Mercer Global Advisors Inc.

MERCER GLOBAL ADVISORS INC. 1200 17th Street, Suite 2000 Denver, Colorado 80202 merceradvisors.com March 30, 2026 ITEM 1 – COVER PAGE This Form ADV Part 2A is the Mercer Global Advisors Inc. client brochure (“Brochure”). This Brochure provides information about the qualifications and business practices of Mercer Global Advisors Inc. 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. If you have any questions about the content of this Brochure, please contact us at 888.885.8101 or CCO@merceradvisors.com. Mercer Global Advisors Inc. is registered with the SEC and delivers all investment-related services. Mercer Advisors Inc. is the parent company of Mercer Global Advisors Inc. and is not involved with investment services. Registration as an investment advisor does not imply a certain level of skill or training. Additional information about Mercer Global Advisors Inc. is also available on the SEC’s website at https://adviserinfo.sec.gov/  ITEM 2 – MATERIAL CHANGES Since the annual amendment of Form ADV Part 2A filed on March 28, 2025, the material changes to this Brochure are as follows: • Cover Page: Mercer Global Advisors Inc. relocated to a different office within the same building, • • • • • • • • • • resulting in an address change. Item 14 (Client Referrals and Other Compensation): Updated disclosure regarding the Firm’s participation in the Fidelity Wealth Advisor Solutions Program (“WAS Program”) to reflect that referrals under the program are received through Strategic Advisers LLC. Item 5 (Fees and Compensation): Added clarification regarding the calculation of advisory fees and the potential for accounts to be temporarily suspended from billing when data feeds are unavailable for clients utilizing third-party data aggregation platforms. Item 5 (Fees and Compensation): Updated minimum fee disclosures for clients who engaged the Firm on or after January 1, 2026, for the Guided Investing, Wealth Path, and Custom Wealth service offerings. Item 8 (Methods of Analysis, Investment Strategies, and Risk of Loss): Added additional risk disclosures related to cybersecurity (including third-party dependency risks) and the Firm’s use of artificial intelligence tools (including use, limitations, and controls). Updated disclosures regarding the Firm’s use of options strategies, Delaware Statutory Trust (DST) investments in connection with Section 1031 exchanges, and Section 721 UPREIT transactions, including a discussion of the associated risks. Item 10 (Other Financial Industry Activities and Affiliations): Added disclosure regarding an affiliated entity, Mercer Advisors Tax Services, LLC. Item 14 (Client Referrals and Other Compensation): Added disclosure regarding a referral arrangement with Goldman Sachs Wealth Services, L.P. (“GS Ayco”). Item 5 (Fees and Compensation) and Item 10 (Other Financial Industry Activities and Affiliations): Added disclosure regarding an affiliated real estate entity, FSC Realty, LLC (“FSC”). Item 5 (Fees and Compensation), Item 11 (Code of Ethics and Personal Securities Transactions), and Item 12 (Brokerage Practices): Expanded disclosure regarding additional custodian-imposed fees associated with block trades or trades requiring specialized handling, which may be assessed on a per-account or per-trade basis depending on the execution method used. Item 4 (Advisory Business) and Item 10 (Other Financial Industry Activities and Affiliations): Expanded disclosure regarding affiliated private investment funds, including additional discussion of conflicts of interest related to valuation practices and indirect economic incentives. Item 4 (Advisory Business): Enhanced rollover conflict disclosure to include additional fiduciary acknowledgements, clarification that clients are not obligated to roll over assets, and expanded discussion of applicable rollover scenarios. Item 4 (Advisory Business): Updated the Firm’s regulatory assets under management. • ANY QUESTIONS: Mercer Advisors’ Chief Compliance Officer remains available to address any questions regarding the above changes, or any other issue pertaining to this Brochure. 2  ITEM 3 – TABLE OF CONTENTS Item 1 – Cover Page .................................................................................................................................................................................. 1 Item 2 – Material Changes ................................................................................................................................................................... 2 Item 3 – TABLE OF CONTENTS ........................................................................................................................................................... 3 Item 4 – Advisory Business .................................................................................................................................................................. 4 Item 5 – Fees and Compensation ......................................................................................................................................................21 Item 6 – Performance-based Fees and Side-by-Side Management ................................................................................... 26 Item 7 – Types of Clients .................................................................................................................................................................... 26 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss ........................................................................... 26 Item 9 – Disciplinary Information .................................................................................................................................................. 32 Item 10 – Other Financial Industry Activities and Affiliations .............................................................................................. 32 Item 11 – Code of Ethics and Personal Securities Transactions ............................................................................................. 37 Item 12 – Brokerage Practices ........................................................................................................................................................... 38 Item 13 – Review of Accounts ............................................................................................................................................................ 41 Item 14 – Client Referrals and Other Compensation ................................................................................................................. 41 Item 15 – Custody .................................................................................................................................................................................. 47 Item 16 – Investment Discretion ..................................................................................................................................................... 47 Item 17 – Voting Client Securities .................................................................................................................................................... 47 Item 18 – Financial Information ...................................................................................................................................................... 48 Supplemental Information ................................................................................................................................................................ 49 3  ITEM 4 – ADVISORY BUSINESS Description of Advisory Firm Mercer Advisors was founded in 1985 by Kendrick Mercer and started as a law practice focused on estate planning for professionals and families. In May of 2008 Mercer Global Advisors Inc. registered with the SEC. Today, Mercer Global Advisors Inc. (“Mercer Advisors”) is a private company that is owned (indirectly through parent companies) by employees, as well as outside investors. Mercer Advisors is organized as a corporation. Mercer Advisors serves individuals, families, small business owners, plan sponsors, foundations, non-profits, and endowments. Mercer Advisors provides discretionary and/or non-discretionary investment advisory services on a fee basis. As of December 31, 2025, the firm provided discretionary investment management services on assets of $82.9 billion and non-discretionary advisory services on assets of $1.4 billion. Mercer Advisors can also provide financial planning, tax planning, retirement planning, estate planning, and consulting services to clients in varying combinations and with various corresponding fee arrangements, depending upon the level and scope of the requested service(s) to be provided. If Mercer Advisors subsequently determines that the client requires additional and/or extraordinary planning and/or consultation services (to be determined in the sole discretion of Mercer Advisors), Mercer Advisors can, subject to the relevant client agreement(s), determine to charge for such additional and/or extraordinary services, the dollar amount of which shall be set forth in a separate written notice to the client. “Mercer Advisors” is a brand name used by several affiliated legal entities owned by Mercer Advisors, Inc., including Mercer Global Advisors Inc., an SEC registered investment adviser providing investment advisory and family office services; Mercer Advisors Private Asset Management, Inc., an SEC registered investment adviser providing discretionary investment management services to affiliated private funds; Mercer Advisors Tax Services, LLC, a tax services and accounting firm (“MATS”); Heim, Young and Associates, Inc. (MA Brokerage Solutions), a broker-dealer, member FINRA/SIPC; and Mercer Advisors Insurance Services, LLC (MAIS), an insurance agency. Investment Advisory Services Mercer Advisors provides discretionary and non-discretionary investment advisory services on a fee basis. Mercer Advisors’ annual investment advisory fee includes investment advisory services, and to the extent specifically agreed to by the client and in an applicable agreement, financial planning, and other related services (e.g., tax, estate planning, etc.). If the client requires extraordinary planning and/or consultation services (to be determined in the sole discretion of Mercer Advisors), Mercer Advisors can, subject to the relevant client agreement(s), determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written notice to the client. Before engaging Mercer Advisors to provide investment advisory services, clients enter into a client agreement(s) with Mercer Advisors setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the fee that is due from the client. In addition, if engaging in asset management services, the client must also enter into a separate custodial/clearing agreement with a designated broker-dealer/custodian. Mercer Advisors will ascertain each client’s investment objective(s) and then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated, Mercer Advisors thereafter provides ongoing monitoring of the account(s). Mercer Advisors generally require the client(s) to grant our 4  firm discretionary authority to manage their account(s). Discretionary authorization allows Mercer Advisors to determine the specific securities to be purchased or sold for your account without the client’s prior consent. Mercer Advisors has a fiduciary duty to provide services consistent with the client’s best interest. During client’s initial onboarding with the firm, our intention is to evaluate the current portfolio, determine the client’s specific financial planning goals, determine the investment objective, and evaluate other relevant information to develop your investment plan. Please Note: Although client's assets may not be fully invested in agreed upon plan or investment objective during this transition period advisory fees will still be charged by Mercer Advisors on all assets (including assets not yet invested) as set forth in the client’s agreement. Mercer Advisors reviews client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, market conditions, asset class or style drift, account additions/withdrawals, and/or a change in the client’s investment objective, financial position, or tax situation. Based upon these factors, it is not uncommon that an extended period of time will pass where Mercer Advisors determines that changes to a client’s portfolio are neither necessary nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. New clients undergo a review of their current assets and investment objectives. As indicated above, during this analysis and transition period, assets may not be fully invested according to the designated investment objective. However, as also indicated above, advisory fees will still be charged by Mercer Advisors on all assets (including assets not invested) as set forth in the client’s agreement. Pooled Retirement Plans Mercer Advisors provides both discretionary and non-discretionary investment advisory services to ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective designated by the Plan trustees. In such engagements, Mercer Advisors will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). Mercer Advisors will generally provide annual fee for services at a basis point or flat fee rate per the terms and conditions of a client agreement between the Plan and the Firm. Participant Directed Retirement Plans Mercer Advisors also provides investment management services, investment advisory, and consulting services to participant directed retirement plans per the terms and conditions of a client agreement between Mercer Advisors and the plan. For such engagements, Mercer Advisors shall assist the Plan sponsor with the selection of a diversified menu of investment options from which Plan participants shall make their respective investment choices (this can include investment strategies devised and managed by Mercer Advisors), and, to the extent engaged to do so, can also provide corresponding education to assist the participants with their decision-making process. Mercer Advisors can also provide non-discretionary advisory services to ERISA retirement plans whereby the firm provides the Plan Sponsor and the Plan with the recommended diversified investment options for the Plan from which Plan participants can choose. If allowed, Mercer Advisors can also create specific asset allocation models (the “Models”) comprised of any and/or all the designated investment alternatives. When Mercer Advisors is providing non-discretionary advisory services, the Plan Sponsor maintains absolute discretion as to whether to accept any of the Adviser’s recommendations, including the Models. 5  Client Retiremen t Plan Assets and Rollover 401(k) plan. If requested to do so, Mercer Advisors can provide investment advisory services related to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such an event, Mercer Advisors shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Mercer Advisors’ ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. Mercer Advisors will not receive any communications from the Plan Sponsor or custodian, and it will remain the client’s exclusive obligation to notify Mercer Advisors of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by Mercer Advisors to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for the purpose of calculating advisory fees. It is the client’s exclusive obligation to notify Mercer Advisors of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by Mercer Advisors to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for the purposes of Mercer Advisors calculating its advisory fee. Mercer Advisors can also provide non-discretionary advisory services to ERISA retirement plans whereby the firm provides the Plan Sponsor and the Plan with the recommended diversified investment options for the Plan from which Plan participants can choose. Mercer Advisors uses Account Bridge, a service platform offered through a third-party vendor, to view and advise on client assets. Plan participants who wish to opt into Account Bridge will pay a wealth management fee that is separate from fees under the agreement between the plan sponsor and Mercer Advisors. The Plan does not pay an additional fee when their participants choose to engage Mercer Advisors for Account Bridge services. Participants must enter into a separate agreement to utilize Account Bridge services. See additional disclosure under Item 10- Financial Industry Activities and Affiliations. Retirement Rollovers A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Mercer Advisors recommends that a client roll over their retirement plan assets into an account to be managed by Mercer Advisors, such a recommendation creates a conflict of interest if Mercer Advisors will earn new (or increase its current) compensation because of the rollover. If Mercer Advisors provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Mercer Advisors is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by Mercer Advisors, whether it is from an employer’s plan or an existing IRA. Charitable and Non-Profit Organizations Mercer Advisors offers investment management and planning for charities and non-profits. In addition to investment management, the organization can also engage Mercer Advisors for: • Working with non-profit boards on investment policy statements and asset allocation strategy; 6  • Planning for grants and other distributions; • Donor education; • Spending policy, analysis Board education, particularly with respect to the fiduciary obligations of all parties; and/or • Analysis of appropriate portfolio approaches, including environmental, social, and corporate governance considerations. Investment Strategies Mercer Advisors seeks to build portfolios that are diversified across and within major global asset classes. Mercer Advisors’ investment strategies incorporate, as appropriate: • Strategically weighted investments designed to isolate, capture, and compound incremental return from academically validated factors including value, size, momentum, high profitability, quality, low- beta, dividend yield, term, and credit factors. • Broad asset class and multi-factor diversification help diversify risk. • Where possible, we utilize low expense ratio vehicles such as ETFs, index funds, third party SMAs, direct • index strategies, and institutional funds. Interval funds or private funds to invest in private asset classes such as private equity, private credit, real estate, real assets, infrastructure, or hedge fund strategies. • Regular rebalancing to maintain a targeted risk/return profile. Primarily through Orion Advisor Services, Inc. (“Orion”), unaffiliated registered investment advisers that offers various services to independent investment advisers such as Mercer Advisors, we have access to a range of fee-based investment offerings, research and due diligence on asset managers and funds, flexible online reporting on client accounts, and automation of essential back-office functions. Through Orion, we utilize a web-based platform to construct and rebalance client portfolios. For various reasons, including embedded taxable gains and/or limited liquidity, clients transferred to Mercer Advisors from acquired firms may continue to maintain investment holdings, strategies, and managers acquired prior to their Mercer Advisors engagement. It is Mercer Advisors’ general intention to eventually transition such assets to appropriate Mercer Advisors offered investments and/or investment strategies. Investment Programs and Strategies Market Series Program • Globally diversified asset allocation portfolios are designed to provide broad, global asset class diversification by using passive/index focused strategies. • A flexible approach to portfolio implementation allows for the use of any combination of approved, low- cost index mutual funds, index ETFs, or index-oriented Separate Account solutions (including direct indexing strategies and/or technologies). • Tax-management solutions are available for clients with low-basis positions. • A broad range of risk-based and asset class-specific allocations are available. 7  Multifactor Series Program • Globally diversified asset allocation portfolios are designed to provide broad global asset class diversification combined with tilts to academically identified factors such as value, profitability, quality, and momentum (among others). • A flexible approach to portfolio implementation allows for the use of any combination of approved mutual funds, ETFs, or separate account solutions. • As appropriate, it can include allocations to interval funds or private funds providing access to various private markets asset classes or alternatives strategies. • Tax-management solutions are available for clients with low-basis legacy positions. • A broad range of risk-based and asset class-specific allocations are available. Income Series Program • Globally diversified asset allocation portfolios are designed to provide broad global asset class diversification combined with an emphasis on income-oriented asset classes such as dividend-paying equities and non-investment grade bonds (among others). • A flexible approach to portfolio implementation allows for the use of any combination of approved mutual funds, ETFs, or separate account solutions. • As appropriate, it can include allocations to interval funds or private funds providing access to various private markets asset classes or alternatives strategies. • Tax-management solutions are available for clients with low-basis positions. • A broad range of risk-based and asset class-specific allocations are available. Separately Managed Account (SMA) Strategies Mercer Advisors can allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated Independent Managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager shall have day-to-day responsibility for the active discretionary management of the allocated assets. Mercer Advisors shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Factors Mercer Advisors can consider in recommending an Independent Manager include the client’s designated investment objective(s), management style, performance, reputation, reporting, pricing, and research. The fee paid to the selected managers will be in addition to the advisory fees paid to Mercer Advisors. The fee charged by the manager, terms of payment, and termination of service, is determined by the manager. Mercer Advisors provides clients (working through their advisor) the opportunity to invest, as appropriate, in any number of approved Separately Managed Accounts (SMA) strategies. • SMA solutions are available for equities, fixed income (both taxable and tax-exempt), real estate, MLPs, preferred stocks, custom options strategies, and leveraged strategies. • Most approved SMAs are also UMA-compatible, allowing for their use in combination with other SMAs, mutual funds, and ETFs within a single account. Please Note: The investment management fee charged by the Separate Account Manager[s] is separate from, and in addition to, Mercer Advisors’ investment advisory fee disclosed at Item 5 below. 8  Mercer Advisors provides clients—working through their advisor—the opportunity to build, as appropriate, blended portfolios using any combination of approved asset category strategies, including separately managed account strategies. In doing so, advisors work directly with the firm’s Portfolio Consulting Group (“PCG”) to build these solutions uniquely tailored to clients’ household goals, objectives, risk tolerances, and constraints. Annuities Mercer Advisors offers access to advisory variable annuities. The investment selections for the variable annuities are limited to the choices offered through the specific products. Information specific to each annuity, including features, expenses, and investment options, is found in the annuities’ prospectus and application documents. Mercer Advisors provides initial and ongoing advisory services regarding the allocation among, and monitoring of, the investment choices within the variable annuity product. Unless expressly indicated by Mercer Advisors to the contrary, in writing, the client’s variable annuity assets shall be included as assets under management for the purposes of Mercer Advisors calculating its advisory fee. Mercer Advisors does not receive commissions, insurance compensation, revenue-sharing, or any other form of compensation from the purchase, sale, or servicing of advisory annuity products, other than the advisory fee charged to the client. Private Investments Private investments can add value to the portfolios of qualified high-net-worth clients. Mercer Advisors can recommend certain private investments for use as part of a diversified, Mercer Advisors-managed investment strategy. These investments carry risks and are designed for investors that meet qualified purchaser, qualified client, or accredited investor requirements as defined by the SEC. Subscribing to a privately offered investment is a legal contract that is enforceable by the fund sponsor. Clients should take their capital commitments seriously. Private investments are not liquid and cannot be readily sold or converted to cash or other securities. Clients should ensure they have adequate liquidity before choosing to invest. See additional important disclosure regarding Affiliated and Unaffiliated Private Investment Funds in the Important Information Regarding the Advisor Business section below. Other Services Financial Planning Services and Consulting Services Mercer Advisors can provide financial planning and/or consulting services (including investment and non- investment related matters, including estate planning, insurance planning, divorce planning, etc.). The scope of this work will be mutually agreed to. Financial planning or consulting fees are negotiable as described in Item-5 Fees and Compensation. Depending on the types of financial planning services requested, the client may be required to pay a separate fee in addition to the fees paid to Mercer Advisors for investment advisory services, per the client’s agreement. Mercer Advisors provides certain clients with access to an online platform hosted by eMoney Advisor, LLC (“eMoney”). The eMoney platform allows a client to view their complete net worth statement, including those assets that Mercer Advisors does not manage (the “Excluded Assets”). Mercer Advisors does not provide investment management, monitoring, or implementation services for Excluded Assets. The client can choose to engage Mercer Advisors to manage some or all Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Mercer Advisors and the client. 9  The eMoney platform also provides access to other types of information and/or reports, including financial planning concepts. The generated information and/or reports are provided for educational purposes only, and the client should not rely on it as the primary basis for insurance, investment, financial, or tax planning decisions. The generated report is not a recommendation of any investment strategy or transaction, rather it is a tool for Mercer Advisors and the client to collaboratively: (i) confirm the accuracy of the information on the client’s risk tolerance, investment objectives and other personal and financial information, and (ii) solicit the client’s input and feedback to refine the approach for the client’s financial future. Mercer Advisors shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions available on the eMoney platform without Mercer Advisors’ assistance or oversight. Wealth Solutions The goal for many high-net-worth families is to maintain and enhance their family legacy over multiple generations. Centralized wealth management is fundamental to this long-term wealth preservation objective. The Mercer Advisors Wealth Solutions Team offers cohesive personalized solutions designed to help grow, protect, and transfer wealth across generations. Estate Planning services comprise complete estate planning review; extensive tax management, including exploration of the potential tax gaps between client intentions, existing plans, and ever-changing tax landscape; fraud protection for personal, business, and entity interests, and long-term care insurance analysis and recommendation. Mercer Advisors’ team integrates a variety of sophisticated estate planning tools, allowing for the strategic and purposeful distribution of family wealth across generations, as directed by each client’s family vision. Please Note: Mercer Advisors is not a law firm; it does not prepare estate planning documents, and no portion of its services should be construed as legal advice or services. See disclosures regarding ASLG and Mercer Advisors Tax Services LLC below. Estate Planning Mercer Advisors offers clients attorney led estate planning document preparation and other legal services through the law firm Advanced Services Law Group, Inc. (“ASLG”). Estate Planning Strategists employed by Mercer Advisors in our Estate Planning group separately act as Counsel with ASLG to provide these legal services to clients that specifically engage ASLG for such services. Although we offer clients the use of services by ASLG, clients are never obligated or required to use such services. The services of Mercer Advisors and ASLG are separate and distinct from one another, each with a separate agreement and compensation arrangement for services rendered. There is no common ownership between Mercer Advisors and ASLG. Tax Planning and Preparation Mercer Advisors offers a proactive tax planning service through an affiliate, Mercer Advisors Tax Services, LLC (“MATS”). Tax specialists can assist clients at the beginning of the year to create and implement a customized tax plan that helps minimize tax liability throughout the year. As the year progresses, tax specialists can continue to analyze and support clients’ tax needs to maintain a well-organized tax plan. Mercer Advisors’ tax specialists can help forecast future client needs to implement long-term strategies aimed at helping reduce client tax liability in years to come. Mercer Advisors offers tax preparation services through an affiliated entity, Mercer Advisors Tax Services, LLC (“MATS”). 10  Clients needing tax preparation may utilize the team of tax professionals and CPAs but are not obligated to do so. Please Note: Mercer Advisors is not a certified public accounting (CPA) firm. The tax services provided by Mercer Advisors Tax Services, LLC are not public accounting services, and Mercer Advisors Tax Services, LLC does not provide such public accounting services. If you choose to engage Mercer Advisors Tax Services, LLC for either tax planning or tax preparation services you will typically enter into a separate agreement and pay a separate fee, in each case, in addition to the fees you pay to Mercer advisors for investment advisory or other services. Please Note Conflict of Interest: The recommendation that a client considers utilizing MATS’ services presents a conflict of interest. Certain of our advisory personnel and/or our parent company are affiliated, through common ownership and/or control, with an entity that provides tax preparation, tax planning, or related tax advisory services (the “Affiliated Tax Firm”). As a result of this affiliation, we have a financial and business interest in referring clients to the Affiliated Tax Firm. This relationship creates a conflict of interest because we have an incentive to recommend the Affiliated Tax Firm based on the benefits that may accrue to our firm or its affiliates, rather than solely on the client’s needs. These benefits may include, among other things, increased revenues, shared resources, operational efficiencies, or enhanced enterprise value resulting from the use of affiliated services. No client is obligated to consider utilizing MATS. Mercer Advisors will work with the tax professional of the client’s choosing. Retirement Plan Consulting Services Mercer Advisors offers fiduciary investment management or advisory services for employer sponsored retirement plans. Mercer Advisors offers consulting services for group enrollment and participant investment education. Mercer Advisors works with external service providers (recordkeepers and third-party administrators) that provide retirement plan design, documentation, administration, and/or recordkeeping services to meet each plan’s unique objective. Divorce Services Mercer Advisors may be engaged to provide divorce planning consulting services per the terms and conditions of a separate agreement and fee (fee arrangement to be disclosed in the agreement). The objective of the service is to assist the divorcing clients, and their respective divorce counsel(s), to understand the financial implications of various financial planning scenarios related to their divorce case and settlement options. Mercer Advisors is not a law firm and does not provide legal services. No portion of its consulting services serve as a substitute for the engagement of qualified divorce legal counsel. Given that Mercer Advisors will be providing services to divorcing clients, Mercer Advisors’ engagement can present conflicts of interest, and all parties must be guided accordingly. No client is under any obligation to engage Mercer Advisors for such services. The clients are encouraged to address any prospective divorce planning engagement with their respective legal counsel. 11  Wellthy – Health Care Concierge Services Mercer Advisors has partnered with Wellthy to offer care management concierge services to clients with at least $1MM in assets under management. Wellthy is an unaffiliated third-party vendor that offers a caregiving platform (the “Platform”) to help our clients address the logistical and administrative tasks of caring for the ones they love. Costs are determined by Wellthy and no referral fees are received by Mercer Advisors for clients who choose to utilize the service. Mercer Advisors can provide the first six (6) months of the service free of charge to a qualifying client. After six months, the client can choose to continue to utilize Wellthy at a cost of $450 per care project, charged directly to the specified client account. Although Mercer Advisors recommends Wellthy service, no client is under any obligation or requirement to use the service as part of their Mercer Advisors’ relationship. The services of Mercer Advisors and Wellthy are separate and distinct from each other, each with a separate agreement and compensation arrangement for services rendered. Clients can engage Wellthy directly, independent of Mercer Advisors, and could pay more or less for Wellthy than if they engage Wellthy through Mercer Advisors. In addition, the services provided by Wellthy may be available from other vendors at a higher or lower cost than those charged by Wellthy. Mercer Advisors does not provide health care concierge service, and no portion of our services should be construed as such. Financial Consulting Certain Mercer Advisors’ clients whose existing brokerage assets (primarily commission-based variable annuities and mutual funds-the “Assets”) were previously monitored by Mercer Advisors’ investment adviser representatives in their prior separate licensed individual capacities as registered representatives of SEC registered and FINRA member broker-dealers, have transferred the Assets to Mutual Securities, Inc. (“Mutual”), a FINRA member and SEC registered broker-dealer. In conjunction with such transfer of Assets, Mercer Advisors has entered an arrangement with Mutual whereby Mutual compensates Mercer Advisors on a quarterly basis to remain available to provide advisory monitoring/consulting services to such affected clients relative to the Assets. Except for the Mutual consulting fee (which is payable to Mercer quarterly as a flat fee), neither Mercer Advisors, nor any of its representatives, will receive any separate compensation from the clients relative to the Assets. The compensation payable by Mutual to the Firm does not result in higher fees payable by the clients to Mutual. Important Information Regarding Advisory Business Values-Based Investing Limitations Values-Based Investing involves the incorporation of various considerations and limitations into the investment due diligence and portfolio construction process. Faith-based considerations, as well as Environmental, Social and Governance (“ESG”) considerations incorporate criteria/factors used in evaluating potential investments. The number of companies that fall within these acceptable mandates can be limited when compared to those that do not and could cause client portfolios to underperform broad market indices. Investors must accept these limitations, including the potential for underperformance. Correspondingly, the number of Values-Based mutual funds and exchange-traded funds are limited when compared to those that do not maintain such mandates. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Mercer Advisors), there can be no assurance that investment in these securities or funds will be profitable or prove successful. 12  Mutual and Exchange Traded Funds Mercer Advisors uses mutual funds and exchange traded funds for its client portfolios. In addition to Mercer Advisors’ investment advisory fee described below, and transaction and/or custodial fees discussed below, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Use of DFA Mutual Funds Mercer Advisors utilizes the mutual funds issued by Dimensional Fund Advisors (“DFA”). DFA funds are generally only available through registered investment advisers approved by DFA. Thus, if the client were to terminate Mercer Advisors services, and transition to another adviser who has not been approved by DFA to utilize DFA funds, restrictions regarding additional purchases of, or reallocation among other DFA funds, will generally apply. Long/Short Equity Strategy Mercer Advisors can allocate client assets to an unaffiliated separate account manager (the “LS Manager”) that employs a long/short equity investment strategy (the “LS Strategy”) whereby both long and short positions will be maintained within the same portfolio. Long-short equity is an investment strategy that seeks to take a long position in underpriced stocks while selling short, overpriced shares. Please Note: There can be no assurance that the LS Strategy will prove successful. Please Also Note: The LS Strategy employs margin. The use of margin permits the LS Manager to borrow money to buy securities. The broker/custodian for the LS Strategy account charges the account interest for the right to borrow money and uses the account securities as collateral. By using borrowed funds, the customer is employing leverage that will amplify both account gains and losses. To the extent that the LS Strategy employs margin, Mercer Advisors (and the LS Manager) will include the entire market value of the account when computing their respective advisory fees. When fees are based upon a higher-margined account value, both the LS Manager and Mercer Advisors will earn correspondingly higher advisory fee. As a result, the potential for conflict of interest arises since Mercer Advisors has an economic incentive to recommend that the client invest in, (and once invested, have a disincentive to recommend that the client terminate) the LS Strategy. Two Separate Strategy Advisory Fees. The client will incur separate advisory fees for the LS Manager and Mercer Advisors. Opt-Out: A client can advise Mercer Advisors, in writing, not to allocate any assets to the Strategy. Interval Funds- Risk and Limitations Where appropriate, Mercer Advisors may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time period outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender 13  shares when or in the amount desired. There can also be situations where an interval fund has a limited capacity to repurchase shares and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an interval fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Thus, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. Rather, like any type of investment, an interval fund, at any specific point in time, or over any specific time period, can suffer losses, including the potential for substantial losses. In light of these enhanced risks, a client may direct Mercer Global Advisors Inc., in writing, not to purchase interval funds for the client’s account. Cash Positions Mercer Advisors continues to treat cash as an asset class. As such, unless determined to the contrary by Mercer Advisors, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for the purpose of calculating Mercer Advisors’ advisory fee. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Mercer Advisors’ advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts Certain account custodians can require that cash proceeds from account transactions or new deposits be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. Indexing Mercer Advisors can employ an investment strategy referred to as Direct Indexing, a strategy that seeks to replicate an existing stock index, like the S&P 500, through direct ownership of individual stocks. Direct Indexing allows for portfolio customization and adjusting exposure to specific stocks or sectors. It can also provide a tax-loss harvesting benefit, which may help reduce tax bills by offsetting capital gains with losses from other positions. Mercer advisors can utilize the sub-advisory services provided by Orion Portfolio Solutions, a subsidiary of Orion Advisor Solutions, Inc. (together “Orion”) to offer direct indexing solutions. Orion’s sub-advisory fee is paid by the client in addition to the Mercer Advisors advisory fee. Please Note: Conflicts of Interest Mercer Advisors can qualify to receive Orion Preferred Advantage Pricing based upon total net revenues earned by Orion from Mercer Advisors’ clients. As a result, the amount payable by Mercer Advisors for certain other Orion-provided services is reduced if net revenues earned by Orion from Mercer Advisors’ clients meet certain quarterly thresholds. In addition, one of Mercer Advisors’ equity owners, Genstar Capital Partners, LLC, manages one or more private equity funds with ownership interests in Orion. As the result of the above arrangement/relationships, Mercer Advisors has a conflict of interest in utilizing Orion’s sub-advisory services because the Firm has an economic incentive to allocate assets to Orion 14  Margin Accounts-Risks and Conflict of Interest As indicated above and below on this Brochure, Mercer Advisors can recommend the use of margin for investment purposes. As also indicated above and below, should a client determine to use margin, Mercer Advisors includes the market value of the margined assets when computing its advisory fee, This creates a conflict of interest (because Mercer Advisors has an economic incentive to recommend that the client utilize and/or continue to utilize margin due to greater advisory fees earned on the higher margined account value). Please Note: The leverage created by using margin can cause amplified and significant adverse financial consequences in the event of a market correction. Unaffiliated Private Investment Funds Mercer Advisors provides investment advice regarding unaffiliated private investment funds. Mercer Advisors, on a non-discretionary basis, recommends that certain qualified clients consider an investment in private investment funds, the description of which (the terms, conditions, risks, conflicts, conflicts, and fees, including incentive compensation) is set forth in the fund’s offering documents. Private investment funds generally involve various risk factors, including, but are not limited to the potential for complete loss of principal, liquidity constraints, and lack of transparency. A more complete discussion of these risks is set forth in each fund’s offering documents, which will be provided to each client for review and consideration, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Mercer Advisors’ role relative to unaffiliated private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become an unaffiliated private fund investor, the market value of the private fund(s) shall be included as part of “assets under management” for the purposes of Mercer Advisors calculating its investment advisory fee. Mercer Advisors’ fee shall be in addition to the fund’s fees. Mercer Advisors’ clients are under no obligation to consider or make an investment in any private investment fund(s). Affiliated Private Investment Funds Mercer Advisors recommends that certain qualified clients consider an investment in private investment funds. In addition to unaffiliated private investment funds, as disclosed above, Mercer Advisors can also recommend that a client consider investing in private investment funds formed and managed by entities affiliated with Mercer Advisors (i.e. the Aspen Partner Funds). As also disclosed below, private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints, and lack of transparency. A more complete discussion of these risks is set forth in each fund’s offering documents, which will be provided to each client for review and consideration, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. A conflict of interest exists with affiliated funds because Mercer Advisors, MAPAM, and their parent company are under common ownership, and the continued management, growth, or performance of these affiliated funds can provide an indirect economic benefit to the parent company and its shareholders (including employee shareholders). These above conflicts create a risk that Mercer Advisors could have an incentive to retain or recommend affiliated funds rather than unaffiliated alternatives. Mercer Advisors has implemented measures intended to mitigate (but do not eliminate) the above conflicts and risks. Advisors do not receive additional incentives or fees to place clients into affiliated funds. Private funds are 15  included in assets under management for billing purposes the same as any other investment a client might include in their portfolio. Clients should understand that Mercer Advisors and its affiliates have an interest in the success of affiliated funds. Clients are not required to invest in affiliated or unaffiliated funds and may select alternative investments that are consistent with their investment objectives and risk tolerance. Aspen Partners Funds As also discussed in Item 10 below (Other Financial Industry Activities and Affiliations), Mercer Advisors has an affiliated registered investment adviser, Mercer Advisors Private Asset Management (“MAPAM”), which was formed to develop and manage a series of private investment funds offered through a unified technology platform the “Aspen Partners platform”, including the Aspen Partners fund family. These funds are designed to meet the investment objectives of Mercer Advisors’ qualified purchaser clients. Mercer Advisors’ clients are not charged a management fee by the Aspen Partners funds while they are clients of Mercer Advisors, and the fund investment is included in the assets under management for their Mercer Advisors’ managed portfolio. However, if a client invested in an Aspen Partners fund ceases to be a Mercer Advisors client, the fee structure of the applicable fund will change, and the former client will be charged a management fee by the fund, which will be deducted from the client’s capital account. This fee structure, and the circumstances under which it applies, are disclosed in the fund’s subscription agreement and offering documents. As referenced above, MAPAM serves as the investment manager to the Aspen Funds (the “Funds”). The Funds obtain certain “platform services” through its engagement of Opto Investments, Inc. (“Opto”), a platform provider serving the private fund industry. Opto charges the Funds for the platform services provided. Fund investors incur a Fund administrative fee (“platform fee”) covering third-party services, which is payable by the Fund, currently capped at 19 basis points of aggregate capital commitments. The remainder of the platform fee is absorbed by MAPAM’s parent company, Mercer Advisors Inc. Mercer Advisors introduces certain of its qualified clients to the Funds. Please Note: Conflict of Interest: Opto and Mercer Advisors Inc. (“Parent”) (which is also the parent company of Mercer Advisors) have entered into a revenue sharing arrangement whereby Opto will share with the Parent a portion of the fees it earns from certain of its engagements with unaffiliated third-party funds. MAPAM, the Funds, Mercer Advisors, and the Parent have a conflict of interest resulting from the economic inventive provided by the Opto revenue sharing arrangement. The Regis Funds As part of Mercer Advisors Inc. (“Parent”) acquisition of Regis Management Company LLC, MAPAM GP I, LLC, an affiliate of Mercer Advisors, was appointed as the General Partner (“GP”) for the Regis Funds. The Regis Funds are closed to new investors. There are a limited number of current Mercer Advisors advisory clients who are investors in the Regis Funds. Other Funds Managed by MAPAM From time to time, Mercer Advisors or its affiliates may acquire or assume advisory responsibility for funds managed by MAPAM that have existing investors who became invested prior to becoming clients of Mercer Advisors. Investment decisions involving acquired or legacy affiliated funds are subject to oversight by an investment committee, which reviews investment suitability and portfolio construction without regard to affiliation. 16  In addition, certain acquired or legacy funds advised by MAPAM can charge management fees or other fund- level fees, as disclosed in the applicable fund offering documents. These arrangements create a conflict of interest that Mercer Advisors could have an economic incentive to retain or recommend affiliated funds rather than unaffiliated alternatives. Mercer Advisors’ clients are under absolutely no obligation to consider or make an investment in any affiliated or unaffiliated private investment fund. Given the conflicts of interest presented relative to affiliated funds, Mercer Advisors clients should consider seeking advice from independent professionals (i.e., attorney, accountant, adviser, etc.) of their choosing prior to becoming an affiliated fund investor. Private Investments- Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity, constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation- Mercer Advisors uses the most recent valuation as reported by the investment sponsor or fund manager for client portfolio reporting. Reporting from private investment funds generally lags by one to three months. Because of the nature of private investment reporting, the current value of an investor’s holdings could be more or less than the value reflected on the portfolio report. Unless otherwise indicated, Mercer Advisors shall calculate its advisory fee based upon the most recent value provided by the investment sponsor or fund manager. Separate Account Managers As indicated above, Mercer Advisors can allocate a portion of the client’s investment assets among unaffiliated Independent Manager(s) in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager(s) shall have day-to-day responsibility for the active discretionary management of the allocated assets. Mercer Advisors shall continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation, and client investment objectives. Factors that Mercer Advisors shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. Please Note: The investment management fee charged by the Independent Manager[s] is separate from, and in addition to, Mercer Advisors’ investment advisory fee disclosed at Item 5 below. The payment authority granted to the custodian to debit the client’s account for advisory fees shall (to the extent applicable) extend to, and be inclusive of, the fees payable to unaffiliated separate account managers engaged by Mercer to manage a portion of the client’s assets. Clients of firms acquired through an acquisition could be invested in a proprietary SMA strategy administered by the acquired firm. At some point after acquisition, it is Mercer Advisors’ general intention to transition such acquired firm clients to corresponding appropriate Mercer offered investments and/or investment strategies. 17  Reporting Services Mercer Advisors can also provide account reporting services, which can incorporate client investment assets that are not part of the assets that Mercer Advisors manages (the “Excluded Assets”). Unless agreed to otherwise, in writing, the client and/or his/her/its other advisors that maintain trading authority, and not Mercer Advisors, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless also agreed to otherwise, in writing, Mercer Advisors does not provide investment management, monitoring or implementation services for the Excluded Assets. The client can engage Mercer Advisors to provide investment management services for the Excluded Assets pursuant to the terms and conditions of the agreement between Mercer Advisors and the client. Non-Discretionary Service Limitations Clients that determine to engage Mercer Advisors on a non-discretionary investment advisory basis must be willing to accept that Mercer Advisors cannot affect any account transactions without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that Mercer Advisors would like to make a transaction for a client’s account, and client is unavailable, Mercer Advisors will be unable to affect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Client’s Obligation In performing our services, Mercer Advisors shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains each client’s responsibility to promptly notify Mercer Advisors if there is ever any change in the client’s financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services. Investment Risk Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Mercer Advisors) will be profitable or equal any specific performance level(s). Limitations of Financial Planning and Non-Investment Consulting/Implementation Services To the extent agreed to by the client, Mercer Advisors will generally provide financial planning and related consulting services regarding non-investment-related matters, such as tax and estate planning, insurance, etc. Mercer Advisors may provide such consulting services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under management, special projects, extraordinary events or circumstances, stand-alone planning engagements, etc. for which Firm charges a separate or additional fee). Please Note: Mercer Advisors believes that it is important for the client to address financial planning issues on an ongoing basis. Mercer Advisors’ advisory fee, as set forth at Item 5 below, will remain the same even if the client determines not to address financial planning issues with Mercer Advisors. Please Also Note: Mercer Advisors does not serve as an attorney, accountant, or insurance agent, and no portion of our services should be construed as such. Accordingly, Mercer Advisors does not prepare legal documents or sell insurance products. We will recommend the services of other professionals for non-investment implementation purposes (e.g., attorneys, accountants, insurance, etc.), including Mercer Advisors’ affiliates, 18  Mercer Advisors Insurance Services, LLC (“Insurance” ) and Heim, Young & Associates, Inc. (“HYA”), in their separate capacities as licensed insurance agencies, and HYA’s separate capacity as an SEC registered and FINRA Member broker-dealer. In such capacities, Insurance and/or HYA can offer both insurance and securities- related advice and products on a commission compensation basis. Certain Mercer Advisors’ representatives also serve as licensed agents and registered representatives of Insurance and HYA. In addition, some Mercer Advisors representatives offer insurance products on a commission compensation basis in their separate individual licensed capacities independent of Insurance or HYA, and as registered representatives of a broker- dealer other than HYA. The commission compensation earned by Insurance and/or HYA and its agents/representatives is separate from, and in addition to, Mercer Advisors investment advisory fee. Please Note: Conflict of Interest The recommendation by a Mercer Advisors representative that a client consider the purchase of an insurance product from Insurance or HYA presents a conflict of interest, as the potential receipt of an insurance or securities commission compensation by Insurance or HYA and its agent(s) provides an incentive for Mercer Advisors representatives to recommend products based on compensation to be received by its affiliated entity and representative rather than on a particular client’s needs. No client is under any obligation to purchase any insurance product from a Mercer Advisors’ affiliated entity or from an employee of Mercer Advisors. Clients can purchase insurance and securities products through other, non-affiliated insurance agencies, agents, broker-dealers, and registered representatives. Mercer Advisors Tax Services, LLC (“MATS”) provides tax preparation services and various business management services. Clients obtaining the services of MATS will sign a separate engagement agreement to receive services. Tax services provided by MATS are not public accounting services, and MATS is not a CPA firm and does not provide public accounting services. Please Note Conflict of Interest: The recommendation that a client consider utilizing MATS’ services presents a conflict of interest. Certain of our advisory personnel and/or our parent company are affiliated, through common ownership and/or control, with an entity that provides tax preparation, tax planning, or related tax advisory services (the “Affiliated Tax Firm”). As a result of this affiliation, we have a financial and business interest in referring clients to the Affiliated Tax Firm. This relationship creates a conflict of interest because we have an incentive to recommend the Affiliated Tax Firm based on the benefits that may accrue to our firm or its affiliates, rather than solely on the client’s needs. No client is obligated to consider utilizing MATS. Mercer Advisors will work with the tax professional of the client’s choosing. Custodian Charges-Additional Fees As discussed at Item 12 below, when requested to recommend a broker-dealer/custodian for client accounts, Mercer Advisors generally recommends that Schwab, Fidelity, Raymond James, or Goldman Sachs Custody Solutions serve as the broker-dealer/custodian for client investment management assets. Broker-dealers charge brokerage commissions, transaction, and/or other type fees for effecting certain types of securities transactions (i.e., including transaction fees for certain mutual funds, and mark-ups and mark-downs charged for fixed income transactions, etc.). The types of securities for which transaction fees, commissions, and/or other type fees (as well as the amount of those fees) shall differ depending upon the broker-dealer/custodian (while certain custodians, including Schwab, Fidelity, and Raymond James, and Goldman Sachs generally do not currently charge fees on individual equity transactions (including ETFs), others do. 19  Please Note: There can be no assurance that any of these custodians will not change their transaction fee pricing in the future. These fees/charges are in addition to Mercer Advisors’ investment advisory fee in Item 5 below. Mercer Advisors does not receive any portion of these fees/charges. Portfolio Activity Mercer Advisors has a fiduciary duty to provide services consistent with the client’s best interest. Mercer Advisors will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Mercer Advisors determines that changes to a client’s portfolio are neither necessary, nor prudent. Clients remain subject to the fees described in Item 5 below during periods of account inactivity. Account Bridge: Mercer Advisors Account Bridge service uses an investment platform made available by Pontera Solutions, Inc. (“Pontera”), a third-party online platform, to assist with management of clients’ “held-away” accounts, including 401(k)s, 403(b)s, and 529 education savings plans. The Pontera platform permits advisers to manage held-away assets without having to reflect that it has custody of such assets on Part 1 of Form ADV. The advisory fee charged by Mercer Advisors for the management of held-away assets is established in the client’s agreement. Pontera charges Mercer Advisors an annual fee based upon the percentage of assets managed in the held-away accounts. Other than Mercer Advisors’ advisory fee, clients do not pay any additional fee to Pontera or to Mercer Advisors in connection with the use of the Pontera platform. Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, Mercer Advisors will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Cryptocurrency is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated, and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, Mercer Advisors will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. Please Note: Mercer Advisors does not recommend or advocate the purchase of or investment in, cryptocurrencies. Mercer Advisors considers such an investment to be speculative. Please Also Note: Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility, and complete loss of principal. Acquired Advisory Firms Mercer actively acquires other advisory firms. In connection with such acquisitions, we expect that the acquired advisory firm’s client advisory agreements (“Assigned Agreements”) will be assigned to us. Clients of the acquired firms (“Acquired Clients”) will remain subject to the terms of their respective Assigned Agreements, which we expect will include investment programs, models, or strategies and fees (which could be higher than Mercer Advisors standard fee schedule at Item 5 below) that differ from those offered by us for a period of time. Acquired clients will be transitioned to Mercer Advisors’ standard platforms for investment programs, models, strategies, service offerings, and fees schedule over time. We will work with the client to transition their investment advisory services, strategies, and programs to those offered by us and described in this Brochure. See additional Acquired Advisory Firms disclosure at Item 5 below. 20  ITEM 5 – FEES AND COMPENSATION Mercer Advisors reserves the right to negotiate investment management fee arrangements with prospective and existing clients. Mercer Advisors can agree to make exceptions to its standard fee schedule on a case-by- case basis at its discretion. Investment management and other fees assessed (including without limitation those associated with financial planning, tax, estate planning and other services) vary from client to client depending upon a number of factors, including the amount of assets under management, the nature of the assets, the type of analysis required to manage the account(s), the level of service required by the client, the longevity of the client relationship with Mercer Advisors, and other factors. Please see additional disclosures below. Mercer Advisors collects fees monthly. Clients authorize Mercer Advisors to debit fees directly from the clients’ account(s). For a limited number of accounts where the firm is unable to collect fees directly from client accounts, Mercer Advisors will bill the client directly. For limited situations, services, or payments due, clients may be able to pay via credit card. Management fees shall not be prorated for each capital contribution and/or withdrawal made during the applicable calendar month, unless otherwise agreed upon in writing. Accounts initiated or terminated during a calendar month will be assessed as a prorated fee. Upon termination of any account, any prepaid, unearned fees will be refunded promptly; any earned, unpaid fees will be due and payable. For firms acquired by Mercer Advisors, generally the client will remain on their current fee schedule, billing calculation methodology and payment method until notice of a change in the fee or billing practice is provided to the client. Investment Management Fees Mercer Advisors believes that individual and family clients can benefit by looking at their financial life holistically – blending investment, financial, tax and estate planning. The firm offers different service options to help meet the needs of our clients. Please Note: Not all services are included with each client offering. Clients choose the service level that they prefer. Please reference important information regarding fees later in this section. For clients who do not desire a financial plan and a broader set of services, we offer a simplified Guided Investing solution. Guided Investing fees start at 1.10% annually for the first $1 million in managed assets and have a lower minimum fee of $1,200 annually. Guided investing offers investment management services only. Ancillary services such as financial planning, estate planning, etc. are not included with Guided Investing. Wealth Path- Standard Annual Fee Schedule WEALTH PATH TIERED ADVISORY FEES-PERCENTAGE OF ASSETS MANAGED First $1,000,000 1.30% Next $1,000,000 1.00% Minimum Fee $6,000 21  Custom Wealth– Standard Annual Fee Schedule WEALTH MANAGEMENT TIERED ADVISORY FEES-PERCENTAGE OF ASSETS MANAGED First $1,000,000 1.10% Next $1,000,000 1.00% Next $3,000,000 0.90% Next $5,000,000 0.75% Over $10,000,000 0.50% Minimum Fee $15,000 Ascend Group– Standard Annual Fee Schedule ASCEND GROUP TIERED ADVISORY FEES-PERCENTAGE OF ASSETS MANAGED First $1,000,000 1.10% Next $1,000,000 1.00% Next $3,000,000 0.90% Next $5,000,000 0.75% Over $10,000,000 0.50% $75,000 Minimum Fee Clients with greater than $25 million in managed assets may be eligible for our Regis ultra-high net worth service offering. The Regis offering allows customized family office services for ultra-high net worth clients. Regis services vary depending on the client’s needs. Fees are disclosed on the individual client agreements, and the minimum advisory fee for the service offering is $150,000 annually. Additional sub-advisory fees apply when using Separately Managed Account (SMA) strategies. Funds and investments are held by third party custodians and will incur fees for certain transactions. Please refer to your agreement with the custodian for additional information. Investment Management fees will vary based on assets under management. Fees are charged and calculated monthly, in arrears based on the average daily balance. Investment Management fees can change from time to time with advanced notice to existing clients. Please Note: Certain accounts utilize third-party aggregation tools which rely on the account owner to maintain the connection to the Mercer Advisors’ systems via entry of a login name and password. These data feeds can break from time to time. When we discover a broken data feed, we will notify the client to reconnect. In instances when the connection remains broken at the time the monthly fee is calculated we will rely on the most recently utilized account value for billing purposes. The resulting fee calculation may be higher or lower than if the data feed had remained connected. If the connection continues to remain inactive for an extended period, we may remove that account from the portfolio until such time as the account can be reconnected. Exceptions: Certain clients maintain assets that deviate from the above billing method for various reasons. Such exceptions will be identified and communicated to the client, and Mercer Advisors will review to determine if an 22  exception disadvantages the client, and if it does, how Mercer Advisors will seek to address/rectify such disadvantage (to the extent reasonably possible given the nature of the exception). Mercer Advisors currently recommends advisory variable annuities to its clients when appropriate. In addition to Mercer Advisors’ fees, clients incur certain charges in connection with annuity investments including, but not limited to, variable annuity subaccount management fees, mortality expenses, and administrative expenses. Mercer Advisors manages a client’s asset allocations within the annuity using the product’s available subaccounts. Clients provide Mercer Advisors authorization to do so on the client's annuity application. To understand the specific fees and charges, clients should carefully review the product prospectus. Retirement Plan Services: Standard Fee Schedule Fees will vary depending on the type of plan and/or services the client chooses to engage. See disclosure in Item 4 above. Foundations and Endowments Fees will vary depending on the type of plan or services the client chooses to engage. Employee Services Mercer Advisors provides portfolio management services to certain Mercer Advisors principals, employees, and their family members for fee rates that are lower than the rates generally available to other clients. Investment Advisory Other Fees • Clients invested in institutional mutual funds, accumulation units, exchange traded funds (ETFs), and separate accounts pay a management fee, administration fee, and other expenses, in addition to Mercer Advisors’ advisory fees. Furthermore, certain clients pay custody or trustee fees. • Mercer Advisors utilizes the services of third-party managers and/or sub-advisors to provide investment advisory services – it is important to note that these managers will charge a separate and additional fee for their services. party service providers, including recordkeepers and third party • Plan Sponsors may engage third ‑ ‑ ‑ administrators, to support the operation and administration of their retirement plans. The services of these third party providers are separate from the advisory services provided by Mercer Advisors and are subject to additional fees and expenses charged directly by those providers. These fees are in addition to, and not included in, the advisory fees paid to Mercer Advisors. • Mercer Global Advisors Inc. does not receive compensation for the sale of securities to our clients. While some employees of Mercer Advisors are registered representatives of a broker-dealer (including an affiliated broker-dealer, Heim, Young & Associates, Inc.), Mercer Global Advisors Inc. is not a broker- dealer and is not compensated by way of commissions. Heim, Young & Associates, Inc., as a broker- dealer, receives commission-based compensation for the sale of securities. • Private funds charge additional fees as outlined in their subscription agreement. These fees are in addition to the investment management fee paid to Mercer Advisors. • Mercer Advisors recommends clients use Charles Schwab & Co., Inc., National Advisors Trust (“NATC”- for trust related assets), Fidelity, Raymond James, and Goldman Sachs Custody Solutions as custodians for their assets. Mercer Advisors clients who use recommended custodians receive Mercer Advisors negotiated discounted pricing. The custodians' fees charged are separate and apart from any fees charged by Mercer Advisors. 23  • There may be additional fees charged as outlined in item 4 for additional or extraordinary services as requested by the client. • Clients using Account Bridge (401K/held away assets) will pay a wealth management fee in addition to and apart from the plan sponsor fees under a separate agreement. • There may be additional fees for services provided by affiliated entities, including MATS. MAIS, MAPAM, Heim, Young and Associates, Inc, and FSC Realty, LLC. These fees are in addition to the Mercer Advisors investment management fee. account or per ‑ ‑ execution obligations. The use of a custodian’s block trading or specialized • Custodians impose additional fees in connection with certain block trades or trades that require manual handling, specialized execution support, or access to advanced trading services through their respective trading desks. When applicable, these fees are assessed by the custodian and are charged in addition to the advisory fee paid to Mercer Advisors. Such fees may be assessed on a per trade basis, depending on the custodian, the nature of the trade, and the execution method used. No portion of these block trading fees are shared by the custodian with Mercer Advisors. In determining how trades are executed, Mercer Advisors considers execution quality, costs, market conditions, and other relevant factors in fulfilling its best execution services may be appropriate notwithstanding the additional cost. ‑ Financial Planning, Wealth Solutions, Tax Planning Mercer Advisors offers financial planning and tax planning standalone services on a limited basis. Our financial planning-only service involves the advisor and client working together to review personal money management, investment planning, tax consultation, and retirement planning. In addition, the financial planning process can include aspects of money management regarding spending and saving habits, evaluation and strategies for retirement planning, evaluation and planning for education funding, insurance assessment, employee benefit analysis, and business planning. The advisor does not manage the client’s investments. The advisor offers to meet with the client to analyze their financial situation, develop recommendations, and formulate a plan for the client to implement. The typical financial planning-only agreement is invoiced quarterly in advance, and fees will vary depending on the complexity of the relationship. The fee for services is due at the time of engagement and is prorated for the remainder of the quarter in which services are rendered. Tax preparation services are also available to clients at a negotiated rate. See disclosure in Item 4 above. Estate planning consulting is included as part of our wealth management service offering as defined in the client’s investment advisory agreement. Estate planning does not include the preparation of estate documents. Mercer Advisors offers clients estate planning document preparation and other legal services either through our client-led solution powered by Estately that has no additional charge or our attorney-led solution through the Advanced Services Law Group, Inc. (“ASLG”), for an additional fee. In most cases, clients who have over $1.5 million in assets under management and who meet minimum fee requirements qualify to engage ASLG for the drafting of a foundational estate plan (consisting of a trust, will, and incapacity documents) at no additional fee. This $1.5 million threshold is at the discretion of ASLG and subject to change without notice. Additional fees may apply if clients engage for legal services performed by ASLG beyond the foundational plan. See disclosure at Item 4-Advisory Business and Item 10-Other Industry Affiliations. Advisory Services to Brokerage clients As disclosed at Item 4- Financial Consulting and Item 10- Other Industry Affiliations below, Mercer Advisors can receive an advisory fee from customers of unaffiliated broker-dealers. 24  Important Information about Fees Fee Dispersion Mercer Advisors, in its discretion, can charge a higher or lower investment advisory fee, charge a flat fee, waive its fee entirely, or charge a fee on a different interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules including fee schedules of acquired advisory firms, employees and family members, courtesy accounts, competition, negotiations with client, etc.). Please Note: As a result of the above, similarly situated clients could pay different fees. In addition, similar advisory services are available from other investment advisers for similar or lower fees. Please Note: If the client is subject to an annual minimum fee, the client could pay a higher percentage fee than referenced above. When a minimum fee applies, Client’s effective fee rate (calculated as the total advisory fee divided by assets under management) will initially be higher. As Client’s assets increase, the effective fee rate declines and will ultimately align with the standard blended rate under the applicable fee schedule once the minimum fee is no longer applicable. Margin Accounts- Risks and Conflict of Interest Mercer Advisors can recommend the use of margin for investment purposes. A margin account is a brokerage account that allows investors to borrow money to buy securities and/or for other non-investment borrowing purposes. The broker/custodian charges the investor interest for the right to borrow money and uses the securities as collateral. By using borrowed funds, the customer is employing leverage that will amplify both account gains and losses. Should a client determine to use margin, Mercer Advisors includes market value of the margined assets when computing its advisory fee thereby creating a conflict of interest (i.e., Mercer Advisors could have an economic incentive to recommend that the client utilize and/or continue to utilize margin because it can earn a higher advisory fee from the higher margined account value). Please Note: The use of margin can cause significant adverse financial consequences in the event of a market correction. Wrap Programs Services Some advisory firms acquired by Mercer Advisors utilize a fee structure that combines both management and some or all the transaction fees charged by the third-party broker-dealer (custodian). This is known as a “wrap fee”. Except for the continuation of the wrap fee arrangement pursuant to Assigned Agreements for Acquired Clients for a period post-acquisition, Mercer Advisor does not offer wrap fee programs to its clients. At some point after becoming a Mercer Advisors client, Mercer Advisors anticipates that the wrap fee program clients will be transitioned to an appropriate Mercer Advisors investment offering at no higher fee than charged under the wrap program, unless additional services will be provided. Participation in a wrap program may cost the participant more or less than purchasing such services separately. Mercer’s Advisory Fee is Separate from Program Fee; For those clients who have determined to retain a wrap fee program, Mercer Advisors’ advisory fee shall be separate from and in addition to the Program wrap fee. Continued participation in the Program will be more expensive than if the client transitions to Mercer Advisors’ standard investment offering. 25  Acquired Advisory Firms Acquired Clients who join Mercer Advisors as part of the Firm’s acquisition of an advisory firm will be subject to the fees, costs, and billing practices in effect under the Acquired Clients’ respective Assigned Agreements (which could be higher than Mercer Advisors’ standard fee schedules above) until such time as they receive a notice of change or sign a Mercer Advisors agreement. Mercer Advisors and its advisors will be compensated in accordance with such Assigned Agreements. In some instances, the fees and costs associated with some services in the Assigned Agreements will be in addition to Mercer Advisors’ advisory fee. Additionally, Mercer Advisors can provide compensation, including bonuses or other incentives, to its acquired advisory firms for the successful retention of Acquired Clients who transition to Mercer Advisors in connection with the acquisition of an advisory firm. This compensation is paid by Mercer Advisors and does not increase the advisory fees paid by the Acquired Client. The Firm and its advisors’ receipt of compensation in connection with Assigned Agreements and the retention of Acquired Clients can create a conflict of interest because it provides a financial incentive for the Firm to maintain Assigned Agreements with fees more favorable to Mercer Advisors than those described herein, and to encourage Acquired Clients to continue their advisory relationship with Mercer Advisors. ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Mercer Advisors does not utilize a performance-based fee structure given the potential conflict of interest. Mercer Advisors believes that performance-based compensation creates an incentive for an adviser to recommend an investment that carries a higher degree of risk for the client. Advisory fees are based on assets under management. ITEM 7 – TYPES OF CLIENTS Mercer Advisors provides investment advisory services to individuals, high-net-worth individuals, pension and profit-sharing plans, corporations or other business entities, charitable/non-profit organizations, foundations, trust, estates, and brokerage customers, among others. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Mercer Advisors’ Investment Philosophy Our investment philosophy is grounded in the fundamentals of Modern Portfolio Theory and is built upon many decades of peer-reviewed academic research supporting market equilibrium, the integral relationship between risk and return, and the proven efficacy of a long-term investment strategy. Our approach to portfolio construction centers on building risk-appropriate, globally diversified portfolios that are diversified both across and within major asset classes. Where appropriate, Mercer Advisors’ investment philosophy allows for the strategic use of private investments, which we believe provide diversification benefits relative to portfolios of publicly traded securities. Mutual funds, ETFs, and separate account strategies are evaluated based on the following considerations: asset class and factor styles; fees; tax efficiency; inception date; manager tenure; net assets and daily liquidity; alpha; Sharpe ratio; returns; multiple regression; and several other considerations such as custodial availability and applicable transaction charges. We use a variety of industry leading tools to evaluate and monitor managers and portfolios, including, but not limited to, Morningstar Direct®, FactSet, Ycharts, Fi360’s Fiduciary Toolkit, Portfolio Visualizer (for regression analyses), and Retirement Plan Advisory Group (for ERISA plans). 26  Mercer Advisors’ investment philosophy recommends risk-appropriate portfolios designed to help clients achieve their long-term investment objectives. We review clients’ existing portfolios and deliver investment recommendations to reflect: (1) clients’ individual risk tolerances; (2) ERISA policy for qualified plans; and (3) implementation of applicable Investment Policy Statement (IPS). The client is educated on investment strategy, and an investment plan is established using a specific asset allocation investment strategy. Clients may utilize a combination of investment programs. Clients can establish custodial accounts through any of Mercer Advisors’ recommended custodians. Consideration of Environmental, Social and Governance Factors Mercer Advisors can incorporate socially responsible issues into our investment analysis and decision making for our Values-Based portfolios. We do so using such tools as MSCI ESG ratings, Morningstar Sustainalytics Scores, and additional metrics from other industry data providers. Clients must indicate any preference, restrictions, or changes to their preferences to their advisor to be incorporated into the client’s overall investment strategy. ESG Investing Limitations Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including the potential for underperformance. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Mercer Advisors), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Mercer Advisors does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, Mercer Advisors shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund, or separate account manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Risk of Loss- Material Risk Investing in securities involves the risk of loss clients should be prepared to bear, including the loss of principal investment. Past performance may not be indicative of future results. Different types of investment involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Mercer Advisors) will be profitable or equal any specific performance level(s). Securities may fluctuate in value or lose value. Mercer Advisors will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a client will meet their investment goals. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. • Interest- rate Risk: Fluctuations in interest rates cause investment prices to fluctuate. For example, when interest rates rise, coupons paid by existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund can drop in reaction to tangible and/or intangible events and/or conditions. This type of risk is caused by external factors, independent of a 27  • security’s unique underlying circumstance(s). For example, political, economic, natural disasters, and/or social conditions may trigger market events. Inflation Risk: When any type of inflation exists, a dollar next year will not buy as much as a dollar today, because purchasing power is eroding at a rate of inflation. • Currency Risk: International investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Credit Risk: The risk of loss caused by a counterparty’s or debtor’s failure to make a timely payment, or by the change in value of a financial instrument based upon changes in default risk. • Reinvestment Risk: The risk that future proceeds from investments require reinvestment at a potentially lower rate or return (i.e., interest rate). This relates primarily to fixed income securities. • Business Risk: The risk associated with a particular industry or company within an industry. For example, oil-drilling companies must find oil and then refine it- a lengthy process- before they are able to generate a profit. As such they carry a higher risk of profitability than does an electric company, which generates its income from a steady stream of customers who purchase electricity regardless of the economic environment. • Liquidity Risk: Liquidity is the ability to convert an investment readily into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid whereas real estate property is not. • Financial Risk: Excessive borrowing to finance business operations increases a company’s risk of profitability, as the company must meet the terms of its obligations in both good times and bad. During periods of financial stress, the inability to meet loan obligations can result in bankruptcy and/or a declining market value. • Artificial Intelligence: Mercer Advisors may use certain Artificial Intelligence (“AI”) tools in connection with their investment advisory services. Mercer Advisors has adopted an AI Policy that governs the appropriate use of AI tools to help ensure that Mercer Advisors and its employees abide by their fiduciary duty and comply with all applicable regulations. AI tools are not used by Mercer Advisors as a substitute for professional judgment by Mercer Advisors or its employees, and AI-generated output is reviewed for accuracy. All investment decisions and recommendations are made and approved by Mercer Advisors. The use of AI tools does not guarantee the accuracy of analyses or the success of any investment strategy. Clients should not assume that reliance on AI tools results in better performance or reduces risk. AI tools involve limitations and risks that Mercer Advisors monitors and manages. These risks include, but are not limited to, data security concerns, potential inaccuracies, and possible algorithmic biases. To mitigate these risks, Mercer Advisors has implemented controls such as pre- approval requirements for AI tools, restrictions on providing nonpublic personal information to public AI systems, vendor due diligence, review of AI-generated materials, and employee training. • Cybersecurity Risk: Mercer Advisors and its third-party service providers rely on information technology systems that are subject to cybersecurity risks, including the risk of operational disruption or unauthorized access to clients’ confidential or nonpublic personal information, despite the use of controls intended to mitigate such risks. Clients and Mercer Advisors are subject to the risk of cybersecurity incidents that could ultimately cause them to incur financial losses and/or other adverse consequences. Although the Mercer Advisors has established processes to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that the Mercer Advisors does not control the cybersecurity measures and policies employed by third-party service providers, issuers of securities, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchanges and other financial market operators and providers. 28  Risk of Factor Investing Funds that concentrate investments in specific industries, sectors, markets, or asset classes may underperform or be more volatile than other industries, sectors, markets or asset classes and the general securities market. There can be no assurance that performance will be enhanced, or risk will be reduced for funds that seek to provide exposure to certain quantitative investment characteristics (“factors”). Exposure to such investment factors may detract from performance in some market environments, perhaps for extended periods. In such circumstances, a fund may seek to maintain exposure to the targeted investment factors and not adjust to target different factors, which could result in losses. There are no guarantees that low-volatility stocks will provide low volatility. Investing in securities of small capitalization companies involves greater risk than customarily associated with investing in larger, more established companies. A value style of investing is subject to the risk that the valuations never improve or that the returns will trail other styles of investing or the overall stock markets. Momentum style of investing is subject to the risk that the securities are more volatile than the market as a whole or returns on securities that have previously exhibited price momentum are less than returns on other styles of investing. Risk of Separate Account Managers Mercer Advisors is responsible for sourcing, conducting due diligence, approving, and monitoring Separate Account strategies recommended for use by Mercer Advisors clients (see disclosure at Item 4 above). Mercer Advisors’ due diligence utilizes commercially available databases and evaluative tools to screen, track, and assess the universe of investment managers (e.g., mutual funds, ETFs, separately managed account managers referred to herein as “Separate Account Managers”). Mercer Advisors conducts due diligence on Separate Account Managers who have demonstrated a high degree of expertise in implementing a particular investment strategy or strategies. Options Strategies Mercer Advisors may engage in options transactions, and/or recommend that a client engage a separate account to do so, for the purposes of risk hedging and/or generating portfolio income. The use of options transactions as an investment strategy can involve a high level of inherent risk. Option transactions establish a contract between two parties concerning the buying or selling of an asset at a predetermined price during a specific period of time. During the term of the option contract, the buyer of the option gains the right to demand fulfillment by the seller. Fulfillment takes the form of either selling or purchasing a security, depending upon the nature of the option contract. Generally, the purchase or sale of an option contract shall be with the intent of “hedging” a potential market risk in a client’s portfolio and/or generating income for a client’s portfolio. Please Note: Certain options-related strategies (i.e., straddles, short positions, etc.), in and of themselves, produce principal volatility and/or risk. Thus, a client must be willing to accept the enhanced volatility and principal risks associated with such strategies. Considering these enhanced risks, a client can direct Mercer Advisors, in writing, not to employ any or all such strategies for his/her/their/its accounts. • Covered Call Writing- Covered call writing is the sale of in-, at-, or out-of-the-money call options against a long security position held in a client portfolio. This type of transaction is intended to generate income. It also serves to create partial downside protection in the event the security position declines in value. Income is received from the proceeds of the option sale. Such income can be reduced or lost to the extent it is determined to buy back the option position before its expiration. There can be no assurance 29  that the security will not be called away by the option buyer, which will result in the client (option writer) losing ownership in the security and incurring potential unintended tax consequences. Covered call strategies are generally better suited for positions with lower price volatility. • Long Put Option Purchases- Long put option purchases allow the option holder to sell or “put” the underlying security at the contract strike price at a future date. If the price of the underlying security declines in value, the value of the long-put option can increase in value depending upon the strike price and expiration. Long puts are often used to hedge a long stock position to protect against downside risk. The security/portfolio could still experience losses depending on the quantity of the puts bought strike price and expiration. If the security is put to the option holder, it will result in the client (option seller) losing ownership in the security and incurring potential unintended tax consequences. Options are wasting assets and expire (usually within months of issuance). • Concentrated Stock Risk Management – Options strategies designed to reduce downside risk or volatility associated with large single stock or sector concentrated positions while preserving ownership. Risks include limited upside participation, potential losses during adverse market conditions, and the possibility that the strategy does not provide the intended level of protection. • Portfolio Level Hedging – Index based options overlays intended to manage broad market risk or reduce volatility across diversified portfolios. Risks include imperfect correlation between the hedge and the portfolio, costs associated with maintaining hedges, and the potential for losses if market conditions change rapidly. • Structured Outcome or Replication Strategies – Options based strategies designed to replicate or manage defined payoff outcomes. Risks include complexity, limited liquidity under certain market conditions, and the possibility that outcomes differ from expectations. • Tax Aware Transition or Exit Strategies – Options overlays used to support staged diversification or manage tax impacts during portfolio transitions. Risks include market risk, timing risk, and the potential that tax outcomes differ from expectations due to changes in market conditions or tax laws. Please Note: There can be no guarantee that an options strategy will achieve its objective or prove successful. No client is under any obligation to enter into any option transactions. However, if the client does so, the client must be prepared to accept the potential for unintended or undesired consequences (i.e., losing ownership of the security, incurring capital gains taxes). Risks of Specific Securities Utilized Mercer Advisors generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. However, the firm will utilize short sales, margin transactions, and options writing. Short sales, margin transactions, and options writing generally hold greater risk of capital loss and clients should be aware that there is a material risk of loss using any of those strategies. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. • Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you can lose money investing in mutual funds. All mutual funds have cost that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above). • Equity investment generally refers to buying shares of stocks by an individual or firm in return for receiving a future payment of dividends and capital gains if the value of the stock increases. There is an innate risk involved when purchasing a stock of it decreasing in value, and the investment will incur a loss. 30  • Treasury Inflation Protected/Inflation Linked Bonds: The risk of default on these bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. • Fixed Income is an investment that guarantees fixed periodic payments in the future that may involve economic risks such as inflationary risk, interest rate risk, default risk, repayment of principal risk, etc. • Debt securities carry risks such as the possibility of default on the principal, fluctuation in interest rates, and counterparties being unable to meet obligations. • Stocks and Exchange-Traded Funds (ETFs): Investing in stocks & ETF’s carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy.) • Annuities: An annuity is a contract between the client and an insurance company that is designed to meet retirement and other long-range goals. Annuities can be fixed, variable, or indexed, each carrying their own risk including liquidity, market, and interest rate risk. There are additional fees assessed by the insurance carrier. It is critical that investors are aware of the terms and read the prospectus for the product before purchasing an annuity. • Real estate funds face several kinds of risk that are inherent in this sector of the market. Liquidity risk, market risk, and interest rate risk are just some of the factors that can influence the gain or loss that is passed on to the investor. Liquidity and market risk tend to have a greater effect on funds that are more growth-oriented, as the sale of appreciated properties depends upon market demand. Conversely, interest rate risk impacts the amount of dividend income that is paid by income-oriented funds. • Hedge funds are not suitable for all investors and involve a high degree of risk due to several factors that may contribute to above average gains or significant losses. Such factors include leveraging or other speculative investment practices, commodity trading, complex tax structures, a lack of transparency in the underlying investments, and generally the absence of a secondary market. • Real Estate Investment Trusts (REITs) have specific risks including valuation due to cash flows, dividends paid in stock rather than cash, and the payment of debt resulting in dilution of shares. • Private Investments carry certain risks including liquidity risk, capacity risk, and transparency risk. • Alternative Investments carry a substantial risk as they are largely unregulated offerings not subject to securities laws. • Precious Metal ETFs (Gold, Silver, and Palladium Bullion backed “electronic shares” not physical metal): Investing in precious metal ETFs carries risk of capital loss. • Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various other types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. • Short-term trading risks include liquidity, economic stability, and inflation. • Short sales risk includes the upward trend of the market and infinite possibility of loss. • Margin transactions use leverage that is borrowed from a brokerage firm as collateral. • Options writing involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. Delaware Statutory Trust 1031 exchange and 721 UPREIT Delaware Statutory Trust (“DST”) 1031 and Section 721 UPREIT transactions are tax-deferred real estate investment strategies that may be used by certain investors seeking diversification, professional management, and potential tax deferral. While both strategies involve the disposition of investment real estate, they differ in structure, flexibility, and long-term tax consequences. 31  A DST 1031 exchange is an IRS-approved method allowing real estate investors to defer capital gains taxes by pooling their capital into professional managed, institutional-quality commercial properties. It acts as a “like- kind” replacement property, offering passive ownership, and potential diversification. It is designed to provide investors with the opportunity to exchange currently owned property for a higher-quality professionally managed institutional property(ies). Section 1031 of the U.S. Internal Revenue Code permits the avoidance of paying capital gains taxes for the sale of an investment property if the seller reinvests the proceeds from the sale within certain time limits in a property or properties of like kind and equal or greater value. Generally, from the date of sale, the seller has 45 days to identify potential replacement properties and 180 days to acquire replacement properties To defer all taxes, the new property must be of equal or greater value, with all equity reinvested. A 721 UPREIT converts investment property into real estate investment trust (“REIT”) operating partnership units (“OP units”) for diversification, liquidity, and tax deferral. It is designed to provide investors with the opportunity to swap a single asset for a share in a large professionally managed portfolio that seeks to provide steady income and reduced risk. Key Differences • Future Tax Deferral: DST investments may offer the potential for future Section 1031 exchanges upon sale, whereas a 721 UPREIT transaction converts the property interest into REIT operating partnership units, making future Section 1031 exchanges generally unavailable. • Asset Exposure: DSTs typically involve interest in one or a limited number of properties, while UPREIT structures generally provide exposure to a broad, diversified institutional real estate portfolio. • Flexibility: Some investors may utilize a “two-step” strategy by first completing a 1031 exchange into a DST and later participating in a 721 transaction if the DST property is acquired by a REIT, providing additional flexibility before committing to a long-term REIT investment. Please Note Investment Risks and No Assurance of Success: As with any investment or investment strategy, there can be no assurance that a DST or 721 UPREIT transaction will be profitable or achieve a certain level of performance. While these transactions offer tax-deferred diversification, they come with significant fees and risks, including illiquidity, lack of control, and potential for total loss of capital. No Mercer Advisors client is under any obligation to consider either a DST or 721 UPREIT transaction. ITEM 9 – DISCIPLINARY INFORMATION Mercer Advisors, as a firm, has no legal, financial, or other “disciplinary” item(s) to report. Mercer Advisors is obligated to disclose any disciplinary event that would be material to a potential client when evaluating the firm to initiate a Client / Advisor relationship, or to continue a Client / Advisor relationship with the firm. Please refer to the Form ADV Part 2B for individual Advisor information. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS “Mercer Advisors” is a brand name used by several affiliated legal entities owned by Mercer Advisors, Inc., including Mercer Global Advisors Inc., an SEC registered investment adviser; Mercer Advisors Private Asset Management, Inc., an SEC registered investment adviser; Mercer Advisors Tax Services, LLC (“MATS”); Heim, Young and Associates, Inc. (MA Brokerage Solutions); and Mercer Advisors Insurance Services, LLC (MAIS). 32  Please Note: Certain of our advisory personnel and/or our parent company are affiliated, through common ownership and/or control, with various other entities that provide services to clients. As a result of this affiliation, we have a financial and business interest in referring clients to the affiliated entities. This relationship creates a conflict of interest because we have an incentive to recommend the affiliated entities based on the benefits that may accrue to our firm or its affiliates, rather than solely on the client’s needs. These benefits may include, among other things, increased revenues, shared resources, operational efficiencies, or enhanced enterprise value resulting from the use of affiliated services. Insurance Services Mercer Advisors has two related insurance agencies. Mercer Advisors Insurance Services, LLC (“MAIS”), and Heim Young & Associates, Inc. (“HYA”) are wholly owned subsidiaries of Mercer Advisors Inc. Employees of Mercer Advisors serve as officers of MAIS and HYA. MAIS and HYA provide individual life, disability, long-term care coverage, and fixed and indexed annuities through various insurance companies. Heim, Young & Associates is also a broker-dealer and provides access to variable life and annuity products which require insurance licensing. For Mercer Advisors clients who wish to purchase insurance products through MAIS, MAIS has entered into non-exclusive referral agreements with Howard Insurance Agency, Inc., AgencyONE, and Hub International. Howard Insurance, AgencyONE, or Hub International will provide necessary services related to the marketing, placement, and servicing of the insurance products, including without limitation preparing and presenting illustrations, supporting the underwriting process, assisting with the completion and execution of applications, delivering policies, and servicing in-force business. MAIS and Howard Insurance Agency will be listed as “co-agents” on the policies. While Mercer Advisors does not receive a referral fee, each of MAIS, Howard Insurance Agency, and/or AgencyONE, or Hub International in any combination, receives a percentage of the commission revenue. AgencyONE receives overrides from the insurance business written by MAIS, a portion of which is shared with MAIS. The receipt of insurance commissions is in addition to any advisory fees charged separately by Mercer Advisors. This practice presents a conflict of interest as certain Mercer Advisors’ employees are officers of MAIS and MAIS is an affiliate of Mercer Advisors. MAIS has also entered into a relationship with Advisors Excel, LLC, an Insurance Marketing Agency, which provides services such as marketing support, carrier access and training and development. MAIS receives from selected insurance carrier 100% of the commission based on the product sold. Advisors Excel receives overrides from the insurance carrier on the business placed, a portion of which is shared with MAIS. HYA also offers insurance products to clients, primarily, but not exclusively, as part of its broker-dealer activities. The receipt of any commission for insurance through HYA is separate and in addition to advisory fees charged separately by Mercer Advisors. This practice presents a conflict of interest as certain Mercer Advisors’ employees are officers of HYA and HYA is an affiliate of Mercer Advisors. HYA has entered into a non-exclusive referral relationship with AgencyONE to provide necessary services related to the marketing, placement, and servicing of insurance products, including without limitation preparing and presenting illustrations, supporting the underwriting process, assisting with the completion and execution of applications, delivering policies and servicing in-force business. For these clients, HYA receives 100% of the commission on the product while AgencyONE receives overrides from the placed insurance products, which is shared with HYA. 33  Clients are never obligated or required to purchase insurance products and are able to choose any independent insurance agent or insurance company to purchase insurance products. Separate from MAIS, employees who are licensed to sell insurance are required to report their licensure as an Outside Business Activity, and the activity is disclosed on the individual’s FINRA Form U-4 and ADV Part 2B filings, as appropriate. Moreover, Mercer Advisors acquires advisory firms who have affiliated insurance entities and/or employees who recommend insurance products and receive insurance commissions. As part of the acquisition process, any insurance entities are separate from and held outside Mercer Advisors. For those employees who retain and actively use their insurance licenses, they are required to report their licensure as an Outside Business Activity, and the activity is properly disclosed on the individual’s FINRA Form U-4 and Form ADV filings. Mercer Advisors periodically reviews these outside business activities. These employees will earn commission-based compensation for selling insurance products. Insurance commissions earned by these people are separate and in addition to Mercer Advisors’ advisory fees. Mercer Advisors does not receive any compensation for insurance products offered by these employees, and the products are not provided, recommended, or approved by Mercer Advisors. This practice presents a conflict of interest because persons providing investment advice on behalf of Mercer Advisors who are insurance agents have an incentive to recommend insurance products to clients for the purpose of generating commissions rather than solely based on clients’ needs. Please Note: Conflict of Interest The recommendation by Mercer Advisors that a client consider the purchase of an insurance product through Mercer Advisors Insurance Services or Heim, Young & Associates, Inc. (“HYA”) presents a conflict of interest, as the potential receipt of an insurance commission compensation by Mercer Advisors Insurance Services, HYA and their agent(s) provides an incentive for Mercer Advisors representatives to recommend insurance products based on compensation to be received by its affiliated entity and representative rather than on a particular client’s needs. No client is under any obligation to purchase any insurance product from a Mercer Advisors’ affiliated entity or from an employee of Mercer Advisors. Clients can purchase insurance products through other, non-affiliated insurance agencies and agents. Securities Sales Mercer Global Advisors Inc. has an affiliated broker dealer entity, Heim, Young & Associates Inc. (“HYA”). HYA is a wholly owned subsidiary of Mercer Advisors Inc. Certain employees of Mercer Advisors serve as officers of HYA. As indicated at Item 4 above, some Mercer Advisors’ representatives, in their separate individual capacities, also serve as registered representatives of various SEC registered and FINRA member broker-dealers, including Purshe Kaplan Sterling Investments (PKS), an unaffiliated broker-dealer, and Heim, Young & Associates Inc. Please Note: Conflict of Interest The recommendation by a Mercer Advisors’ representative that a client purchase securities or any investment product on a commission basis from a Mercer Advisors’ representative in his/her individual capacity as a representative of a broker-dealer, presents a conflict of interest, as the receipt of commission compensation provides an incentive to recommend investments and/or investment products based on commissions to be received, rather than on a particular client’s need. The commission compensation is separate from, and in addition to, the investment advisory fees paid by the client to Mercer Advisors. Any commissions received by HYA are not paid directly to the advisors acting in their capacity as registered representatives. No client is under any obligation to purchase any securities commission products from a Mercer Advisors’ representative. 34  Affiliated Registered Investment Advisors Mercer Advisors Private Asset Management Inc. (“MAPAM”), an SEC registered investment advisor, is an affiliate of Mercer Global Advisors Inc. MAPAM provides investment advisory services to affiliated private funds. Information regarding Mercer Advisors Private Asset Management Inc. can be found on the Investment Advisor Public Disclosure site. For more information, please see Item 4 above which provides details the affiliated funds and corresponding conflicts of interest and associated risks. Affiliated Tax Entity Mercer Advisors Tax Services, LLC (“MATS”) provides tax preparation services and various business management services. Clients obtaining the services of MATS will sign a separate engagement agreement to receive services. Tax services provided by MATS are not public accounting services, and MATS is not a CPA firm and does not provide public accounting services. Please Note Conflict of Interest: The recommendation that a client considers utilizing MATS’ services presents a conflict of interest, as previously disclosed. No client is obligated to consider utilizing MATS. Mercer Advisors will work with the tax professional of the client’s choosing. Separate Affiliated Entity MAPAM GP I, LLC, is an affiliate of Mercer Advisors and is the general partner for affiliated private investment funds. Real Estate Entity FSC Realty, LLC is an affiliated entity which provides real estate management and real estate advisory services. Clients engaging in these services are separate and apart from services provided by Mercer Global Advisors Inc. Services provided by FSC will be outlined in a separate engagement and incur additional fees. Please Note Conflict of Interest: Conflicts of interest can exist if clients choose to engage in these services, as the firm has an indirect incentive to recommend the services of an affiliated entity. Certain of our advisory personnel and/or our parent company are affiliated, through common ownership and/or control. As a result of this affiliation, we have a financial and business interest in referring clients to FSC. This relationship creates a conflict of interest because we have an incentive to recommend FSC based on the benefits that may accrue to our firm or its affiliates, rather than solely on the client’s needs. Sponsorship of P odcasts Mercer Advisors offers various podcasts to help provide general aspects of financial education. The podcasts are widely available to both Mercer Advisors clients and non-clients and address various topics aimed at financial education, market commentary, and current topics within the industry. Other Financial Affiliations Mercer Advisors recommends, but does not direct clients to use, certain unaffiliated custodians, including Charles Schwab & Co., Inc., Fidelity Brokerage Services LLC, Raymond James & Associates Inc., and Goldman Sachs Custody Solutions (Folio Investments, Inc. DBA GSCS), member New York Stock Exchange/SIPC as custodians of their assets. In addition, as referenced in Item 10 below, Mercer Advisors has a relationship with NATC, whereby NATC can serve as custodian for trust assets and corporate trustee of trust clients. Mercer 35  Advisors clients who use recommended custodians receive Mercer Advisors negotiated discounted commissions and/or other fees. Clients obtained through the acquisition of other firms by Mercer Advisors may utilize custodians other than our recommended custodians. These custodian fees or other charges may be higher than those provided through our recommended custodians. Our Advisors can recommend and/or clients can request to move their accounts to recommended custodians to take advantage of any discounted commissions and/or other fees. Higher fees can adversely impact account performance. Please Note Continued Conflict of Interest: Mercer Global Advisors Inc. acquired substantially all the assets of Regis Management Company, LLC (“Regis”). Clients of Regis transitioned to Mercer Advisors in July 2024. Prior to the acquisition of Regis assets, two current representatives of Mercer Advisors, in their individual capacities as former Regis members (together, the “Members”) acquired a profits interests in certain private investment funds (the “Fund[s]”) managed by the following Fund managers (the “Managers”): Mainsail Partners, LLC, (private equity buyout funds), RMA Real Estate Investment Advisors (real estate investment funds), and Merus Capital, LLC (venture capital funds). The profits interests shall continue to be payable to the Members until such time as the respective Funds are terminated. Regis, having disclosed the conflict pertaining to the Members’ corresponding profits interests, introduced the Funds to certain of their clients, some of which became (and continue to be) Fund investors. As indicated above, certain Regis clients have transitioned their relationships to Mercer Advisors. In addition to these former Regis clients, Mercer Advisors could introduce additional clients to the newest Funds offered by Mainsail, RMA, or Merus. While the two current Mercer employees would not have an economic interest in the newest funds, they will still be invested in an affiliate of the GP of the newest funds and thereby have a conflict. If Mercer Advisors introduce additional clients to the newest Funds offered by Mainsail, RMA, or Merus, such conflict will be disclosed, in writing, prior to the client’s Fund purchase. The Members do not receive any profits interests for any other Manager-affiliated private investment funds that were formed subsequent to 2012. We have a limited number of wealth management clients that are executives or managers of other private funds, including but not limited to private equity, private real estate, and venture capital funds. We believe that we will advise selected clients to invest with one or more of these other private funds. This creates a conflict of interest if we advise a client to invest in a fund managed by another fee-paying wealth management client. If this occurs, we will disclose this conflict when we make the investment recommendation. We believe this potential conflict is mitigated through our investment due diligence process and the required review and approval by our Investment Committee. Retirement Plan Services Mercer Advisors can refer appropriate clients to Third Party Administrators (“TPA”) and Record-keepers for services. Advisory Services to Brokerage Customers Mercer Advisors has agreements with certain broker-dealers to provide investment advisory services to their brokerage customers. The broker dealers compensate Mercer Advisors for providing investment advisory services to their customers. The brokerage customers will execute an advisory agreement directly with Mercer Advisors. 36  Estate Planning Document Preparation As disclosed at Item 4 above, Mercer Advisors offers clients estate planning document preparation and other legal services in conjunction with Advanced Services Law Group, Inc. (“ASLG”). Trust and Estate Administration Services Mercer Advisors acquired Kanaly Trust Company through a merger and acquisition. As part of this acquisition, Mercer Global Advisors Inc. transitioned the trust services portion of Kanaly Trust Company to NATC (see below) but retained their asset management service relationships for all accounts. Since the trust services portion of the business was transitioned to NATC, all trust powers and trust authority previously granted to Kanaly Trust Company also transitioned to NATC. Mercer Advisors has entered into an Estate Administration Services Agreement with National Advisors Holdings, Inc. and National Advisors Trust Company (collectively, “NATC”). Mercer Advisors will, by order of an applicable probate court, governing document, or such collateral agreements acceptable to NATC, be designated as NATC’s delegee for each estate for which NATC provides estate administration services under the Estate Administration Services Agreement. Mercer Advisors’ delegated powers are strictly limited by the terms of the Estate Administration Agreement, and, if so desired, further limited in writing by NATC. Duties of Mercer Advisors pursuant to the Estate Administration Services Agreement include: (1) identification and inventory of decedent's real and personal property; (2) obtainment of death certificate; (3) assisting a client in securing a decedent's safe deposit box (if applicable); (4) obtainment of names, addresses and SSNs on all heirs and other interested parties; and (5) obtainment of deeds and title documents on all real assets. Notwithstanding anything in the Estate Administration Services Agreement to the contrary, in no event shall Mercer Advisors’ duties include authority with which Mercer Advisors could unilaterally possess or dispose of funds or securities in any form. Please Note Conflict of Interest: For estate administration services, probate fees are divided between NATC and Mercer Advisors on a case-by-case basis. As a result of the probate fee sharing, Mercer Advisors has a conflict of interest when recommending NATC. ITEM 11 – CODE OF ETHICS AND PERSONAL SECURITIES TRANSACTIONS Mercer Advisors has adopted a Code of Ethics expressing the firm’s commitment to ethical conduct. The Code of Ethics describes the firm’s fiduciary duties and responsibilities to clients and sets forth Mercer Advisors’ practice of monitoring employees’ personal securities transactions and prohibiting the use of material non- public information. Mercer Advisors will provide a complete copy of its Code of Ethics to any client or prospective client, upon request. Requests shall be submitted to the Compliance Department at Mercer Advisors, 1200 17th Street, Suite 2000, Denver, Colorado 80202 or by emailing CCO@merceradvisors.com. Outside business Activity- Conflict of Interest Outside business activities of Mercer Advisors’ employees pose a potential conflict of interest. Investment Adviser Representatives (IARs) are required to disclose their investment-related outside business activities on their Form ADV Part 2B, copies of which remain available upon request. In addition, investment-related outside business activities are disclosed for individual advisors in the Investment Adviser Public Disclosure (IAPD) website located at https://adviserinfo.sec.gov/. 37  Dave Welling, CEO at Mercer Advisors, serves on the Board of Manager of Yukon YC Holdings LLC d/b/a YCharts (“YCharts”), a privately held company. Mercer Advisors entered an agreement with YCharts to obtain access to tools that assist Mercer Advisors with its investment-related analyses for client accounts and for presentations to the public. Mercer Advisors (not the client) pays for access to such tools. ITEM 12 – BROKERAGE PRACTICES In the event the client requests that Mercer Advisors recommend a broker-dealer/custodian for execution and/or custodial services, Mercer Advisors generally recommends that investment advisory accounts be maintained at Schwab, Fidelity, Goldman Sachs, or Raymond James. Prior to engaging Mercer Advisors to provide investment management services, the client will be required to enter into a separate custodial/clearing agreement with each designated broker-dealer/custodian. Factors that Mercer Advisors considers in recommending any broker-dealer/custodian to clients include historical relationship with Mercer Advisors, financial strength, reputation, execution capabilities, pricing, research, and service. Broker-dealers/custodians can charge transaction fees for effecting certain securities transactions (See Item 4 above). To the extent that a transaction fee will be payable by the client to a broker- dealer/custodian, the transaction fee shall be in addition to Mercer Advisors’ investment advisory fee referenced in Item 5 above. Mercer Advisors has a duty to obtain best execution for client account transactions. However, such duty does not mean that the client will not pay a transaction fee that is higher than another qualified broker-dealer might charge to affect the same transaction where Mercer Advisors determines, in good faith, that the transaction fee is reasonable. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker- dealer’s services, including the value of research provided, execution capability, transaction rates, and responsiveness. Accordingly, although Mercer Advisors will seek competitive rates, it will not necessarily obtain the lowest possible rates for client account transactions. account or per trade basis, depending on the ‑ ‑ execution ‑ Custodians impose additional fees in connection with certain block trades or trades that require manual handling, specialized execution support, or access to advanced trading services through their respective trading desks. When applicable, these fees are assessed by the custodian and are charged in addition to the advisory fee paid to Mercer Advisors. Such fees may be assessed on a per custodian, the nature of the trade, and the execution method used. No portion of these block trading fees are shared by the custodian with Mercer Advisors. In determining how trades are executed, Mercer Advisors considers execution quality, costs, market conditions, and other relevant factors in fulfilling its best obligations. The use of a custodian’s block trading or specialized execution services may be appropriate notwithstanding the additional cost. Mercer Advisors has entered into referral arrangements with Schwab, Fidelity, and Goldman Sachs which is explained in Item 14. Research and Benefits Although not a material consideration when determining whether to recommend that a client utilize the services of a particular broker-dealer/custodian, Mercer Advisors can receive from Schwab, Fidelity, or Raymond James (or another broker-dealer/custodian, investment manager, platform sponsor, mutual fund sponsor, or vendor) without cost (and/or at a discount) support services and/or products, certain of which assist Mercer Advisors to better monitor and service client accounts maintained at such institutions. Included 38  within the support services that can be obtained by Mercer Advisors can be investment-related research, pricing information and market data, software and other technology that provide access to client account data, compliance and/or practice management-related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support-including client events, computer hardware and/or software and/or other products used by Mercer Advisors in furtherance of its investment advisory business operations. Certain of the support services and/or products that are received assist Mercer Advisors in managing and administering client accounts. Others do not directly provide such assistance but rather assist Mercer Advisors to manage and further develop its business enterprise. Mercer Advisors’ clients do not pay more for investment transactions and/or assets maintained at Schwab, Fidelity, Raymond James, or other custodians as the result of this arrangement. There is no corresponding commitment made by Mercer Advisors to third party custodians to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as result of the above arrangement. Schwab Monetary Assistance/Additional Benefit: Mercer Advisors has entered into a separate agreement with Schwab, whereby Schwab provides monetary assistance to Mercer Advisors to defray certain costs that can be incurred relative to the transition of client accounts from an existing custodian to Schwab. Schwab’s support services are generally available on an unsolicited basis (Mercer Advisors does not have to request them) and at no charge to Mercer Advisors. Support services are offered on a tiered schedule based on the amount of client assets transferred to and maintained at Schwab over a period of 24 months. Mercer Advisors’ recommendation that clients maintain their assets in accounts at Schwab could be based in part on the receipt by Mercer Advisors of some of the foregoing products and services and other arrangements and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which creates a conflict of interest. Directed Brokerage A directed brokerage arrangement arises when a client requires that account transactions be affected through a specific broker-dealer/custodian, other than one generally recommended by Mercer Advisors. In such client directed arrangements, the client will negotiate terms and arrangements for their account with that broker- dealer, and Firm will not seek better execution services or prices from other broker-dealers or be able to "batch" the client’s transactions for execution through other broker-dealers with orders for other accounts managed by Mercer Advisors. As a result, a client will likely pay higher commissions or other transaction costs or greater spreads, or receive less favorable net prices, on transactions for the account than would otherwise be the case. Some clients of firms acquired by Mercer Advisors have accounts held at other custodians prior to their association with Mercer Advisors. Clients are always able to change their custodian to a Mercer Advisors recommended custodian. Should clients choose to retain their current custodian, these accounts will be treated as directed brokerage accounts. Please Note the Following: • In the event that the client directs Mercer Advisors to effect securities transactions for the client’s accounts through a specific broker-dealer, the client correspondingly acknowledges that such direction could cause the accounts to incur higher commissions or transaction costs than the accounts would otherwise incur had the client determined to effect account transactions through alternative arrangements that are available through Mercer Advisors. 39  • Higher transaction costs adversely impact account performance. • Transactions for directed accounts could be executed following the execution of portfolio transactions for non-directed accounts. Order Aggregation Transactions for each client account generally will be affected independently unless Mercer Advisors decides to purchase or sell the same securities for several clients at approximately the same time. In these instances, the Firm will try to (but is not obligated to) combine or “batch” such orders (aka “block trade”) for individual equity transactions (including ETFs) with the intention to obtain better price execution, to negotiate more favorable commission rates, or to allocate more equitably among the Firm’s clients differences in prices and commissions or other transaction costs that might have occurred had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. If the Firm becomes aware that a Firm employee seeks to trade in the same security on the same day, the employee transaction will either be included in the “batch” transaction or transacted after all discretionary client transactions have been completed. In some limited circumstances, if the size of the block trade will be a significant percentage of the average daily volume, Schwab and/or Fidelity may decide to utilize their block trading team to execute the transactions, which would incur an additional trade fee per client account. See the custodian fee schedule for additional fees and account terms and conditions. The Firm shall not receive any additional compensation or remuneration as the result of such aggregation. Allocation of Investment Opportunities with Limited Supply MGA has adopted allocation policies and procedures that guide our employees when allocating investment opportunities among Client accounts consistent with our fiduciary obligations. Our policy is to allocate investment opportunities in a fair and equitable manner. In most instances, when the supply of the investment opportunity is limited, meaning there is more client demand than available supply at that time, the allocation method used will be pro rata. In limited durations, if the pro rata allocation might not be the most fair and equitable method, we may seek to employ what we believe to be a more equitable method. Only a small group of designated investment and trading personnel are authorized to determine the method chosen for limited investment opportunities and oversee the implementation. When a decision is made, the designated employee will document the allocation method used and the rationale for choosing that method, along with any special considerations that were present. Special considerations include but are not limited to client investment objectives and other specific portfolio constraints, available cash balances, and in the case of private securities in limited supply the required timing of completing the client’s subscription agreement (or indication of interest), investment minimums, and additional risk or suitability considerations of the investment. Trade Errors Mercer Advisors has an obligation to ensure that clients are not disadvantaged by trade errors. A trade error is an error in the placement, execution, or settlement of a client’s trade. When a trade error occurs, we work with all relevant parties in the trading process to promptly correct the error while ensuring it does not disadvantage the client. The correction of a trade error can generate a gain or a loss. A trade error gain is typically not paid to Mercer Advisors. The custodian/broker-dealer will either donate the gain to charity or allow a balance to accrue in an error account maintained on our behalf. In such cases, Mercer Advisors does not benefit from the gains in the 40  error account, except to the extent that any gains that remain in the account can be used to offset any other trade error losses. Trade away/Prime Broker Fees In limited circumstances, if, in the reasonable determination of Mercer Advisors, it would be beneficial for the client, individual fixed income transactions, equities, and ETFs will be effected through broker-dealers other than the account custodian, in which event, the client generally will incur both the fee (commission, mark- up/mark-down) charged by the executing broker-dealer and a separate “trade away” and/or prime broker fee charged by the account custodian (i.e., Schwab, Fidelity, Raymond James, etc.). Soft Dollar Arrangements Mercer Advisors does not currently have any soft-dollar arrangements and does not anticipate entering into any soft-dollar arrangements in the future. However, as disclosed above and at Item14 below, Mercer Advisors receives certain products and services from broker-dealers/custodians. ITEM 13 – REVIEW OF ACCOUNTS The design and implementation of a financial plan is recommended for all clients. Reviews are conducted with clients to evaluate his/her plan to make necessary adjustments to achieve stated objectives, when and where appropriate. Normally, reviews are coordinated through client service teams and conducted by Advisors or Financial Planners. Reviews with clients are typically conducted at least annually. Clients should contact their advisor to report any changes in their personal situation that may impact their financial situation or the current financial plan. Review Triggers More frequent reviews may be triggered by material changes in variables including, but not limited to, unique client circumstances, style changes, and/or market conditions. Other conditions that trigger a portfolio review include changes in the securities laws, new investment information, and/or changes in client goals and/or circumstances. Regular Reports Clients receive direct custodian reporting on at least a quarterly basis and from Mercer Advisors on a periodic basis. See additional disclosure in Item 15 below. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Benefits Received As indicated in Item 12 above, Mercer Advisors can receive from Schwab, Fidelity, or Raymond James (and others) without cost (and/or at a discount), support services and/or products. Mercer Advisors’ clients do not pay more for investment transactions and/or assets maintained at Schwab, Fidelity, or Raymond James (or any other institution) as a result of this arrangement. There is no corresponding commitment made by Mercer Advisors to any such entity, to invest any specific amount or percentage of client assets in any specific mutual funds, securities, or other investment products as the result of the above arrangements. 41  Client Referrals Charles Schwab & Co Mercer Advisors receives client referrals from Charles Schwab & Co., Inc. (“Schwab”) through Mercer Advisors’ participation in the Schwab Advisor Network® (“the Service”). The Service is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with Mercer Advisors. Schwab does not supervise Mercer Advisors and has no responsibility for Mercer Advisors’ management of client portfolios, advice, or other services. Mercer Advisors pays Schwab a fee to receive client referrals through the Service. Mercer Advisors’ participation in the Service raises potential conflicts of interest. Mercer Advisors pays Schwab a Non-Schwab Custody Fee if custody of a referred client’s account is not maintained by, or assets within the account are transferred from, Schwab. This Fee does not apply if the client was solely responsible for the decision to remove asset custody from Schwab. The Non-Schwab Custody Fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Schwab. The Non- Schwab Custody Fee is higher than the Participation Fees Mercer Advisors generally would pay in a single year. Thus, Mercer Advisors will have an incentive to recommend that client accounts be held in custody at Schwab. The Participation and Non-Schwab Custody Fees are based on assets in accounts of Mercer Advisors’ clients who were referred by Schwab and those referred clients’ family members living in the same household. As such, Mercer Advisors will have an incentive to encourage household members of clients referred through the Service to maintain custody of their accounts and execute transactions at Schwab and to instruct Schwab to debit Mercer Advisors fees directly from the accounts. Mercer Advisors pays Schwab a Participation Fee for all referred client accounts maintained in custody at Schwab and a Non-Schwab Custody Fee for all accounts maintained at, or transferred to, another custodian. The Participation Fee paid by Mercer Advisors is a percentage of the fees paid by the client to Mercer Advisors or a percentage of the value of the assets in the client’s account, subject to a minimum Participation Fee. Mercer Advisors pays Schwab a Participation Fee for as long as the referred client’s account remains in custody at Schwab. The Participation Fee is billed to Mercer Advisors quarterly and may be increased, decreased, or waived by Schwab periodically. The Participation Fee is paid by Mercer Advisors, not by the client. Mercer Advisors has agreed not to charge clients referred through the Service any fees or costs greater than those charged to clients with similar portfolios who were not referred through the Service. For Mercer Advisors client accounts maintained in custody at Schwab, Schwab will not charge the client separately for custody but will receive compensation from the clients in the form of commissions or other transaction-related compensation on securities trades executed through Schwab. Schwab also will receive a fee (generally lower than the applicable commission on executed trades) for clearance and settlement of trades executed through broker-dealers other than Schwab. Schwab’s fees for trades executed at other broker- dealers are in addition to the other broker-dealer's fees. Thus, Mercer Advisors has an incentive to cause trades to be executed through Schwab rather than another broker-dealer. Mercer Advisors nevertheless acknowledges its duty to seek best execution of trades for client accounts. Fidelity Wealth Advisor Solutions® Mercer Advisors participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which Mercer Advisors receives referrals from Strategic Advisers LLC (Strategic Advisers), a registered investment adviser and Fidelity Investments company. Mercer Advisors is independent and not affiliated with Strategic Advisers or any Fidelity Investments company. Strategic Advisers does not supervise or control 42  Mercer Advisors, and Strategic Advisers has no responsibility or oversight for Mercer Advisors provision of investment management or other advisory services. Under the WAS Program, Strategic Advisers acts as a solicitor for Mercer Advisors, and Mercer Advisors pays referral fees to Strategic Advisers for each referral received based on Mercer Advisors assets under management attributable to each client referred by Strategic Advisers or members of each client’s household. The WAS Program is designed to help investors find an independent investment advisor, and any referral from Strategic Advisors to Mercer Advisors does not constitute a recommendation by Strategic Advisers of Mercer Advisors particular investment management services or strategies. More specifically, Mercer Advisors pays the following amounts to Strategic Advisers for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” assets by Strategic Advisers and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, Mercer Advisors has agreed to pay Strategic Advisers an annual program fee of $50,000 to participate in the WAS Program. These referral fees are paid by Mercer Advisors and not by the client. To receive referrals from the WAS Program, Mercer Advisors must meet certain minimum participation criteria, but Advisor has been selected for participation in the WAS Program as a result of its other business relationships with Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, Mercer Advisors has a conflict of interest with respect to its decision to use certain affiliates of Strategic Advisers, including FBS, for execution, custody and clearing for certain client accounts, and Advisor could have an incentive to suggest the use of FBS and its affiliates to its advisory clients, whether or not those clients were referred to Mercer Advisors as part of the WAS Program. Under an agreement with Strategic Advisers, Mercer Advisors has agreed that Advisor will not charge clients more than the standard range of advisory fees disclosed in its Form ADV 2A Brochure to cover solicitation fees paid to Strategic Advisers as part of the WAS Program. Pursuant to these arrangements, Mercer Advisors has agreed not to solicit clients to transfer their brokerage accounts from affiliates of Strategic Advisers or establish brokerage accounts at other custodians for referred clients other than when Mercer Advisors’ fiduciary duties would so require, and Advisor has agreed to pay Strategic Advisers a one-time fee equal to 0.75% of the assets in a client account that is transferred from Strategic Advisers’ affiliates to another custodian; therefore, Mercer Advisors has an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of Strategic Advisers. However, participation in the WAS Program does not limit Mercer Advisors’ duty to select brokers on the basis of best execution. Goldman Sachs Wealth Services New Client Referrals Mercer Advisors receives client referrals from Goldman Sachs Wealth Services, L.P. (GS Ayco). GS Ayco is not affiliated with Mercer Advisors. If a GS Ayco referral is accepted by Mercer Advisors as a client, Mercer Advisors shall compensate GS Ayco with a referral fee (i.e., a portion of the advisory fee earned by Mercer Advisors from the assets of the GS Ayco referred client). GS Ayco referred clients do not pay a higher advisory fee to Mercer Advisors than if the client engaged Mercer Advisors directly, independent of the GS Ayco referral. Please Note Conflict of Interest: It is anticipated that GS Ayco referred clients will utilize the services of affiliates of GS Ayco (the “Affiliates”) for account execution, custody, and clearing services. In addition, Mercer Advisors could recommend that non-GS Ayco referred clients utilize the Affiliates for client’s execution, custody and clearing services. Mercer Advisors’ recommendation and use of the Affiliates present a conflict of interest (i.e., in consideration for GS Ayco referrals, Mercer could have an economic incentive to utilize the Affiliates for both GS Ayco referred and non-GS Ayco referred Mercer Advisors’ clients). 43  Deposit Products Mercer Global Advisors Inc. refers clients to deposit products offered by Goldman Sachs Select (GS Select) and can receive compensation from Goldman Sachs Bank USA (Goldman Sachs) in connection with client participation in these deposit products. Goldman Sachs is an independent financial institution and is not affiliated with Mercer Advisors. Goldman Sachs has the sole discretion to modify the deposit products available to Mercer Advisors’ clients. Mercer Global Advisors Inc. receives referral fees from Goldman Sachs based on client deposits in GS Select products. These fees are paid by Goldman Sachs and do not result in additional charges to clients. However, this referral arrangement creates a conflict of interest because Mercer Advisors has a financial incentive to recommend GS Select deposit products over other available cash management solutions Lending Products Mercer Global Advisors Inc. can refer clients to lending products offered by Goldman Sachs Bank USA (“Goldman Sachs”). Goldman Sachs is an independent financial institution and is not affiliated with Mercer Advisors. Mercer Global Advisors Inc. does not receive referral compensation from Goldman Sachs. Sub-Advisory Mercer Advisors has also entered mutual compensation arrangements with Goldman Sachs affiliates whereby Mercer Advisors utilizes Goldman Sachs affiliated advisers to provide sub-advisory services for Mercer Advisors’ client accounts and Goldman Sachs affiliates utilize Mercer Advisors for sub-advisory services. No affected Mercer Advisors’ client pays a higher advisory fee to Mercer Advisors as the result of such sub- advisory arrangement. Please Note: No client is under any obligation to utilize the Affiliates, GS Select deposit products, or Goldman Sachs lending products. Please Note Conflict of Interest: The combination of the above referral arrangements creates economic incentives and conflicts of interest for Mercer Advisors to recommend and utilize Goldman Sachs affiliated products and services. StoneCastle Network Mercer Global Advisors Inc. refers clients to the deposit bank account program (the “KEEP program”) offered by StoneCastle Network LLC (“StoneCastle”). Clients participating in the KEEP program can make deposits that are intended to qualify to obtain 100% coverage in the deposit insurance provided by the Federal Deposit Insurance Corporation (FDIC) and/or National Credit Union Administration (NCUA). Clients desiring to participate in the KEEP program enter into a separate agreement with StoneCastle and are subject to the program requirements and limitations. Mercer Advisors will receive a referral fee of .05% from StoneCastle based on the average client’s monthly balance in the KEEP program. This referral arrangement creates a conflict of interest because Mercer Advisors has a financial incentive to recommend that clients utilize the KEEP program over other available deposit solutions. Please Note: No Mercer Advisors’ client is under any obligation to utilize the KEEP program. Moreover, Mercer Advisors makes no guarantee: (1) of success of the KEEP program’s intended objective of providing 100% deposit insurance coverage; or (2) that the deposit rates available under the KEEP program will be equal to those available from other deposit institutions. 44  Other Referral Arrangements Mercer Advisors has entered into referral agreements with various unaffiliated referral sources. Under each of these agreements, Mercer Advisors agrees to pay to the referral source a fee for client referrals. The arrangements are structured to be compliant with applicable securities laws, including a formal contract between Mercer Advisors and the referring entity. Pursuant to the contract, each potential client is provided with a disclosure statement that describes the relationship between Mercer Advisors and the referring entity- including the compensation that will be paid to the referring entity- prior to or at the time the client enters into a client agreement with Mercer Advisors. The notice confirms that Mercer Advisors will not charge the client a higher advisory fee as a result of the referral arrangement. Mercer Advisors has implemented a program to compensate corporate employees for client referrals. The program is structured to comply with applicable securities law. In addition, Mercer Advisors may hold client appreciation events, the invitation criteria for which could include whether the client has introduced prospective new client(s) to Mercer Advisors during the preceding year. Other Compensation Mercer Global Advisors Inc. receives no other direct compensation from clients, outside of what has been disclosed in this Brochure, beyond fees charged as described under Item 5- “Fees and Compensation.” All Mercer Advisors licensed, supervised employees are compensated based upon a combination of: (1) base salary; and (2) bonuses related to meeting certain criteria including revenue retention and adding new client assets. Third Party Sponsorship Mercer Advisors holds training sessions known as “Academies/National Symposium/Market Meetings” for employees. Certain organizations may cover a portion of the costs associated with these events. Sponsorship events include participating in or hosting educational, training, or other events for clients and/or employees. These sponsors have greater access to our employees to provide educational and training opportunities. Not all sponsors participate at the same level, and participation is voluntary. Sponsors include companies utilized as primary custodians, companies that manage assets as a part of a client’s portfolio, or companies in which Mercer Advisors may invest client assets. Sponsors include companies such as Charles Schwab, Fidelity, State Street Corporation, Orion Advisor Solutions, AQR Capital Management, National Advisors Trust Company, Dimensional Funds Advisors, BlackRock, and Vanguard among others. Please Note: Sponsorship presents a conflict of interest for Mercer Advisors (i.e., Mercer Advisors has an economic incentive to recommend or utilize the products and/or services provided by event sponsors. There is no corresponding agreement between Mercer Advisors and any sponsor that Mercer Advisors shall initiate or continue to use any sponsor’s affiliated products or services. Mercer Advisors is a large organization with several affiliated entities (together "Mercer Advisors"). Mercer Advisors has business relationships with many unaffiliated counterparties that it may utilize in conjunction with its service offerings to clients, including custodians, brokers, investment platforms, managers, and fund sponsors (together, the “Counterparties”). Mercer Advisors and the Counterparties can participate in joint marketing and/or investment management efforts, including investment symposiums, and event sponsorships. However, these same Counterparties offer certain funds, investment managers, and/or investment products which are utilized in Mercer Advisors’ client investment portfolios. The use of these services in client portfolios is evaluated independent of their sponsorship commitments to determine if it is consistent with 45  Mercer Advisors’ fiduciary duty. These parties can include our primary custodians or others that manage assets as part of our client’s portfolio or in which Mercer Advisors may invest client assets. Please Note: The above relationships present a conflict of interest for Mercer Advisors (i.e., Mercer Advisors has an economic incentive to recommend or utilize the products and/or services provided by such Counterparties. There is no corresponding agreement between Mercer Advisors and any sponsor that Mercer Advisors shall initiate or continue to use any Counterparty affiliated products or services. The InvestHERs program at Mercer Advisors has a dual mission: to be the wealth management firm of choice for female investors and to be the best place to work for women in the financial services industry. The initiative includes mentorship programs, educational events, and affinity groups. The InvestHERs program is a key initiative to drive diversity, equity, and inclusion in the firm and financial services industry. Annually the firm holds the InvestHERs summit to provide educational opportunities for the women of the firm. Dimensional Fund Advisors is the primary sponsor of the summit and provides educational support, facilities, and event planning staff for the event. The benefits received by Mercer Advisors and/or its personnel are not dependent upon or tied to any current and/or future relationship we have with sponsors or counterparties. Mercer Advisors’ representatives do not receive additional compensation for recommending products or services offered by a sponsor or counterparty. Mercer Advisors will not share client information with any sponsor, except with client consent for the specific purposes described in Mercer Advisors’ Privacy Notice. Please Note Conflict of Interest: As part of its fiduciary duties to clients, Mercer Advisors always endeavors to place client interests first. Clients should be made aware, however, that the receipt of economic benefits by Mercer Advisors or its related persons creates a potential conflict of interest that could influence the selection of sponsors’ or counterparties’ products or services. Miscellaneous Mercer Advisors can qualify to receive Orion Preferred Advantage Pricing based upon total net revenues earned by Orion from Mercer Advisors’ clients. As a result, the amount payable by Mercer Advisors for certain other Orion-provided services is reduced if net revenues earned by Orion from Mercer Advisors including fees paid by clients to utilize Orion sub-advisory services meet certain quarterly thresholds. Thus, Mercer Advisors has an economic incentive to allocate assets to Orion. In addition, one of Mercer Advisors’ equity owners, Genstar Capital Partners, LLC, manages one or more private equity funds with ownership interests in Orion. Please Note Conflict of Interest: As the result of the above arrangement/relationships, Mercer Advisors has a conflict of interest in utilizing Orion’s sub-advisory services. As described in Item 10 – Mercer Advisors acquired Kanaly Trust Company through a merger and acquisition. As part of this acquisition, Mercer Global Advisors Inc. transitioned the trust services portion of Kanaly Trust Company to NATC but retained their asset management service relationships for all accounts. Please Note Conflict of Interest: For estate administration services, probate fees are divided equally between NATC and Mercer Advisors. As a result of the probate fee sharing, Mercer Advisors has a conflict of interest when recommending NATC. 46  ITEM 15 – CUSTODY Mercer Advisors shall have the ability to deduct its advisory fee from the client’s custodial account. Clients are provided with written transaction confirmation notices, and a written summary account statement directly from the custodian at least quarterly. Clients should review all such notices and statements. Please Note: To the extent that Mercer Advisors provides clients with periodic account statements or reports, the client is urged to compare any statement or report provided by Mercer Advisors with the account statements received from the account custodian. Please Note: The account custodian does not verify the accuracy of Mercer Advisors’ advisory fee calculation. Mercer Advisors and/or certain of its members engage in other services and/or practices (i.e., bill paying, password possession, trustee service, etc.) These services and practices result in Mercer Advisors having custody of client funds Having such custody requires Mercer Advisors to undergo an annual surprise examination from a qualified CPA and make a corresponding disclosure filing with the SEC for as long as Mercer Advisors provides such services and/or engages in such practices. In addition, certain clients have established asset transfer authorizations that permit the qualified custodian to rely upon instructions from Mercer Advisors to transfer client funds or securities to third-parties are not subject to the annual surprise examination. ITEM 16 – INVESTMENT DISCRETION Mercer Advisors generally has discretionary trading authority (limited power(s) of attorney) on advisory accounts. Mercer Advisors has authority to buy or sell securities on the client’s behalf, as designated for the specific account. Clients can impose restrictions, in writing, on Mercer Advisors’ discretionary authority (e.g., restrict the buying and/or selling of specific securities traded in their account, limiting or prohibiting the use of margin, etc.). ITEM 17 – VOTING CLIENT SECURITIES Mercer Advisors can accept the authority to vote proxies for clients. When voting proxies on behalf of our clients, Mercer Advisors assumes a fiduciary responsibility to vote in our clients' best interests. Authority to vote proxies is included in the client agreement. Relative to engagements by retirement plans under the Employee Retirement Income Securities Act of 1974 (ERISA), Mercer Advisors acknowledges its responsibility as a fiduciary to vote proxies prudently and solely in the best interest of plan participants and beneficiaries. To assist in this effort, Mercer Advisors has retained Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to assist Mercer Advisors proxy voting advice and administrative services. In conjunction with Broadridge, Mercer Advisors has adopted and implemented written policies and procedures reasonably designed vote proxies in the best interest of clients. Generally, absent mitigating circumstances, proxies will be voted consistent with the recommendations of the issuer’s management. Mercer Advisors may exercise its discretion to engage unaffiliated separate account managers and/or sub- advisors to provide portfolio management services to certain accounts. Consistent with its management responsibilities, these managers may assume authority for voting proxies for these accounts. You can request a copy of our proxy voting policies and procedures, or how proxies were voted on your behalf by contacting us at CCO@merceradvisors.com or Compliance Department at 1200 17th Street Suite 2000, Denver, CO 80202. 47  ITEM 18 – FINANCIAL INFORMATION Mercer Advisors has no financial conditions that would impair its ability to meet its contractual commitments to clients. Pursuant to SEC regulations, an audited balance sheet is not required to be provided because Mercer Advisors does not serve as a custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, and six months or more in advance. 48  SUPPLEMENTAL INFORMATION Business Continuity and Contingency Plan Disasters: The company has a Business Continuity Plan which covers natural disasters such as snowstorms, hurricanes, tornados, and/or flooding. The Plan covers human-caused disasters such as loss of electrical power, loss of water pressure, fire, bomb threat, nuclear emergency, chemical event, biological event, T-1 communications line outage, Internet outage, railway accident, and/or aircraft accident. Electronic files are backed up and archived offsite. Information Security: Mercer Advisors maintains an information security program to reduce the risk that personal and confidential client information is breached. Mercer Advisors employs the use of firewalls, virus scanners, and other methods of securitization to help protect client information. Privacy Information Our full Privacy policy along with other information on information security can be found on our website at the Privacy and Security Center. Mercer Advisors reserves the right to change the Privacy Notice at any time without prior notification. Please contact Mercer Advisors for additional information. Brochure Supplements Personnel Brochure Supplements (Form ADV Part 2Bs) are provided to each client by his/her Wealth Management Team. ANY QUESTIONS: Mercer Advisors’ Chief Compliance Officer remains available to address any questions regarding this Part 2A. 49