolio Manager whose strategy is available to clients in both STRATIS or UMA and another Program sponsored by JPMS — such as STRATIS or ICS or UMA — may not aggregate orders for the sale or purchase of a security for clients in both Programs; therefore, clients in STRATIS or UMA with assets invested according to such a strategy may receive execution of the order at a different time and price than JPMS clients invested according to the same strategy in the other Program. Each client is responsible for monitoring their Program account(s). The actual allocation of assets may change over time due to fluctuations in the market value of the assets and/or additions to or withdrawals by the client. In addition, clients are responsible for determining whether a change in the client’s circumstances may warrant a change to their selected Program, Portfolio Manager and/or strategy. At account opening, the client’s Wealth Advisor determines that the Program account and the investment strategy(s) are suitable investments for the client, based on the information provided by a client. Clients have ongoing reasonable access, during normal business hours, to their Wealth Advisor who is available for consultation regarding the client’s account(s). Wealth Advisors are an essential component to the Programs and provide clients with non-discretionary and/or discretionary investment advisory services and account maintenance support. Since most discretionary accounts invested in a strategy of an unaffiliated and/or affiliated third-party Portfolio Manager in STRATIS, UMA, ICS, JPMCAP and CBP are managed by the Portfolio Manager in a similar manner, JPMS typically does not review individual trades or individual accounts in such Programs. Rather, the designated Portfolio Manager performs the ongoing review of the client accounts in their strategy or strategies. Refer to the applicable Portfolio Manager’s Form ADV Part 2A for more information. The information in this Brochure does not include all of the specific review features associated with each Program or those applicable to particular client accounts. Clients are urged to ask questions regarding JPMS’ review process applicable to a particular Program or investment product. JPMS may have a conflict of interest in connection with the aggregation of orders by multiple Program clients for the purchase or sale of the same security. On occasion, an aggregated order will not be fully executed, or “filled.” A partial “fill” of an aggregated order must be allocated among the affected clients’ accounts. When the affected accounts include a proprietary or personal account for the Portfolio Manager or JPMS or any of their affiliates or other related persons (including Wealth Advisors), or an account that JPMS or its affiliates may have some other reason to favor (because it typically pays JPMS more compensation, for example), the Portfolio Manager or JPMS may have an interest in allocating more shares or units from the partial “fill” to such an account, leaving fewer shares or units for the accounts of other affected clients. JPMS addresses this conflict by processes designed to ensure that the allocation of a partially filled order is fair and equitable in accordance with applicable law. Factors that may affect allocations include, for example, available cash in each account, the size of each account and order, client-imposed or other restrictions on investments in each account, and the desirability of avoiding odd lots. Providing a comparatively favorable allocation to a proprietary or personal account of JPMS or its affiliates or other related persons, however, would not constitute a fair and equitable allocation. For more information about the non-PM Portfolio Manager’s aggregation and allocation policies, refer to its Form ADV Part 2A Brochure or other applicable disclosure document(s). e. Conflicts of Interest Created by Contemporaneous Trading JPMS has established Program guidelines relating to the investment advice or management of assets in the Programs, including but not limited to security concentration, cash concentration or target asset allocation guidelines, which can restrict or limit activity in Program account(s). Program guidelines can vary and change at the sole discretion of JPMS. If the client’s Program account(s) is identified as having investments outside Program investment guidelines, JPMS can consider investments in the client’s other JPMS advisory accounts before taking any action. Clients may request to have these accounts removed from guideline consideration, although a final determination will be made at the sole discretion of JPMS. The client’s Wealth Advisor can make a recommendation to bring their Program account(s) within investment guidelines, or JPMS will require the Wealth Advisor to bring the Program account(s) within the investment guidelines. If a client decides not to take the requested action or the Wealth Advisor does not comply with these guidelines, JPMS can terminate the account(s) from the applicable Program. This will result in the account(s) being converted into a brokerage account(s). Positions taken by a certain client account or the accounts of clients of affiliates for whom the adviser executes trades may also dilute or otherwise negatively affect the values, prices or investment strategies associated with positions held by a different client account. For example, this can occur when investment decisions for one client are based on research or other information that is also used to support portfolio decisions by JPMS or an affiliate for a different client following the same, similar or different investment strategies or by an affiliate of JPMS in managing its clients’ accounts. When a portfolio decision or strategy is implemented for an account ahead of, or contemporaneously with, similar portfolio decisions or strategies for JPMS or an affiliate's other client (whether or not the portfolio decisions emanate from the same research analysis or other information), market impact, liquidity constraints or other factors could result in one account being disadvantaged or receiving less favorable investment results than the other account, and the costs of implementing such portfolio decisions or strategies could be increased. In accordance with the above, Program guidelines may require the client to sell certain securities, thus resulting in capital gains or losses and additional tax reporting obligations. Any potential tax consequences will not prevent JPMS from conducting these transactions in a client’s Program account(s). In addition, it is a perceived as a conflict of interest when the activity in one account closely correlates with the activity in a similar account, such as when a purchase by one account increases the value of the same securities previously purchased by another account, or when a sale in one account lowers the sale price received in a sale by a second account. Furthermore, if JPMS or an affiliate manages accounts that engage in short sales of securities in which other accounts invest, JPMS or an affiliate could be seen as harming the performance of one account for the benefit of the account engaging in short sales if the short sales cause the market value of the securities to fall. Also, certain private funds managed by JPMS or its At JPMS' sole discretion, certain Wealth Advisors have greater latitude in recommending or selecting securities. Therefore, the availability of investment strategies and securities and the applicability of investment limitations can vary depending on the Wealth Advisor. Certain qualified Wealth Advisors manage approved concentrated strategies for select clients that can be required to meet additional eligibility requirements. JPMS’ supervision and monitoring does not substitute for a client’s continued review of their Program assets and the performance of their 33823_J 11-05-2025 Page 46 of 49  Clients are for performance benchmarking too difficult, infeasible or insufficiently valid or useful to the client. reviewing Program responsible investments. communications, including performance reports, trade confirmations and account statements that JPMS provides to them. PA and PM JPMS reviews client accounts in PA and PM on an ongoing and periodic basis. Subject to JPMS’ policies and procedures and applicable law, the periodic performance review typically provided to Program clients may include information about assets in other accounts maintained by the client with JPMS as well as other assets identified to JPMS by the client. By including any such assets in the performance review, JPMS is not undertaking to provide or be responsible for providing any services with respect to those assets. Each Wealth Advisor is responsible for reviewing the Program account(s) they manage in PM and/or advise in PA on an ongoing basis. Responsibility for the supervision of activity in PA and PM accounts lies with the head of the JPMS business and each Wealth Advisor’s Regional Director. Certain aspects of the day-to-day supervision of the Wealth Advisors is delegated by the head of the JPMS business (on behalf of the head of the JPMS business and Regional Directors) to supervision under the Global Head of Wealth Management Supervision. Ongoing reviews of PA and PM accounts by JPMS typically include reviewing Program accounts representing certain risk levels or PA and PM accounts with little or no trading activity. For PA, from time to time, Program clients will typically receive a summary of the asset allocation applicable to the client’s Program account as part of the performance reports provided by JPMS. These summaries are intended to confirm the client’s financial information and the investment objective, risk tolerance and target asset allocation for the account, as provided by the client during the account opening process. Whenever the investment objective, risk tolerance or target asset allocation for the account is subsequently modified by the client, the client receives a Program communication from JPMS that confirms any such modification. Clients should carefully review these asset allocation summaries with their Wealth Advisor(s) to ensure that they accurately represent the client’s current information. Certain Program accounts may also be reviewed by appropriate personnel on other than an ongoing or periodic basis. Among the factors that might trigger such a review are changes in market conditions, securities positions and/or the client’s investment objective or risk tolerance; a request by the client for a meeting or the occurrence of such meeting; client complaints; concerns expressed by a Wealth Advisor’s manager(s), a member of JPMS management or Compliance; and/or the application of internal policies of JPMS. b. Reports to Program Clients Performance reviews are not a substitute for regular monthly or quarterly account statements or Form 1099 and should not be used to calculate the Fee or to complete income tax returns. As applicable, if JPMS does not receive information about the original cost of a security from the client, the market value of the security on a date set by JPMS may be used in lieu of original cost in certain circumstances. JPMS and its affiliates are entitled to rely on the financial and other information that clients or any third-party provides to JPMS. The client is solely responsible for any information that the client provides to JPMS, and JPMS shall not be liable in connection with its use of any information provided by the client or a third-party in the periodic review. JPMS does not provide tax advice, and nothing in the performance review should be construed as advice concerning any tax matter. JPMS allows certain Wealth Advisors in PM to create a composite performance for accounts they manage in a similar style. In preparing account statements, performance reviews and/or reports for Program clients, JPMS uses various industry and non-industry standards to measure account performance, and JPMS may use multiple valuation sources that provide different values for a single asset. As a result, the determination of an account’s asset values may differ for different purposes and different statements, reviews and reports. Detailed calculations of a client’s account asset values are available upon request. Program clients will receive trade confirmations of all transactions executed through JPMS or its affiliates for a Program account, unless they elect to receive a periodic statement of all transactions executed through JPMS for Program accounts in lieu of separate transaction confirmations, and for applicable Programs, to have a copy of the confirmations instead sent to their selected Portfolio Manager. (Notwithstanding such an election by a client, JPMS may in its discretion choose to provide the client with separate written confirmations of some or all of the transactions in the account.) Clients who make this election will not pay a different Fee based upon this election, can rescind this election at any time upon written notice to JPMS, and can later choose to receive from JPMS, at no additional cost, trade confirmations for any prior trades effected during the period in which the client previously elected not to receive separate trade confirmations. Each client receives written account statements on at least a quarterly basis that show all transactions in the account, all contributions to and withdrawals from the account, and all fees and expenses charged to the account. The option to suppress trade confirmations is not available for account(s) in PA. information to determine or verify Neither JPMS nor any third-party reviews the account or specific performance its accuracy or compliance with presentation standards, and the information may not be calculated on a uniform and consistent basis. Clients receiving periodic performance reviews from JPMS should carefully review the disclosures, definitions and other information contained in the reviews. Each client account is also governed by a Summary of Your Investment Advisory Account document, which outlines and/or confirms the preferences and other selections a client makes for each account after discussion with their Wealth Advisor(s). Clients will receive a Summary for each account they open, and any time clients make certain changes to their account, including changes to the client’s Risk Score, that confirms any such modification. Clients should notify their Wealth Advisor(s) promptly if they believe any information or election contained in any Summary of Your Investment Advisory Account is inaccurate or incomplete, or if clients have any questions or concerns regarding any information contained therein. For certain Programs, there is an inherent conflict of interest where JPMS or an affiliated Portfolio Manager values securities or assets in client accounts or provides any assistance in connection with such valuation and JPMS and an affiliated Portfolio Manager are receiving fees based on the value of such assets. Overvaluing certain positions held by clients will inflate the value of the client assets as well as the performance record of such client accounts which would likely increase the fees payable to JPMS and the affiliated Portfolio Manager. The valuation of investments may also affect the ability of the affiliated Portfolio Manager to raise successor or additional funds. As a result, there may be circumstances where JPMS or the affiliated Portfolio Manager is incentivized to determine valuations that are higher than the actual fair value of investments. Additionally, Program clients typically receive periodic performance reviews summarizing the investment performance of their Program account(s), which are also included in the Fee. However, certain client accounts may not receive such performance reviews; in its discretion, JPMS may not provide a client with performance reviews for a Program account if, for example, the account’s assets are not custodied by JPMS or JPMS concludes that the nature of the investment strategy used or securities held the account makes valuation, performance measurement or in On occasion, JPMS utilizes the services of affiliated pricing vendors for assistance with the pricing of certain securities. In addition, securities for 33823_J 11-05-2025 Page 47 of 49  sponsors to provide financial support for such activities, JPMS has an incentive to allow them (as opposed to others that are unwilling to provide such financial support) to participate in such joint marketing activities. However, the payments by the Portfolio Managers and/or sponsors are not made in exchange for JPMS’ provision of investment advisory services to its clients. which market quotations are not readily available, or are deemed to be unreliable, are fair valued in accordance with established policies and procedures. Fair value situations could include, but are not limited to, a significant event that affects the value of a security, illiquid securities or securities that have defaulted or been de-listed from an exchange and are no longer trading, or any other circumstance in which it is determined that current market quotations do not accurately reflect the value of the security. c. Account Errors and Resolutions Refer to Item 9.ii above for a discussion of (1) revenue sharing arrangements between JPMS and certain of its affiliates pursuant to which JPMS may receive compensation from the affiliates in connection with referrals of clients by JPMS to such affiliates for the receipt products and services to the clients; and (2) solicitation arrangements in which JPMS acts as solicitor for certain other investment advisers who compensate JPMS for referring clients to them. In such cases, the compensation is in exchange for JPMS’ referral of clients to other (affiliated or unaffiliated) financial service providers — not for JPMS’ own provision of investment advisory services to its clients. b. Compensation from JPMS to Unsupervised Persons for Client Referrals Account errors, trade errors and other operational mistakes occasionally occur in connection with the management of Funds and client accounts. JPMS has developed policies and procedures that address the identification and correction of such errors and generally require that errors caused by JPMS and affecting a client's account be resolved promptly and fairly. Errors can result from a variety of situations, including portfolio management (e.g., inadvertent violation of investment restrictions), trading, processing or other functions (e.g., miscommunication of information, such as wrong number of shares, wrong price, wrong account, executing the order as a buy rather than a sell and vice versa). The intent of the policies and procedures is to restore a client account to the appropriate financial position as determined in good faith by JPMS based on what it considers reasonable in light of all relevant facts and circumstances surrounding the error. JPMS makes its determinations pursuant to its error policies and procedures on a case-by-case basis, in its discretion, based on factors it considers reasonable. Under certain circumstances, JPMS may consider whether it is possible to adequately address an error through cancellation, correction, reallocation of losses and gains or other means. In addition to compensating certain supervised persons (including Wealth Advisors) for their provision of investment advisory services to clients on behalf of JPMS and/or for their referral or introduction of investors who become advisory clients of JPMS, JPMS has entered into agreements with certain unaffiliated third-parties (sometimes also called a “finder,” “referrer” or “promoter”) for their referral of prospective investment advisory clients to JPMS in accordance with Rule 206(4)-(1) of the Advisers Act. Under these solicitation arrangements, JPMS agrees to pay each finder when a referred prospective client becomes an investment advisory client of JPMS. JPMS either pays the finder a flat amount or a specified portion of the Fee it receives and retains relating to each such client’s advisory account. When a finder makes a referral of a prospective client to JPMS under a solicitation arrangement, the arrangement creates a material conflict of interest with the prospective client because: • The finder has a financial incentive to make the referral because it will be entitled to compensation from JPMS if the referred prospective client becomes a client of JPMS; If a trade error is made in a client’s account, JPMS will take action to make the account whole. JPMS corrects trade errors in IRA and ERISA accounts in the impacted Program account and uses a firm account to correct all other trade errors in non-retirement Program accounts. If bonds are erroneously sold from a client’s account, it is possible that JPMS or the Portfolio Manager will not be able to find the same bonds to buy back for the account. In that case, JPMS or Portfolio Manager will purchase bonds that it believes are equivalent in quality and yield. v. Testimonials and Endorsements • The finder does not base such referrals on any review, due diligence or assessment of JPMS, or on our personnel, investment strategies or services; a. Compensation from Non–Clients to JPMS for JPMS’ Provision of Advisory Services • The finder does not conduct an assessment of the suitability of JPMS’ services for referred prospective clients; and • To the best of its knowledge, JPMS does not receive economic benefits from non-clients for providing investment advice or other advisory services to its clients. It may not be in the referred prospective client’s best interest to become a client of JPMS. JPMS addresses this conflict in the following ways: • that discloses, among other things, JPMS and its affiliates do receive economic benefits from certain Funds when JPMS’ investment advisory clients’ invest in such Funds. Although these benefits are attributable to sales of the Funds to JPMS’ investment advisory clients and the investment of investment advisory 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 the clients. For a discussion of the benefits and the conflicts of interest they raise, refer to Items 4, 9.ii and 9.iii above. JPMS’ payments of solicitation fees to finders are typically subject to certain legal requirements and conditions, including the delivery by the finder to the referred client, at the time of the referral, of a the written document relationship between the finder and JPMS, the fact that the finder will be compensated for the referral, the terms of the compensation arrangement, and the amount (if any) in addition to the advisory fee that the referred client will be charged by JPMS for the cost of obtaining the client’s business; and • Prospective clients referred to JPMS by finders have no obligation to become clients of JPMS, and their declining to do business with JPMS will not affect their relationship with the finder. vi. Financial Information JPMS is not aware of any financial condition that is reasonably likely to impair JPMS’ 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. As discussed in Item 4 above, JPMCB also receives economic benefits when JPMS’ investment advisory clients select the Deposit Account as the vehicle for the “sweeping” of available cash balances in their accounts. Again, while these benefits are attributable to the investment of the assets of JPMS’ investment advisory clients in the Deposit Account, they are not benefits JPMCB receives in exchange for JPMS’ provision of investment advisory services to the clients. 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 offered in the Programs. These Portfolio 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 or its affiliates. Because of the willingness of these Portfolio Managers and/or 33823_J 11-05-2025 Page 48 of 49  Appendix A The following Model Portfolio Provider investment strategies are available in STRATIS. Model Portfolio Providers provide Model Portfolios to JPMS to implement. Although JPMS, acting as implementation manager, generally purchases and sells in the account investments that are consistent with the Model Portfolios provided by the Model Portfolio Providers, JPMS retains investment discretion over account investments. JPMIM Model Portfolio Strategies J.P. Morgan Digital Evolution Strategy The strategy aims to achieve capital appreciation by investing in equity securities and depositary receipts of companies focusing on or benefiting from the development of technology related products, services and processes that enhance mobility and connectivity. The strategy expects to invest in companies across all market capitalizations with a preference toward medium and large capitalizations. The strategy seeks to deliver long-term total returns in excess of its benchmark over a full market cycle. The strategy seeks to allocate to concentrated equity investments (limited number of holdings) expected to produce current income and capital gains over a longer-term horizon. J.P. Morgan Focused Dividend Growth Strategy J.P. Morgan Innovators Strategy The strategy seeks to deliver long-term total returns by investing in companies that aim to effectively drive innovation by investing in research and development to generate higher growth and profitability. The strategy primarily invests in U.S. listed equity securities, including depository receipts, and real estate investment trusts (REITs). The strategy seeks to deliver capital appreciation by investing in a diversified portfolio of large capitalization, U.S. listed equity securities of companies with a history of growth and future growth potential. J.P. Morgan Large Cap Growth Opportunities The strategy seeks to deliver capital appreciation by investing in a diversified portfolio of U.S. listed equity securities across a broad range of market capitalization levels. J.P. Morgan All Cap Opportunities J.P. Morgan Dividend Opportunities The strategy seeks to provide total return through capital appreciation and income generation by investing in a diversified portfolio of U.S. listed equity securities which have a history of maintaining or growing their dividend, and which display the potential to increase their dividend in future periods. The strategy seeks to achieve long term capital appreciation by investing in a diversified portfolio of large capitalization U.S. listed equity securities. J.P. Morgan Large Cap Core Opportunities 33823_J 11-05-2025 Page 49 of 49