TRANSAMERICA RETIREMENT ADVISORS, LLC

Item 1 – Cover Page TRANSAMERICA RETIREMENT ADVISORS, LLC Third-Party Money Management Services Brochure 6400 C Street SW Cedar Rapids, IA 52499 (866)-368-0566 May 22, 2025 This brochure provides information about the qualifications and business practices of Transamerica Retirement Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at (866)-368-0566. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Transamerica Retirement Advisors, LLC is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. Additional information about Transamerica Retirement Advisors, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov.  Transamerica Retirement Advisors, LLC May 22, 2025 Item 2 – Summary of Material Changes This section of the brochure highlights changes that were made since Transamerica Retirement Advisors, LLC’s (“TRA”) last annual update on February 14, 2025. This brochure has been updated as follows: Morningstar Investment Services, LLC (“Morningstar”) entered into an agreement with AssetMark, Inc. (“AssetMark”), an SEC-registered investment adviser, whereby certain investment management agreements (“IMAs”), including TRA’s Third-Party Money Management Services program (“TPMM”), will transition from the Morningstar Wealth Platform to a platform managed by AssetMark. AssetMark will assume responsibility for providing the advisory services under your IMA. TRA has entered into an agreement with AssetMark, for AssetMark to provide services to TRA’s Third-Party Money Management Services program. AssetMark has selected various investment management firms to develop, maintain and provide model portfolios and asset allocation strategies among securities and other investments, and AssetMark itself may also serve as a Portfolio Strategist to TPMM accounts. The brochure was updated to make changes to reflect the program’s current third-party money manager, AssetMark, following the transition from Morningstar to AssetMark. Each year, TRA is required to update this brochure within 90 days of its fiscal year end, which is December 31, and must deliver to you the updated brochure or a summary of material changes to the brochure within 120 days of the fiscal year end. Item 3 – Table of Contents Item 1 - Cover Page 1 Item 2 - Summary of Material Changes 2 Item 3 - Table of Contents 2 Item 4 - Advisory Business 3 Item 5 - Fees and Compensation 4 Item 6 - Performance-Based Fees and Side-by-Side Management 7 7 Item 7 - Types of Clients Item 8 - Methods of Analysis, Strategies and Risk of Loss 8 Item 9 - Disciplinary Information 10 Item 10 - Other Financial Industry Activities and Affiliations 10 Item 11 - Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading 12 Item 12 - Brokerage Practices 12 Item 13 - Review of Accounts 13 Item 14 - Client Referrals and Other Compensation 13 Item 15 - Custody 14 Item 16 - Investment Discretion 14 Item 17 - Voting Client Securities 14 Item 18 - Financial Information 14 Page 2  Transamerica Retirement Advisors, LLC May 22, 2025 Item 4 – Advisory Business Our Firm Transamerica Retirement Advisors, LLC (“TRA”) is a registered investment advisory firm that, with its predecessors, has been in business since 1992. TRA is part of the AEGON family of companies, a global leader in pensions. TRA is a wholly owned subsidiary of Transamerica Retirement Solutions, LLC (“TRS”), a firm dedicated to providing services to retirement plans and their participants which is owned by AEGON Ltd, and a publicly traded international insurance group (“AEGON”). As of December 31, 2024, TRA manages approximately $7.110 billion of client assets on a discretionary basis and approximately $9.048 billion of client assets on a non-discretionary basis. Not all these assets are associated with the Third- Party Money Management Services. These figures are computed in the same fashion as in our Form ADV, Part 1A. Please refer to TRA’s other Form ADV brochures for discussions of the other investment advisory services offered by TRA. Our Advisory Services While TRA offers different advisory products and services, this brochure focuses on the Third-Party Money Management Services (“TPMM”). TPMM is a managed asset allocation service that helps clients prepare for, and transition through, retirement. At the outset of the relationship, our phone-based investment advisor representatives located in the Transamerica Advice Center (“TAC”), referred to throughout as (“TAC Advisors”), conduct interviews with clients to determine their financial needs and objectives. The TAC Advisor will make a recommendation to the client about whether to invest in the TPMM service and which strategy within the TPMM service is appropriate for the client at the time. The TAC Advisor will base these recommendations on an analysis of the client’s current financial situation, investment goals, risk tolerance and present investment holdings and strategies. Based on this analysis, the TAC Advisor will then provide recommendations to the client about whether to invest assets with the third-party manager available through TPMM and which investment strategy to consider. Investment Options. TRA offers access to the TPMM program model portfolios through AssetMark, Inc., an SEC-registered investment adviser (“AssetMark”). AssetMark has selected various investment management firms (“Portfolio Strategists”) to develop, maintain and provide allocations among securities and other investments (“Model Portfolios”). AssetMark may also serve as a Portfolio Strategist to TPMM accounts. Pursuant to agreements, Portfolio Strategists develop and maintain the Model Portfolios consistent with certain investment objectives, strategies or investment allocations. Model Portfolios may include equity securities, municipal securities, US government securities, exchange traded notes and/or other securities products. Your TAC Advisor will determine whether the TPMM program is in your best interest and, if so, will recommend a Model Portfolio offered by AssetMark, based on your financial goals and objectives. You make the decision and expressly agree to accept and implement the TAC Advisor’s recommendation of AssetMark, the Portfolio Strategist and the Model Portfolio. Once you sign an agreement with AssetMark (separate from the agreement you sign with TRA), AssetMark or the Portfolio Strategist will have discretionary authority over your account to invest your assets in accordance with the Model Portfolio. The Portfolio Strategist, not TRA, designs the Model Portfolios and selects the investments underlying the model. In addition to determining whether the TPMM program is in your best interest and recommending a Model Portfolio, TAC Advisors will also, prior to making a recommendation, aid you in completing the questionnaire that is designed to elicit information on which the recommendation will be based; help you to understand the investment management process, investment objectives, and the investment strategies undertaken as part of the service; review and complete any required applications or questionnaires; answer questions about the service; and explain any special instructions from you to AssetMark for the management of the assets in an account. Annual Review Report. You will receive an Advisory Review Report at least annually. This comprehensive view of your advisory account(s) will summarize your investment objectives, personal information, and account performance. You are encouraged to review this information to ensure that it is still accurate and consistent with your goals, as changes to this information could impact your asset allocation. Periodically, our team of TAC Advisors may review this Advisory Review Report with you. Also, you are welcome to contact us any time to review your account. Page 3  Transamerica Retirement Advisors, LLC May 22, 2025 Investment Models. The TPMM service offers several Model Portfolios to address different customer needs. Additional description of the Models may be found in AssetMark’s Form ADV Part 2A or other disclosure document. The TPMM service offers the following model strategies: • Active/Passive Asset Allocation Models provide risk-tolerance-based portfolios using a combination of active and passive investments to implement targeted asset allocation ideas. The Models combine actively managed ETFs and mutual funds and/or passive mutual funds. • ESG Asset Allocation Models provide a diversified portfolio built with mutual funds and ETFs that use a variety of sustainable investing approaches. They invest in both active and passive investments in U.S. and international equities. All underlying investments consider environmental, social and governance (“ESG”) factors in their decision-making and portfolio construction process. • ETF Asset Allocation Models provide diversified, risk-tolerance-based actively managed portfolios implemented through investments in, typically, lower cost ETFs. • Mutual Fund Asset Allocation Models provide diversified, risk-tolerance-based actively managed portfolios implemented through investments in mutual funds. • Select Equity Strategy Models provide a series of strategy focused portfolios through investment in individual stocks. • Wealth Builder Models provide simple risk-tolerance-based ETF asset allocation models that offer active management for small balance accounts. TRA’s Due Diligence Committee conducts ongoing monitoring of the Model Portfolios and will work with AssetMark to conduct reviews of Portfolio Strategists with which AssetMark has entered into agreements and TRA determines to make available within the TPMM service to help ensure that the model strategies continue to perform in line with expectations and established benchmarks. Investment Education Services TRA offers investment education services, when elected by an employer-sponsored retirement plan (“Plan”), to certain Plan participants who hold retirement accounts with Transamerica Retirement Solutions LLC (“TRS”), a Plan recordkeeper and service provider, and a TRA affiliate. These services are typically provided by Retirement Plan Consultants (“RPCs”) who are registered representatives of Transamerica Investors Securities, LLC. (“TIS”), an affiliated broker-dealer and who may be investment advisory representatives of TRA. These services are designed to educate participants about the Plan, Plan investment options, the importance of saving early, the value of diversification, and general investment principles. RPCs do not provide Plan participants with advice or recommendations with respect to the selection of securities or services available in their Plan accounts. However, TAC Advisors, not the RPCs, may provide advice and recommendations that a participant subscribe to an in-plan advisory service. As part of these educational services, TRA provides asset allocation models for use by Plans that set different allocations among asset classes and investment styles, so that together the models offer a range of portfolios with different return and risk characteristics. These general educational services are furnished to participants as part of a package of recordkeeping, administrative and technical services to the Plan sponsor through TRS. While TRA does not charge for the provision for these general educational services, the services are part of the bundled services for which TRS charges Plan recordkeeping service fees. When an RPC identifies a client who may benefit from receiving investment advice or the participant requests investment advice beyond the education and guidance that an RPC can provide, the RPC refers the participant to a TAC Advisor. Item 5 – Fees and Compensation You will be charged an advisory fee, a portion of which is paid to TRA and a portion of which is retained by AssetMark and a Portfolio Strategist. The advisory fee is not negotiable. Your total advisory fee for TPMM will range between 0.75%- 1.30%, on an annual basis, based upon the average daily value of your TPMM account, excluding fund and custodial expenses and the model selected (as shown in the table below). The advisory fee is debited from your TPMM account quarterly, in advance, and calculated based on the prior period’s ending balance. You may qualify for a breakpoint fee reduction based upon certain products and/or services purchased and held through Transamerica. Page 4  Transamerica Retirement Advisors, LLC May 22, 2025 Of the total advisory fee paid, TRA typically receives between 0.55% and 0.75%, for the services it provides as described above. All advisory fees paid by you for TPMM are separate and distinct from (1) the fees and expenses charged by mutual funds and ETFs underlying the Models, and (2) custodial and transaction fees charged (discussed more below). You authorize AssetMark to automatically deduct fees from your advisory account(s). Note that AssetMark will charge advisory fees on cash positions as well as securities positions held within your accounts. You should refer to the AssetMark Client Service Agreement or other disclosure document for a complete discussion of the fees and termination procedures associated with TPMM. Annual Advisory Fee Rate Schedule Account Assets* Wealth Builder Models ETF Models Active/Passive Models Mutual Fund Models ESG Models Select Equity Models $0 - $499,999 1.05% 1.05% 1.05% 0.95% 1.15% 1.30% $500,000 - $999,999 0.95% 0.95% 0.95% 0.85% 1.05% 1.20% $1,000,000 - $3,000,000 0.85% 0.85% 0.85% 0.75% 0.95% 1.10% Over $3,000,000 0.70% 0.70% 0.70% 0.60% 0.80% 0.95% $10,000 $25,000 $25,000 $25,000 $25,000 $75,000 Minimum Account Balance** * For fee calculation purposes, TRA aggregates assets in an individual client’s TPMM account with assets that the client maintains within other TRA advisory accounts, a retirement plan account record kept with TRS, and certain other Transamerica brokerage and annuity accounts. ** TRA may waive the minimum account balance requirement in certain instances. The advisory fees you pay includes advisory services and other services and fees, including custodial services, IRA fees and other account or administrative fees related to your account. The advisory fees do not cover brokerage fees and transaction charges, which are charged to your account separately and will be reflected in your account statement. Charles Schwab & Co., Inc. (“Schwab”), which serves as custodian and provides clearing and brokerage services for the TPMM program, has two pricing structures to cover transaction costs. The first pricing model is asset-based pricing, where your account is charged 0.10% (10 basis points) annually to cover all transaction costs for trades on the non-NTF platform. This pricing model is employed primarily for mutual fund-based and hybrid strategies. The second pricing model is transaction- based pricing where you will be assessed charges with each trade in your account. This pricing model is employed primarily for ETF and stock-based strategies. Please refer to your account establishment paperwork, custodial account paperwork, Client Services Agreement and/or AssetMark’s Form ADV Part 2A or similar disclosure document, for additional details on fees and expenses. As noted above, you will indirectly pay your respective share of mutual fund and ETF expenses held within your TPMM account. Those fees and expenses, which are described in the relevant mutual fund or ETF prospectus, include management fees, administrative fees, transfer agency and sub accounting fees, and all other fund operating expenses. These indirect fees and expenses are not included within the advisory fee you pay for advisory services. Mutual funds are offered with different share classes, the expenses of which may differ as disclosed in the prospectus. In addition to the types of fees described above, certain mutual fund share classes charge 12b-1 (servicing and distribution) fees; other share classes do not charge 12b-1 fees. Because 12b-1 fees, typically about 25 basis points (0.25%) per year, add to the cost of investing in the mutual fund, a 12b-1-paying share class of a mutual fund will underperform a non- 12b-1-paying share class of the same fund. As noted above, transactions in TPMM accounts are placed by AssetMark or the Portfolio Strategist through the Schwab platform. Schwab offers two clearing platforms; each includes a variety of mutual funds and ETFs. The two platforms are (1) a “no-transaction fee” (or NTF) platform where no transaction fees are charged for purchases and sales; and (2) a transaction fee platform (non-NTF platform), where there is a separate charge for each purchase and sale placed on behalf of an account. Schwab, not TRA or AssetMark, determines which mutual funds (and mutual fund share classes) and ETFs are included on each platform. Certain mutual funds offered on the NTF platform use 12b-1 share classes, and others use non-12b-1 share classes. Therefore, you will not necessarily purchase the lowest cost share class for which you are eligible, which will lower investment returns. If mutual funds on the NTF platform charge 12b-1 fees, these fees are retained by Schwab as compensation for the clearing services. TRA does not receive any portion of this 12b-1 fee. Page 5  Transamerica Retirement Advisors, LLC May 22, 2025 The Model Portfolios include a mix of mutual funds and ETFs, and, depending on the type of strategy, each generates a different level of trading activity. The Model Portfolios investing in mutual funds, will include only mutual funds that are cleared through the NTF platform. ETFs that are included in the Model Portfolios, however, may be cleared through either the NTF or the non-NTF platform, meaning that a separate transaction charge may apply. Accordingly, Model Portfolios with a higher concentration of ETFs and those that rebalance frequently will incur higher transaction charges than those that are concentrated in mutual funds and/or engage in less frequent rebalancing. Participation in the TPMM program offered through TRA may cost you more than purchasing similar services directly through AssetMark. However, AssetMark’s services available through TPMM are not offered directly to you and are only available through an investment advisor such as TRA. In addition, the TPMM service also includes on-going planning services and monitoring the performance of the Portfolio Strategists as described above. You will receive quarterly statements (or notification that your statements are available to view online) directly from Schwab. These statements will show all transactions, positions, and credits/debits (deposits/withdrawals) in your account. These statements will reflect deductions for advisory fees and other custodial and/or transaction fees paid by you. Advisor Compensation. TAC Advisors and RPCs earn a salary and can also earn an annual bonus, and periodic incentive compensation. TAC Advisors also receive incentive compensation if an individual opens an advisory account. The incentive compensation may be a flat dollar amount, or an asset-based fee calculated on the amount invested in the account and the number of accounts opened during the month. The periodic incentive compensation paid to TAC Advisors is the same across all advisory and brokerage accounts. RPCs receive incentive compensation based on activities performed, which may include number of participant meetings held, discussions about in-plan products/services, and the number of referrals to the TAC. In addition, TRA conducts programs under which both TAC Advisors and RPCs may be eligible to receive non-cash awards and other non-cash benefits. These programs, which may span from one week to several months will generally focus on TAC Advisors’ and RPCs’ activities. This may include the number of phone calls made/received, the amount of time spent in the phone queue, use of certain advisor tools, decreases in not in good order transactions, call quality metrics, number of applications sent, paperwork assists and/or number of referrals to the TAC. The payment of bonus and incentive compensation or non-cash awards and other non-cash benefits does not change the fees that you pay for advisory services. Set forth below is a description of conflicts related to compensation paid to TRA and our TAC Advisors and RPCs. TRA earns an advisory fee for the advisory services it provides. When an individual opens an advisory account such as TPMM, TRA earns compensation for providing such services and thus has an incentive to encourage individuals to open an advisory account or to contribute more to their advisory accounts. TRA seeks to mitigate the conflict by requiring TAC Advisors to follow a process that helps to ensure that that their recommendations are in the client’s best interest and that they have met their fiduciary obligations to the client. When working with a client, TAC Advisors review the investor's financial situation, needs/objectives, and goals amongst other things before making an investment recommendation. TRA requires that the recommendation be reviewed by a supervisor before being approved. Certain products and services are more profitable to us and our affiliates than other products and services. TAC Advisors are also registered representatives of an affiliated broker-dealer firm and certain TAC Advisors are insurance agents of an affiliated insurance agency. As a result, TAC Advisors may be able to recommend a broker-dealer account or an annuity to prospective clients in addition to our investment advisory programs. Most annuities generate higher up-front revenue or compensation to us, TAC Advisors and, possibly, TRA’s affiliates, than other accounts and products. For example, within its advisory services, TRA’s net advisory fees received from the TPMM service, and its Transamerica Personalized Portfolios (“TPP”) advisory service are substantially similar, but they are generally higher than its net advisory fees received for the Managed Advice service (whether available in a Transamerica recordkept retirement plan or as a retail IRA account). However, in certain cases, the aggregate compensation received by TRA and its affiliates in connection with the Managed Advice service may be higher where the Plan sponsor or fiduciary has selected investment options managed or sponsored by a Transamerica entity to be available within the advisory program. The TPMM service does not include proprietary investment options. Page 6  Transamerica Retirement Advisors, LLC May 22, 2025 This differential compensation between products creates an incentive for TRA to recommend those products that are more profitable to the firm and its affiliates. TRA seeks to mitigate this conflict by not setting product-specific sales goals for its TAC Advisors. TRA and its affiliates seek to mitigate the conflict to TAC Advisors by structuring their incentive compensation to be the same across all advisory and brokerage accounts. Additionally, TRA and its affiliates provide training to their respective financial professionals regarding their fiduciary and best interest obligations, and monitor/supervise their sales activity to confirm that they have met their fiduciary or best interest obligations when making a recommendation to clients. TAC Advisors receive direct compensation when a client opens an advisory account. TAC Advisors may assist and recommend that an individual enroll in an in-plan advisory service or transfer or rollover their Plan account balance into a retail advisory account. Because we compensate TAC Advisors for each such transaction, there is an incentive for TAC Advisors to recommend the rollover transaction into a TRA advisory program or to recommend an in-plan advisory service such as Managed Advice or AMA. When making a recommendation to rollover assets from a Plan account into an IRA advisory account or the subscription to the Managed Advice or AMA service, the TAC Advisor is acting in a fiduciary capacity and is required to act in the client’s best interest. TRA seeks to mitigate the conflict by providing training to TAC Advisors regarding their fiduciary obligations to the client, and by monitoring/supervising TAC Advisors’ sales activity to confirm that they have met their fiduciary or best interest obligations when making a recommendation to clients. RPCs receive indirect compensation for referrals to our TAC Advisors. Where appropriate, RPCs may refer participants to TAC Advisors to provide additional services not available through the RPC, which may include providing advice and recommendations about in-Plan investment options, investment options outside of a Plan or answering specific questions about the client’s financial situation, needs and/or objectives. A portion of an RPC’s bonus and incentive compensation is based on their referral activity. The receipt of incentive compensation for referrals creates an incentive for RPCs to make referrals. This conflict is mitigated by making the number of referrals made by an RPC only one of many factors in determining the amount of bonus and incentive compensation earned. Other factors used in determining bonus and incentive compensation include other activity-based goals (such as the number of group meetings held with participants and the number of individual one-on-one meetings with participants), an RPC’s customer service ratings, and personal development goals. Additionally, bonus compensation is tied to corporate financial and non-financial results. TRA further seeks to mitigate the conflict by making the payment of bonus and incentive compensation independent of whether a referral results in the enrollment in a service or the opening of an advisory account. The incentive compensation paid to RPCs does not increase the fees paid by the Plan, Plan Sponsor, or participants. TAC Advisors may lose compensation if you transfer or close your account within a specified period after account opening. TAC Advisors receive compensation when you open and fund an advisory account. If you transfer or close your account within nine (9) months from the account opening date, the compensation paid to the TAC Advisor will be “charged back” or offset against their current compensation. While this practice is designed to help ensure that the TAC Advisor’s recommendation is in your best interest over the long-term, it creates a conflict of interest as the TAC Advisor is incentivized to keep you in your account for at least nine months. This could impact the advice the TAC Advisor provides you during the nine-month window to encourage you to stay in the account a minimum of nine months. TRA seeks to mitigate the conflict by providing training to TAC Advisors regarding their fiduciary obligations to the client. Item 6 – Performance-Based Fees and Side-by-Side Management Neither TRA nor any of its advisory personnel charge performance-based fees with respect to the accounts which they manage. Item 7 – Types of Clients Through TPMM, we typically provide investment advisory services to individuals. However, we may from time-to-time also provide advisory services to corporations or other businesses, trusts, estates, and charitable organizations. For information about the minimum account balance for each of the investment portfolios, please see the table in Item 5. Page 7  Transamerica Retirement Advisors, LLC May 22, 2025 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Methods of Analysis TAC Advisors provide each client with a recommendation regarding the appropriateness of investing in the TPMM service. When making a recommendation of whether to invest in the TPMM service, our TAC Advisors will take into consideration information provided by you, the capabilities of the services, the expenses associated with the services, and how these factors align with your goals at the time. Currently, only one third-party manager, AssetMark, is available through TPMM. TRA may select additional third-party managers for TPMM. Generally, in selecting third-party managers for TPMM, TRA selects registered investment advisers using the following criteria: Investment philosophy and strategy of the manager • • Historical performance record of manager model portfolios using rolling returns over of varying time periods • Comparison of performance track records of the manager against their peers and benchmarks • Costs • Tenure of key portfolio managers • Breadth and depth of personnel • Firm culture • Regulatory history and reputation • Transparency and communication with us The methods of analysis, sources of information and investment strategies used will vary. We encourage you to read AssetMark’s Form ADV Part 2A, AssetMark’s Client Agreement and any other document you receive before entering an agreement with AssetMark. Investment Strategies The Portfolio Strategists will provide Model Portfolios typically utilizing either ETFs or mutual funds to implement their investment models. In some cases, a Portfolio Strategist may include equity securities, municipal securities, US government securities, exchange traded notes and/or other securities products within its investment strategies. While a Portfolio Strategist may have demonstrated a certain level of success in past economic conditions, the Portfolio Strategist may not be able to replicate that success in future markets. In addition, although a Portfolio Strategist may have invested in a certain manner in past years, it may deviate from its strategy in future years. To mitigate these risks, TRA seeks to select Portfolio Strategists with a proven track record that have demonstrated a consistent level of performance and success. TRA also conducts annual due diligence on AssetMark, and the Portfolio Strategist(s) utilized for TPMM, which includes a review of consistency in investment approach among the other factors described above. Risk of Loss All investments in securities include a risk of loss of your principal. Stock markets and bond markets fluctuate over time and clients may lose money. You should be prepared to lose money in an investment account offered through TRA. Investments are not a deposit of a bank and are not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. You may lose money by investing in investment products. Each investment strategy offered by the advisory programs offered by TRA poses risks, and many factors affect each investment’s performance or account’s performance. Investments or accounts are also subject to volatility in non-U.S. markets through either direct exposure or indirect effects in the U.S. markets from events abroad. Investments or accounts that seek exposure to debt are subject to risks of prepayment or default, and model portfolios that concentrate in particular industries, or are otherwise subject to particular segments of the market that may be significantly impacted by events affecting those industries or markets. In addition, the investments in your advisory account may be subject to the following specific risks: Page 8  Transamerica Retirement Advisors, LLC May 22, 2025 Model Risk The Model Portfolios and computer software and systems are based on generally accepted principles of modern investment theory. However, like all models, algorithms and/or calculations (“Models”), tools have inherent risks. Models may incorrectly forecast future behavior or produce unexpected results, including losses. The success of using Models depends on numerous factors, including the validity, accuracy and completeness of the Model’s development, implementation and maintenance, the Model’s assumptions, factors, algorithms and methodologies, and the accuracy and reliability of the supplied historical or other data. If incorrect data is entered into even a well-founded Model, the resulting information will be incorrect. Investments selected with Models may perform differently than expected due to the design of the Model, inputs into the Model, or other factors. In addition, changes to a Model, although subject to compliance controls and testing, may not have the desired effect with respect to an investor’s account. While this risk increases if changes to a Model are insufficiently tested prior to implementation, even extensively tested changes may not produce the desired effect over time. The advice generated from the Portfolio Strategist is partly dependent on information received from you and other third parties and external sources, meaning the service could be impacted depending on the accuracy of the information provided. Cybersecurity and Technology Risk The Model Portfolios and computer software and systems used by AssetMark and or the Portfolio Strategists are dependent upon algorithms, as well as other various computer and telecommunications technologies, many of which are provided by or are dependent upon third parties such as data feed, data center, telecommunications, or utility providers. The successful deployment, implementation, and/or operation of such activities and strategies, and various other critical activities of TRA on behalf of its clients, could be severely compromised by system or component failure, telecommunications failure, power loss, a software-related “system crash”, fire or water damage, human errors in using or accessing relevant systems, unauthorized system access or use (e.g., “hacking”), computer viruses, or various other events or circumstances. It is not possible to provide fool-proof protection against all such events, and no assurance can be given about the ability of applicable third parties to continue providing their services. Any event that interrupts such computer and/or telecommunications systems or operations could have a material adverse effect on TRA’s clients, including preventing TRA from trading, modifying, liquidating, and/or monitoring its clients’ investments. Risk of Investing in ETFs Shares of an ETF trade on an exchange, and therefore, the value of such shares may differ from the value of the ETF’s underlying investments. ETFs may trade at a market price which reflects a “premium” or a “discount” to the net asset value (“NAV”) of their shares. If the market price is higher than the NAV, the ETF is said to be trading at a “premium.” If the price is lower, it is trading at a “discount”. Accordingly, ETFs may be purchased at prices that exceed the NAV of their underlying investments and may be sold at prices below such NAV. Under such circumstances the sale of ETF shares sold at a discount may not reflect the NAV of the underlying investments of those ETF shares. Moreover, there are costs associated with purchasing and selling ETFs, called a “big-ask” spread (the difference between what a buyer is willing to pay (bid) for an ETF and the seller’s offering (ask) price). All these transaction costs (which do not apply to the purchase and sale of mutual funds) will adversely affect the performance of TPMM portfolios, which, at this time, invest primarily in ETFs. Risk of Investing in ETFs and Mutual Funds (“Funds”) To the extent your account is invested in Funds, your account will be subject to the performance of the Funds held in your account. Additionally, your account will be subject to the risk that the Funds will not meet their investment objectives, and you will be exposed to the risks of the Funds in your account, which risks are based on those Funds’ underlying investments. You should expect to be subject to the following risks: • Market Risk. The risk that securities in a Fund go up or down due to factors affecting the securities markets generally or a particular industry. • • Equity Securities Risk. The risk that prices of equity securities held by a Fund are generally more volatile than the prices of fixed income securities, and that equity security prices will rise and fall in response to a number of different factors, including events that affect particular companies as well as events that affect entire financial markets or industries. Interest Rate Risk. The risk that the value of fixed income securities in a Fund will decline because of an increase in interest rates. • Credit Risk. The risk is that fixed income securities in a Fund will be unable to meet their financial obligations causing a decline in the value of the securities and, as a result, in the Fund. • Foreign Investment Risk. The risk that a Fund’s investments in securities issued by foreign issuers will be subject to fluctuations in currency exchange rates, political instability, and foreign taxes, which risks may be more pronounced for issuers in developing or emerging market countries. Page 9  Transamerica Retirement Advisors, LLC May 22, 2025 To learn more about Fund-specific risks, you should review the prospectuses of the Funds available in your account. TRA will monitor and perform due diligence on AssetMark, and the Model Portfolios provided by the Portfolio Strategist. Investing in securities can involve a risk of loss to your principal. TRA cannot guarantee any level of performance or prevent losses in your account. Please refer to AssetMark’s Form ADV Part 2A or other disclosure document for information on risks related to their specific methods of analysis and investment strategies including risks associated with using Models and investing in mutual funds and ETFs. Item 9 – Disciplinary Information On January 17, 2025, the SEC issued an order regarding TRA’s failure to disclose certain conflicts of interest. Without admitting or denying the findings, TRA consented to the entry of the order finding that it had violated Section 206(2) of the Advisers Act by failing to adequately disclose conflicts of interest related to incentive compensation paid to its investment advisor representatives between June 1, 2017 and February 1, 2022, and Section 206(4) and Rule 206(4)-7 promulgated thereunder by failing to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act in connection with such disclosures of conflicts of interest. As part of the settlement, TRA was ordered to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 206(4) of the Advisers Act and Rule 206(4)-7 promulgated thereunder and ordered to pay a civil money penalty in the amount of $2.9 million, which penalty amount shall be distributed to affected investors. Item 10 – Other Financial Industry Activities and Affiliations TRA is an indirect wholly owned subsidiary of AEGON. Various direct or indirect subsidiaries of AEGON are engaged in investment advisory, brokerage, banking, or insurance businesses. TRA may have material business arrangements with the affiliates described below and certain TRA officers may serve as officers of one or more of these affiliates. Aegon USA Investment Management, LLC TRA has entered into compensation arrangements to act as an introducer for Aegon USA Investment Management, LLC (“Aegon AM US”) in connection with advisory services provided in connection with defined benefit retirement plans. Aegon AM US compensates TRA and other Transamerica affiliates as applicable out of its own resources based on a percentage of the management fee it earns from the account a solicitor has introduced. This arrangement does not increase the fees charged by Aegon AM US to any client. Administrative Group, LLC Administrative Group, LLC dba TAG Resources, TAG, or Transamerica Fiduciary Services provides administrative and certain fiduciary services for plan sponsors of 401(k) and profit-sharing plans with a focus on pooled plan arrangements. Additionally, within certain retirement plans serviced by this entity, the Managed Advice service may be made available to participants and plan recordkeeping and related services are provided by TRS. Transamerica Asset Management, Inc. Transamerica Asset Management, Inc. (“TAM”) serves as an investment adviser to a family of mutual funds known as the “Transamerica Funds”. Transamerica Funds may be selected by Plan sponsors for investment by Plan participants and such funds may be utilized within Managed Advice and Advisor Managed Advice services and Today’s Advice. Transamerica Funds may also be selected by Morningstar for investment within the Managed Advice IRA. Investment in the Transamerica Funds generates revenues for TAM and its affiliates. Transamerica Capital, LLC Transamerica Capital, LLC ("TCL") is a wholesaler and underwriter for various Transamerica products, including mutual funds and variable annuities. These TCL wholesaled and underwritten products may be used as retirement plan options and may be held by pension plan clients. TCL and its employees may receive compensation for the sale of such products based on the number of sales and/or assets under management. Transamerica Financial Life Insurance Company/Transamerica Life Insurance Company Transamerica Financial Life Insurance Company (“TFLIC”) and Transamerica Life Insurance Company (“TLIC”) issue group annuities to be used as funding vehicles for retirement and pension plans, and individual variable and fixed annuities to individual retail investors. Group annuities may be included as investment options within the Managed Advice and Advisor Page 10  Transamerica Retirement Advisors, LLC May 22, 2025 Managed Advice advisory services. Certain TRA advisors who are licensed insurance agents of TRIA (defined below) may be appointed with TLIC/TFLIC. Transamerica Investors Securities, LLC Transamerica Investors Securities, LLC ("TIS") is a registered broker-dealer and a wholly owned subsidiary of TRS. TAC Advisors, RPCs and CEs are registered representatives of TIS. Transamerica Retirement Insurance Agency, LLC Transamerica Retirement Insurance Agency, LLC (“TRIA”) is a 50-state registered insurance agency and wholly- owned subsidiary of TRS. Certain TRA advisors are licensed insurance agents of TRIA, and they are authorized to sell certain life insurance and fixed and indexed annuity products. In their role as insurance agents, TRA phone-based advisors receive a portion of the commission earned by TRIA in connection with the sale of such products. Transamerica Retirement Solutions, LLC Transamerica Retirement Solutions, LLC (“TRS”) is a retirement services firm offering a range of products and services, including recordkeeping, participant education and communications, Plan design, Plan testing, general ERISA, and IRS compliance, as well as investment products to fund these Plans. Transamerica Trust Company Transamerica Trust Company (“TTC”) sponsors collective trust funds for Plans and provides directed trustee and custodial services to retirement plans. If selected by the Plan sponsor, TTC collective trust funds may be available as investment options within TRS-recordkept retirement plans and may be used within the Managed Advice advisory service. Conflicts of Interest • Our affiliates benefit if your account includes proprietary investment options. An account may include proprietary investment options that are advised, managed, serviced, or sponsored by a TRA affiliate such as mutual funds, collective investment trusts (“CITs”) and/or stable value products. Where a proprietary investment option is in the TPMM, TPP, Managed Advice or AMA service, TRA’s affiliates receive compensation for the services they provide in connection with those options. For example, Transamerica mutual funds and CITs will typically assess fees for various services, including management/advisory services, administration, shareholder, and/or transfer agency services, distribution services, and trustee services, which fees are typically included in the mutual fund or CIT’s share price. Also, where a stable value annuity contract is available, such as the Transamerica IRA Stable Value Option available in TPP, Transamerica life insurance companies earn revenue based on the difference between the interest rate credited on your investment and the insurance company’s interest revenue on assets invested in the contract. TRA seeks to mitigate the conflict by ensuring that neither it nor its affiliates exercise discretion or have responsibility for the allocation of assets within the TPP accounts, Managed Advice or AMA advisory accounts. With respect to Managed Advice and AMA, the Plan sponsor or other appropriate fiduciary is responsible for selecting the investment options available in the Plan from a large selection of proprietary and non-proprietary investment options and share classes available on TRS’ platform. Within Managed Advice IRAs, Morningstar is responsible for the selection of available investment options from a large selection of proprietary and non- proprietary investment options and share classes. Within TPP accounts, GSAM is responsible for the selection of investments from a large selection of proprietary and non-proprietary investments and share classes. GSAM is also responsible for the allocation of assets to the eligible investments within the TPP service. Additionally, TRA mitigates this conflict by utilizing a third-party manager for selecting 1) the investment options used in their model asset allocation portfolios, 2) investment allocations and recommendations, and 3) their methods of analysis and investment strategies. The third-party managers are independent from TRA. The TPMM service does not include proprietary investment options. • Transamerica personnel receive incentive compensation for making referrals to the Firm. Where appropriate, retirement call center representatives within our TRS record keeping business may refer Plan participants to TAC Advisors for investment-related and advisory services. Call center representatives receive a flat dollar amount for such referrals. The receipt of incentive compensation for referrals creates an incentive for these call center representatives to make referrals. The conflict of interest is mitigated by making the payment of incentive compensation independent of whether the referral results in the opening of an advisory account or the provision of advisory services. The incentive compensation paid to call center representatives Page 11  Transamerica Retirement Advisors, LLC May 22, 2025 does not increase the fees you pay if you enroll in the TPMM service. Where appropriate, Transamerica client executives (“CEs”), who are registered representatives of TIS and provide direct support to retirement plan sponsors and administrators of those plans, may refer plan sponsors that are interested in making in-plan Managed Advice available to their participants, or may refer a plan that has requested the TAC Advisors to provide investment advisory services to participants. CEs are eligible to earn a bonus based on this referral activity and, as a result, they are incented to make referrals. Referral bonuses are based on assets within the Plan, the adoption rate of Managed Advice by Plan participants, as well as total assets rolled over by TAC Advisors into an advisory account. CEs provide education and information regarding Managed Advice, and the decision whether to offer Managed Advice is made by the Plan’s fiduciary, not TRA or the CE. Additionally, CEs do not communicate directly with Plan participants, including as it relates to subscribing to the Managed Advice service or with respect to the investment advisory services offered by TRA. CEs may conduct certain activities coordinated with the Plan sponsor, such as providing Plan marketing campaigns or conducting focused educational meetings and outreach. The bonuses paid to CEs do not increase the fees paid by the Plan, Plan sponsor, or participants. In addition, Transamerica retirement vice presidents (“RVPs”), who are registered representatives of TIS and who support TRS recordkeeping business by wholesaling retirement plan services, may provide education regarding the in-plan Managed Advice service. RVPs are eligible to earn a bonus based on whether the Plan selects the advisory service and, as a result, they are incented to suggest that the Plan sponsor elect the Managed Advice service for its Plan. We mitigate this conflict of interest by prohibiting RVPs from making recommendations of TRA’s advisory services. Additionally, RVPs do not meet with and do not communicate directly with Plan participants. The compensation paid to RVPs does not increase the fees paid by the Plan, Plan sponsor or participants. TRA may be subject to additional conflicts of interest specific to other investment advisory services offered by the Firm. Please see the Form ADV Part 2A Brochures for TRA’s other investment advisory services to review those conflicts of interest, as well as the Firm’s efforts to mitigate or remove those conflicts. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading TRA has adopted a code of ethics (the “Code”) under Rule 204A-1 under the Investment Advisers Act of 1940, which sets forth certain restrictions and standards of conduct for TRA’s advisory personnel. While the Code permits such employees to invest in securities that may be held or acquired by TRA’s advisory clients, it prohibits specific types of personal securities transactions that may give rise to substantial conflicts of interest. It also establishes reporting requirements through which certain employees provide information to TRA on their personal securities transactions. More generally, the Code prohibits employees from taking inappropriate advantage of their position with TRA and provides that TRA may sanction employees who violate the Code. Any client or prospective client may obtain a copy of the Code without charge by calling 866-368- 0566 or writing to us at Transamerica Retirement Advisors, LLC, 6400 C Street SW, Cedar Rapids, IA 52499. Item 12 – Brokerage Practices Transactions in Funds for the TPMM program are executed by the third-party manager/Portfolio Strategist through Schwab, an unaffiliated clearing broker-dealer. Clearing fees are charged to your account on an asset or per transaction basis. If asset basis is selected, the account will be charged a fee every quarter, depending on the qualified custodian, based on the average daily balance of your account(s). If a per transaction basis is selected, you will be charged a transaction fee in the calendar quarter the transactions are made based on a specific rate per trade. TAC Advisors will inform you of the clearing fees involved. Please read AssetMark’s Form ADV Part 2A or similar disclosure document and your client agreement for important information about their brokerage practices. Page 12  Transamerica Retirement Advisors, LLC May 22, 2025 Item 13 – Review of Accounts You will receive an Advisory Review Report at least annually. This comprehensive view of your advisory account(s) will summarize your investment objectives, personal information, and account performance. You are encouraged to review this information to ensure that it is still accurate and consistent with your goals, as changes to this information could impact your asset allocation. Periodically our team of TAC Advisors may review this Advisory Review Report with you by phone and you are welcome to contact us at any time to review and update your account. Please refer to AssetMark’s Form ADV Part 2A or similar disclosure document for information related to AssetMark’s review of TPMM client accounts. Periodically, TRA delivers an Annual Due Diligence Questionnaire to AssetMark. TRA reviews AssetMark’s answers to the questionnaire with our Due Diligence Committee. The Committee may vote to retain AssetMark or, if material irregularities are noted during a review, terminate its relationship with AssetMark. The Committee will also review publicly available information annually and more frequently, if necessary, to help ensure AssetMark is still an appropriate firm to provide the TPMM platform, and the Model Portfolios are appropriate for the TPMM program. You will receive periodic account statements, transaction confirmations, annual review report and/or performance reports. We urge you to carefully review these reports and compare your custodial statements with your performance reports. The information in your performance reports may vary from your custodial statements due to accounting procedures, reporting dates, or valuation methodologies of certain securities. In the event of any discrepancies, you should rely on the statements you receive from the custodian of your assets. We urge you to carefully review these documents and notify TRA if you have any questions. Item 14 – Client Referrals and Other Compensation For certain Plan sponsors, in accordance with Rule 206(4)-1 under the Advisers Act, TRA is authorized to market and refer the services of a third-party registered investment adviser (“Third-Party Adviser”) to participants who have terminated from their Plan or are otherwise interested in rolling monies out of a retirement plan. The Plan sponsors for which TRA may conduct referral activity is limited to those Plan sponsors where the Third-Party Adviser serves as a fiduciary to the Plan. While TRA receives a referral fee for referrals to the Third-Party Adviser, TAC Advisors do not receive compensation for such activity. The compensation paid to TRA is ongoing and is calculated as a percentage of the advisory fees charged to the participants by the Third-Party Adviser within a non-Plan advisory account. The participants who may be referred by a TAC Advisor to the Third-Party Adviser is limited to those who are in a Plan where the Third-Party Adviser serves as a fiduciary to the Plan. Because TRA contracts with and is paid by the Third-Party Adviser for the referral, any recommendation regarding such Third-Party Adviser presents a conflict of interest. A written disclosure regarding this conflict is provided to the referred clients, which explains TRA’s role, the TAC Advisor’s role as a referral agent, the compensation paid to TRA, and other terms of the relationship between TRA and the Third-Party Adviser. The affiliated personnel listed below make referrals to TAC Advisors. For more information about these referrals, including the compensation paid and the conflicts of interest associated with such referral activity, please see Item 5 regarding Advisor Compensation, and Item 10 regarding Conflicts of Interest. • Certain retirement call center representatives in our TRS recordkeeping business may refer participants to TAC Advisors if it is determined that a participant requires investment advice. Such representatives receive a flat dollar amount for such referrals. • CEs and RVPs who support TRS’s retirement business receive incentive compensation if a Plan sponsor elects to offer the Managed Advice service within a retirement plan. CEs and RVPs are limited to providing education regarding the Managed Advice service and are prohibited from making recommendations of the service. CEs also receive incentive compensation for referring a plan that has requested the TAC Advisors to provide investment advisory services to participants. • RPCs may refer participants to TAC Advisors to provide additional services not available through the RPC, which may include providing advice and recommendations about in-Plan investment options, investment options outside of a Plan, or answering specific questions about the client’s financial situation, needs and/or objectives. Page 13  Transamerica Retirement Advisors, LLC May 22, 2025 TRA may make other referrals in connection with its defined benefit advisory services. Please see TRA’s Form ADV Part 2A Brochure for Defined Benefit Plan Investment Advisory Services for additional details. Except as disclosed, TRA has not entered into any solicitor arrangements whereby we pay a third-party to market our advisory services. Item 15 – Custody In connection with TPMM, TRA does not have custody over funds held in your account(s) and does not hold physical custody of any of these funds. However, in connection with its other investment advisory services discussed in its other Form ADV brochures, TRA is deemed to have limited custody over funds held in your account(s) as a result of its ability to deduct advisory fees directly from your account(s), but we do not hold physical custody of any of these funds. Assets in TPMM accounts are held with Schwab, an independent qualified custodian. You will receive account statements at least quarterly from the custodian. You should carefully review account statements for accuracy. Item 16 – Investment Discretion TRA recommends to you a Model Portfolio available in the TPMM program, but TRA does not have discretion over your account(s). You must expressly agree to implement the TAC Advisor’s recommendation of a TPMM account and the underlying Model Portfolio of the Portfolio Strategist. Once you decide to implement the TAC Advisor’s recommendation and sign an agreement with AssetMark, AssetMark or the Portfolio Strategist will exercise limited discretion over your account(s) to execute transactions as necessary to i) track any reallocations, rebalance or other adjustments to your Model Portfolio, ii) implement changes recommended by AssetMark or your Portfolio Strategist, iii) effect sale transactions of specified securities as directed by you and purchases of replacement securities; and iv) implement any individual securities restrictions imposed on your account(s) by you. Upon specific request to TRA, clients can impose reasonable restrictions on the TPMM service. Item 17 – Voting Client Securities TRA does not accept authority to vote proxies on securities held in your account(s). Regarding TPMM services, you should refer to AssetMark’s or the Portfolio Strategist’s Form ADV Part 2A or other disclosure documents for a complete description of their proxy voting procedures. These documents will explain whether you will receive proxies or other solicitations directly from the custodian. Item 18 – Financial Information We are not subject to any financial condition that is reasonably likely to impair our ability to meet our commitments to clients and have not been the subject of a bankruptcy petition. Page 14