Wells Fargo Advisors

Part 2A of Form ADV Firm Brochure for: Fee-Based Planning Services 801 - 37967 Investment Advisory Services of Wells Fargo Advisors Revised March 2026 Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC, a registered broker-dealer and non-bank affiliate of Wells Fargo & Company. One North Jefferson, St. Louis, MO 63103 Phone (314) 875-3000 www.wellsfargoadvisors.com This brochure provides information about the qualifications and business practices of Wells Fargo Clearing Services, LLC and our Fee-Based Planning Services. This information should be considered before becoming a Client. If you have any questions about these services or the contents of this brochure, please contact us at the telephone number above. This information has not been approved or verified by United States Securities and Exchange Commission or by any state securities authority. Additional Information about Wells Fargo Clearing Services, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. Please note that registration as an investment adviser does not imply a certain level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involve risk, including the possible loss of principal. Investment and Insurance Products are: • Not Insured by the FDIC or Any Federal Government Agency • Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate • Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested 596409 (Rev 05 - 03/26) Page 1 of 18  Summary of Material Changes This section describes the material changes to Wells Fargo Clearing Services, LLC’s (“WFCS”) Part 2A of Form ADV (“Brochure”) for the Fee-Based Planning Services Program since the annual version of this Brochure dated March 2025. WFCS conducts business under the trade name Wells Fargo Advisors (“WFA”). The summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. Clients are encouraged to read this Brochure in detail and contact their Financial Advisor with any questions. Fee-Based Planning Services section of the document has been updated to describe Business Owner Planning, which has been added to the list of services available in the Fee-Based Planning Services Program. Disciplinary Events sub-section of Additional Information has been updated to include: In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. Fees and Compensation section has added information related to compensation for the financial professionals that service WFA clients. Compensation Related to Our Financial Advisors and Branch Management Financial Advisors. Financial Advisors providing service to Clients from either a WFA branch or an office located in a Wells Fargo Bank, N.A. branch receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Financial Advisors discount certain client fees and commissions, or client relationship asset levels are below minimums established by us. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFA advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor’s expense budget and bonus increase, and the Financial Advisor may qualify for recognition trips. Also, as mentioned above the payout schedule is reduced when certain fees are discounted, thus Financial Advisors are discouraged from providing discounts below certain thresholds when negotiating discounts to commissions for brokerage accounts and Program Fees for Advisor Program Accounts. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial Advisor has an incentive to recommend that you invest account assets in an advisory account which have ongoing Program Fees (discussed above) versus a brokerage account which have transaction-based fees. Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities- Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Solutions Team. Financial Advisors receive compensation for each client referred to the Solutions Team, described in the Personalized Unified Managed Account section above. However the Financial Advisor could provide these same services directly to the Client. As a result of the compensation details provided above, Financial Advisors have a financial incentive to not refer otherwise eligible clients to WFA Solutions due to the greater compensation if the Financial Advisor serves the client directly, as these assets will be attributed to those of the Financial Advisor for compensation pay-out, bonus and recognition purposes. 596409 (Rev 05 - 03/26) Page 2 of 18  Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Financial Advisors are also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include overall company performance, reaching certain production levels, tenure with the Firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices. These incentives—particular ones based on production levels (i.e. revenue and profit generated for the Firm), product mix, asset gathering and referrals to affiliates—result in Financial Advisors being encouraged to recommend courses of action that increase your usage of products and services offered by us and our affiliated companies such as Wells Fargo Bank, N.A. and Wells Fargo Securities, LLC. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following three components: an up-front payment; a deferred compensation component; and a back-end bonus arrangement based on new client assets transitioned/gathered over a three-year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFCS. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFCS. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFCS and WFCS's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of certain titles and/or education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Supervisor Compensation. Branch Managers and Area Managers (who are responsible for supervising Financial Advisors operating from a Wells Fargo Bank, N.A. branch) are compensated based on the total revenue generated by the Financial Advisors subject to their supervision. A portion of the Branch Manager’s and Area Manager’s compensation is also based on the branch meeting business growth targets—such as net asset flows from clients, client usage of lending products, financial advisor recruitment and retention, and client usage of affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.—and branch profitability. Therefore, Branch Managers and Area Managers have an incentive to encourage Financial Advisors to recommend products and services that increase or maximize revenue and profit received for the Firm. When Branch Managers and Area Managers serve as Financial Advisors to brokerage and advisory account clients, the Branch Manager (or Area Manager) is compensated as described above for Financial Advisors. Market Growth Strategy Consultants. Market Growth Strategy Consultants support branch-based Financial Advisors and Branch Managers in the growth of WFA advisory accounts. Market Growth Strategy Consultants are compensated by salary and a bonus based on gross asset flows in in Advisory Program Accounts at the branches that they are responsible for supporting and on gross assets referred to the Wells Fargo Bank, N.A. trust services platform. Therefore, the Market Growth Strategy Consultant has a conflict of interest, and is incentivized to emphasize the potential benefits of WFA Advisory Program Accounts and trust and investment management services provided by Wells Fargo Bank, N.A. when providing support to Branch Managers, Financial Advisors, or when joining Financial Advisors in discussions with Clients considering an Advisory 596409 (Rev 05 - 03/26) Page 3 of 18  Program Account or contributing additional funds to an existing Advisory Program Account. IRA Rollovers – Conflicts and Incentives to Transfer Assets from Employer-Sponsored Qualified Retirement Plans to WFA Financial Advisors have an incentive to recommend that you roll over assets from an employer-sponsored Qualified Retirement Plan ("QRP"), such as a 401(k), to an Individual Retirement Account ("IRA") with us. If you are rolling over assets, you should carefully evaluate all choices which are typically available. We have a conflict of interest in connection with a rollover of your assets into an IRA and the investment of the assets with us as opposed to leaving the assets in your former employer's plan or electing another option. The conflict arises because we will likely earn no compensation if you were to leave the assets in your former employer's plan or transfer to your new employer's plan. In addition, the costs of maintaining and investing assets in an IRA with us will generally involve higher costs than the other options available to you. While we typically offer a broader range of investment options and services than an employer-sponsored QRP, there are no guarantees that the additional investment options will outperform your employer-sponsored QRP. 596409 (Rev 05 - 03/26) Page 4 of 18  Table of Contents Summary of Material Changes................................................................................................................. 2 Advisory Business.................................................................................................................................... 6 Firm Description and Ownership.................................................................................................. 6 Types of Advisory Services ......................................................................................................... 6 Fee-Based Planning Services ..................................................................................................... 6 Services Tailored to Individual Client Needs ................................................................................. 8 Portfolio Management Services ................................................................................................... 8 Assets Under Management ......................................................................................................... 8 Fees and Compensation .......................................................................................................................... 8 Performance-Based Fees and Side-By-Side Management .............................................................11 Types of Clients ...............................................................................................................................11 Methods of Analysis, Investment Strategies and Risk of Loss ...........................................................12 Disciplinary Information ..........................................................................................................................12 Other Financial Industry Activities and Affiliations ..............................................................................14 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 16 Brokerage Practices ...................................................................................................................... 17 Review of Accounts ....................................................................................................................... 17 Client Referrals and Other Compensation .............................................................................................17 Custody .....................................................................................................................................................18 Investment Discretion ..............................................................................................................................18 Voting Client Securities ...........................................................................................................................18 Financial Information ...............................................................................................................................18 596409 (Rev 05 - 03/26) Page 5 of 18  Advisory Business Firm Description and Ownership Wells Fargo Advisors (“WFA”) is a trade name used by Wells Fargo Clearing Services, LLC ("WFCS") and Wells Fargo Advisors Financial Network ("WFAFN"). WFA, whose predecessors span more than 150 years, is a leading national securities firm providing investment and other financial services to individual, corporate, and institutional Clients. It is a non-bank affiliate of Wells Fargo & Company (“Wells Fargo”), a publicly held company (NYSE: WFC), and financial holding company and bank holding company founded in 1852. Wells Fargo and its Affiliates are engaged in a number of financial businesses, including retail brokerage and investment advisory services. WFCS is affiliated with WFAFN, a broker-dealer also providing advisory and brokerage services. Information about the advisory and brokerage services offered by WFAFN is available by contacting them directly. WFA is also affiliated with Wells Fargo Investment Institute, Inc. (“WFII”), a registered investment adviser that provides advisory services and research to WFA. The terms “Client,” “you,” and “your” are used throughout this document to refer to the person(s) or organization(s) who contract with us for the Services described here. “WFA,” “we,” “our,” and “us” refer to WFA together with our Affiliates, including but not limited to, Wells Fargo and its agents with respect to any services provided by those agents. “Affiliate” means any entity that is controlled by, controls or is under common control with WFA. Each Affiliate is a separate legal entity, none of which is responsible for the obligations of the other. “Account” means collectively or individually any brokerage Account and/or any Advisory Program Account you have with us, including any and all funds, money, securities and/or other property you have deposited with us. “Securities and/or Other Property” means, but is not limited to, money, securities, financial instruments and commodities of every kind and nature and related contracts and options, distributions, proceeds, products and accessions of all property. Types of Advisory Services We sponsor a number of wrap fee advisory programs that are designed to help Clients meet their investment objectives and goals. They include Unified and Separately Managed Account Programs, Mutual Fund Advisory Programs, Financial Advisor-Directed Programs and Non-Discretionary Advisory Programs (“Programs”). We also offer Consulting and Financial Planning advisory services. This Disclosure Document is being provided pursuant to Section 204 of the Investment Advisers Act of 1940 and deals solely with our Fee-Based Planning Services. Descriptions of the services and fees for the other Programs and services we offer can be found in separate disclosure documents, copies of which are available upon request. Fee-Based Planning Services We offer personal planning and consulting services (“Services”) to both prospective and existing Clients under a Fee-Based Planning Services agreement (“Agreement”). Prior to providing this planning and consulting advice for you, your Financial Advisor (“FA”) will obtain information about you. Generally, we offer these Services to prospective or existing Clients with a minimum net worth of $250,000, inclusive of real estate and other assets you own held at other financial institutions. The types of information we obtain from you can include, but are not limited to: • Your current financial situation, including the amount and nature of your assets and liabilities, the amounts and sources of current and anticipated income, the amounts and types of current and projected expenses (including education expenses), and insurance coverage; • Your current and long-term financial and wealth transfer goals, objectives, and desires (including retirement goals); and • Other information as relevant to your specific engagement. The scope and duration of the Services and the fees that we charge will vary based on the complexity of your financial situation and your net worth (for the determination of fees). The descriptions of Services listed below are not exhaustive and are included to illustrate the typical areas included within each Service. Through Fee-Based Planning, you can elect to receive advice and recommendations related to the following Services: 596409 (Rev 05 - 03/26) Page 6 of 18  Cash Flow Analysis Cash flow planning may include support in the budgeting process, debt management, planning around major purchases and associated financing options, home purchase and mortgage analysis, income planning, and reviewing potential tax considerations. Education Planning Education planning may involve support in reviewing educational goals, developing savings strategies and evaluating funding alternatives, education around financial aid, review of student loans options, debt repayment strategies and discussion of potential tax credits. Retirement Planning Retirement planning may involve support in identifying goals, developing savings strategies, education around federal benefits, reviewing employer-based stock benefits, and evaluation of distribution strategies. Risk Planning Risk planning may involve the review of existing policies and needs for protection in case of disability, long-term care, or in case of death, as well as other types of insurance products, and assistance in the evaluation of employer benefit programs. Wealth Planning Wealth transfer planning may involve assistance in designing gifting strategies, reviewing potential estate and trust planning strategies, discussion of benefits related to property ownership and titling and beneficiary designation considerations. Divorce Planning Divorce planning may involve assistance with budgeting, calculating divorce payments, evaluating alimony and child support, potential tax credits or deductions, tracing of asset ownership, and future value calculations of retirement accounts and pension funds. Financial Advisors, or a member of their team, must have the Certified Divorce Financial Analyst® (“CDFA”) designation to be able to offer this Service. Special Needs Analysis Special needs planning may involve assessing current and future needs, retirement and long-term care planning, reviewing life insurance needs, discussions on availability and applicability of federal benefits, purpose of special needs trust, estate and beneficiary planning, as well as personal planning considerations for caregivers and families. Financial Advisors, or a member of their team, must have the Chartered Special Needs Consultant® (“ChSNC®”) designation to be able to offer this Service. Sports and Entertainment Sports and entertainment planning may involve reviewing employee benefits and retirement benefits, business planning, cash flow planning, assistance in navigating sudden wealth, guidance in developing an Investment Policy Statement and navigating around unknown career time horizon. Financial Advisors, or a member of their team, must have the Sports & Entertainment Accredited Wealth Management AdvisorTM (“SE-AWMATM”) designation to be able to offer this Service. Business Owner Planning Business owner planning focuses on transition planning for business owners, which may involve reviewing and discussing key business information relevant to a client's business transition planning, market attractiveness, as well as reviewing existing buy-sell agreements. In addition, the service may provide guidance on contingency planning, reviewing and discussing transition goals and priorities, pre-sale planning, identifying and comparing the suitability of potential ownership transition options, and related financial planning (which may be charged separately). 596409 (Rev 05 - 03/26) Page 7 of 18  Our advice under this program may be delivered through meetings and other means of communication with you and may include written reports and materials that we prepare for you. At the end of the engagement, we will send you a Client summary letter (“Client Summary Letter”) that describes the Services(s) provided to you over the course of the engagement. We assume no responsibility for the accuracy or completeness of the information supplied by you that is used in the production of any written materials that are provided, if any. The accuracy or completeness of this information also may affect the results and any recommendations contained in our advice under this Agreement. Any written materials we provide are prepared by us based not only on your current financial situation and goals but also our understanding of current tax and other applicable laws and regulations and our advice and recommendations are as of the date the information is delivered, without an obligation to update this information after the term of this Agreement (unless we otherwise have agreed to provide updates). Generally, our engagement with you ends upon the delivery of the Services you have selected and our delivery of the Client Summary Letter to you. Unless otherwise specifically agreed to by us, neither we nor your FA shall have duties or obligations with respect to: the implementation of our advice or recommendation and, without limiting the generality of the foregoing; monitoring or updating any plan rendered during the course of the Services; and we shall have no duty or obligation to provide investment advisory or investment management services to you that are outside the scope of the Services discussed above. Some planning tools and software are generally available to WFCS advisory Clients and prospective Clients at no additional charge. These tools are not intended or expected to replicate the Services described herein. However, depending on the specific circumstances of the Client or prospective Client, these standard tools could be sufficient for the particular needs of the Client or prospective Client. Before you engage us for the Services described herein, you should discuss with your FA how these Services are expected to be of value to you. When we charge a fee for Fee-Based Planning Services (Services) we act in the capacity of an investment adviser. We may also provide similar services free of charge in our capacity as a broker-dealer (which may be dependent on the relationship, and the scope and complexity of those needs). In deciding whether to obtain the Services for a fee, you should consider whether you prefer to enter into a fiduciary relationship with us under the Investment Advisers Act that is governed by a written services agreement outlining the services you will receive and the duration of the engagement. Throughout this document, references to Services mean those services subject to a fee and provided to you. Services Tailored to Individual Client Needs The Services described in this document are tailored to you and designed to meet your needs. They are drawn from research and analysis we believe to be appropriate to your circumstances. Portfolio Management Services We act as portfolio manager for certain wrap fee advisory Programs that we offer to Clients and collect a fee for performing that service. We do not act as a portfolio manager for the Services described in this brochure. Assets Under Management As of December 31, 2025, we manage $478,834,872,430 of Client assets on a discretionary basis and $192,586,970,269 of Client assets on a non-discretionary basis. Fees and Compensation Fees for Services are described below and will vary based on the extent, nature and complexity of the advice requested and your financial needs and are therefore subject to negotiation. As a result, fees may vary from Client to Client and from different Financial Advisors based on these and other factors. In general, these fees ordinarily can range from $0 up to $25,000 for the engagement. We may elect to waive fees, in whole or in part, in our sole discretion, including but not limited to in connection with promotional efforts or participation in other advisory programs. Not all clients may have access to the same promotions, so it is possible that similarly situated clients will pay a different advisory fee. Additionally, in certain circumstances, the fee may be negotiated at a higher rate due to additional complexity. The specific fee of any Client will be included in the Client Agreement for the contracted Services. 596409 (Rev 05 - 03/26) Page 8 of 18  Services Service Fee for Clients with a Net Worth of $250,000 to $500,000 Service Fee for Clients with a Net Worth over $500,000 to $1,000,000 Service Fee for Clients with a Net Worth over $1,000,000 Cash Flow Analysis Up to $1,000 Up to $2,500 Up to $5,000 Education Planning Up to $1,000 Up to $2,500 Up to $5,000 Retirement Planning Up to $1,000 Up to $2,500 Up to $5,000 Risk Planning Up to $1,000 Up to $2,500 Up to $5,000 Wealth Planning Up to $1,000 Up to $2,500 Up to $5,000 Divorce Planning Up to $1,500 Up to $3,750 Up to $7,500 Special Needs Analysis Up to $1,500 Up to $3,750 Up to $7,500 Sports & Entertainment Up to $1,500 Up to $3,750 Up to $7,500 Business Owner Planning Up to $1,500 Up to $3,750 Up to $7,500 Total Fee per engagement Up to $5,000 Up to $12,500 Up to $25,000 You may elect to pay the full amount of the fee at the conclusion of this agreement or elect to pay 50% with the signing of the Agreement and 50% upon completion of the Services. Our fee does not include any updates to the advice that we provide under this Agreement. Fees can be paid by debiting a non-retirement account or you can pay by check. A portion of the fees for the Services described herein is paid to our FAs. We and your FA will not provide legal or accounting advice, and the fees payable by you under the Agreement for these Services cover only the services rendered by us and do not cover fees of your specialists. In this regard, we and your FA are not responsible for drafting or providing any legal or other documentation or taking any other action relating to or arising from implementation of our advice (subject to the considerations set forth in the following paragraph). The fees described above do not cover fees and expenses (such as advisory fees, and brokerage expenses) incurred in connection with the implementation of a plan or for the implementation of our advice and recommendations under the Services. You may elect to implement our advice and recommendations in whole or in part through us but are under no obligation to do so. In the event you elect to implement, you will be provided with an appropriate disclosure document describing the nature and extent of the services provided by us, the fees charged by us for those services and other related matters. The fees charged by us in connection with the implementation of our consulting services are in addition to the fees incurred by you under this agreement for fee-based personal planning and consulting services. We share a portion of these fees—whether advisory fees or brokerage expenses and commissions—with your FA. As a result, your FA has an incentive to recommend the implementation of the plan through us and has an incentive to recommend certain products or services over others based on the compensation they receive. We intend, however, to make all recommendations independent of such compensation considerations and based solely on our obligations to consider your objectives and needs. Compensation Related to Our Financial Advisors and Branch Management Financial Advisors. Financial Advisors providing service to Clients from either a WFA branch or an office located in a Wells Fargo Bank, N.A. branch receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Financial Advisors discount certain client fees and commissions, or client relationship asset levels are below minimums established by us. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFA advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor’s expense budget and bonus increase, and the Financial Advisor may qualify for recognition trips. Also, as mentioned above the payout schedule is reduced when certain fees are discounted, thus Financial Advisors are discouraged from providing discounts below certain thresholds when negotiating discounts to commissions for brokerage accounts and Program Fees for Advisor Program Accounts. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial 596409 (Rev 05 - 03/26) Page 9 of 18  Advisor has an incentive to recommend that you invest account assets in an advisory account which have ongoing Program Fees (discussed above) versus a brokerage account which have transaction-based fees. Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities-Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Solutions Team. Financial Advisors receive compensation for each client referred to the Solutions Team, described in the Personalized Unified Managed Account section above. However the Financial Advisor could provide these same services directly to the Client. As a result of the compensation details provided above, Financial Advisors have a financial incentive to not refer otherwise eligible clients to WFA Solutions due to the greater compensation if the Financial Advisor serves the client directly, as these assets will be attributed to those of the Financial Advisor for compensation pay-out, bonus and recognition purposes. Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Financial Advisors are also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include overall company performance, reaching certain production levels, tenure with the Firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices. These incentives—particular ones based on production levels (i.e. revenue and profit generated for the Firm), product mix, asset gathering and referrals to affiliates—result in Financial Advisors being encouraged to recommend courses of action that increase your usage of products and services offered by us and our affiliated companies such as Wells Fargo Bank, N.A. and Wells Fargo Securities, LLC. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following three components: an up-front payment; a deferred compensation component; and a back-end bonus arrangement based on new client assets transitioned/ gathered over a three-year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFCS. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFCS. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFCS and WFCS's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of certain titles and/or education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Supervisor Compensation. Branch Managers and Area Managers (who are responsible for supervising Financial Advisors operating from a Wells Fargo Bank, N.A. branch) are compensated based on the total revenue generated by the Financial Advisors subject to their supervision. A portion of the Branch Manager’s and Area Manager’s compensation is also based on the branch meeting business growth targets—such as net asset flows from clients, client usage of lending products, financial advisor recruitment and retention, and client usage of affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.—and branch profitability. Therefore, 596409 (Rev 05 - 03/26) Page 10 of 18  Branch Managers and Area Managers have an incentive to encourage Financial Advisors to recommend products and services that increase or maximize revenue and profit received for the Firm. When Branch Managers and Area Managers serve as Financial Advisors to brokerage and advisory account clients, the Branch Manager (or Area Manager) is compensated as described above for Financial Advisors. Market Growth Strategy Consultants. Market Growth Strategy Consultants support branch-based Financial Advisors and Branch Managers in the growth of WFA advisory accounts. Market Growth Strategy Consultants are compensated by salary and a bonus based on gross asset flows in in Advisory Program Accounts at the branches that they are responsible for supporting and on gross assets referred to the Wells Fargo Bank, N.A. trust services platform. Therefore, the Market Growth Strategy Consultant has a conflict of interest, and is incentivized to emphasize the potential benefits of WFA Advisory Program Accounts and trust and investment management services provided by Wells Fargo Bank, N.A. when providing support to Branch Managers, Financial Advisors, or when joining Financial Advisors in discussions with Clients considering an Advisory Program Account or contributing additional funds to an existing Advisory Program Account. IRA Rollovers – Conflicts and Incentives to Transfer Assets from Employer-Sponsored Qualified Retirement Plans to WFA. Financial Advisors have an incentive to recommend that you roll over assets from an employer-sponsored Qualified Retirement Plan ("QRP"), such as a 401(k), to an Individual Retirement Account ("IRA") with us. If you are rolling over assets, you should carefully evaluate all choices which are typically available. We have a conflict of interest in connection with a rollover of your assets into an IRA and the investment of the assets with us as opposed to leaving the assets in your former employer's plan or electing another option. The conflict arises because we will likely earn no compensation if you were to leave the assets in your former employer's plan or transfer to your new employer's plan. In addition, the costs of maintaining and investing assets in an IRA with us will generally involve higher costs than the other options available to you. While we typically offer a broader range of investment options and services than an employer-sponsored QRP, there are no guarantees that the additional investment options will outperform your employer-sponsored QRP. Termination Either you or we may terminate this Agreement at any time prior to the completion of the Services under this Agreement by written notice to the other party at the address specified in the Agreement (or such other address as specified by either party to the other in writing). If you terminate this Agreement early, you shall remain responsible for compensating us for the Services rendered up to the time of termination. If we terminate this Agreement, you shall not be obligated to compensate us for the Services hereunder, that have not yet been rendered. Termination of this Agreement shall not affect the liabilities and obligations of the parties arising from or in connection with the Services performed prior to such termination. This agreement also automatically will terminate upon the earlier of: the completion of the agreed upon Services under this Agreement or within 6 months of acceptance and approval of this agreement by the firm. This Agreement does not automatically renew and continuation of services after termination of the Agreement requires the execution of a new Fee-Based Planning Services agreement. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees in any of our investment advisory Programs. We do not have any side-by-side management situations. Types of Clients We provide the "Services" described in this brochure to individuals or trusts. Methods of Analysis, Investment Strategies and Risk of Loss The advice and recommendations associated with these Services are developed by your Financial Advisor using information, materials and/or tools provided by Wells Fargo. Certain planning tools may employ simulation techniques (e.g. Monte Carlo simulations, retirement income calculators) and complex statistical analyses to illustrate or present the likelihood of possible investment and financial outcomes. These tools are used as part of the planning process and inform the process; the outputs of these tools are not intended, in and of themselves, to be viewed as nor construed as, planning and advice. The outcomes rendered from these tools are hypothetical in nature and are no 596409 (Rev 05 - 03/26) Page 11 of 18  guarantee of future actual investment results or future income streams. The outputs of these tools can vary with each use and over time. You have the option whether to implement all or a part of our planning advice through us. If you choose to implement any portion of our planning advice through one of the advisory Programs that we offer, you will be provided with an additional disclosure document describing those services. Risk of Loss If you choose to implement any portion of your plan through us, please be aware that all investments shall be at your risk exclusively, and you must understand that we do not guarantee any return on the investments recommended or advised upon. Disciplinary Information We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of the broker-dealer, investment adviser or predecessor firms. For more information on broker/dealer related disciplinary events you may visit: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ Our investment advisory disciplinary history is available by going to: http://www.adviserinfo.sec.gov/ In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. In January 2025, WFCS and WFAFN agreed to a settlement with the SEC regarding allegations that they failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to their cash sweep program, specifically, their use of a bank deposit sweep program. The order found that WFCS and WFAFN did not adopt and implement reasonably designed policies and procedures that considered the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; or addressed the duties of WFCS and WFAFN financial advisors in managing client cash in advisory accounts, in willful violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. WFCS and WFAFN, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28 million by WFCS and $7 million by WFAFN. In August 2023, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC (collectively, the “Firm”) agreed to a settlement with the SEC regarding allegations that from at least 2002 through December 2022, the Firm and its predecessor firms overcharged approximately 10,945 accounts of advisory clients, for accounts opened through 2014, for more than $26.8 million in advisory fees and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the overbilling in willful violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells Fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells Fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the Firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected accountholders. Without admitting or denying the findings, the Firm consented to a settlement that included a cease and desist order, censure and civil money penalty of $35,000,000. In December 2021, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti-money laundering Customer Identification Program (CIP) in the required non-erasable and non-writable “Write Once, Read Many" (WORM) format 596409 (Rev 05 - 03/26) Page 12 of 18  in violation of Exchange Act Rule 17A-4(F)(2)(II)(A) and failed to notify FINRA prior to using the non-WORM compliant storage platform in violation of Exchange Act rules 17A-4(F)(3)(V) and 17A-4(F)(2)(I). Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine, jointly and severally, of $2,250,000. On August 27, 2020, Wells Fargo Clearing Services, LLC agreed to a settlement with FINRA regarding allegations that the Firm failed to reasonably supervise the activities of two former registered representatives, thus violating its own written supervisory procedures along with NASD Rule 3010(a) and FINRA Rules 3110(a) and 2010. Between November 2012 and October 2015, the two representatives recommended that many of their customers invest a substantial portion of their assets in four high-risk energy securities, which generated multiple red flags regarding overconcentration and suitability in their customers' accounts that the firm failed to reasonably investigate. The Firm has previously compensated 67 clients over $9.7 million for losses in these investments. Without admitting or denying the findings, the Firm agreed to a settlement that included a censure, a fine of $350,000 and restitution in the amount of $201,498 plus interest to additional specified clients. On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, following the Firms' offers of settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds ("ETFs") without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The Commission found that the Firms willfully violated Section206(4) of the Advisers Act and Rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 203(e)(6) of the Advisers Act and failed reasonably to fulfill theirs supervisory responsibilities within the meaning of Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained in the Order, to: cease and desist from committing or causing any violations and any future violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; be censured; and jointly and severally pay a civil monetary penalty in the amount of $35,000,000. In 2018, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC elected to participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative ("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling $17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms self-reported. In December 2017, Wells Fargo Advisors agreed to a settlement with the State of Illinois Securities Department regarding allegations that it received, reviewed and/or analyzed documents and information from a financial advisory firm concerning certain money manager strategies that contained information that was later found to be false and misleading. The findings stated that we included the financial advisory firm’s money manager strategies in certain of our externally managed Separately Managed Account Programs, but that we did not utilize inaccurate historical performance data in connection with our decision to onboard the money manager strategies and we did not incorporate inaccurate performance data in our advertisements or Program marketing materials. Without admitting or denying the findings, the Firm agreed to a total monetary payment of $270,000. On December 21, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also found that the Firms failed to implement an audit system for those records, failed to provide its third-party vendors full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce written procedures. 596409 (Rev 05 - 03/26) Page 13 of 18  Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,500,000. The Firms also consented to a review of its policies and procedures. On December 5, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through available applications. The findings stated that these applications allowed the Firms’ representatives to manually enter information regarding customers’ external accounts, assets and liabilities into a centralized table which the Firms maintained. This information would then be used to populate reports, including those that would be sent to the Firms’ customers. FINRA found that the Firms did not have systems in place to review the contents of the reports, including information about customer holdings away from the Firms. In addition, the Firms’ supervisory systems and procedures were inadequate because there was no mechanism allowing representatives to designate which reports were actually provided to customers and the system could not distinguish between draft reports and completed reports that were sent to customers, which should have been subject to the Firms’ supervisory systems designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,000,000. Other Financial Industry Activities and Affiliations We are a national securities firm providing qualified custodial, investment and other financial services to individual, corporate and institutional Clients. We are a registered broker-dealer and investment adviser. WFCS is a member of all principal stock exchanges in the United States, including the New York Stock Exchange and NASDAQ. WFCS is also a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). We may also route transactions through our affiliate, Wells Fargo Securities, LLC. Unless otherwise stated as the case, the investment advisory services offered and the underlying stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not insured or otherwise protected by the Federal Deposit Insurance Corporation (“FDIC”) or another government agency. They are not obligations of any bank or any affiliate of WFA; are not endorsed or guaranteed by Wells Fargo, WFA, or any bank or any affiliate of us; and involve investment risk including possible loss of principal. Cash balances in Client Accounts may be held in a depository product sponsored by Wells Fargo Bank, N.A. Wells Fargo Clearing Services, LLC is not an FDIC-insured depository institution; FDIC deposit insurance only protects against the failure of an insured depository institution. Banking products and services provided by Wells Fargo Bank, N.A. Member FDIC. Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible for securities we sell or purchase. As a general matter, unless otherwise stated, we may be a principal or engaged in underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to issuers whose securities may be sold to you. From time to time, a bank or thrift affiliated with us may lend money to an issuer of securities underwritten or privately placed by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will disclose to the extent required by applicable securities laws: (i) the existence of any material lending relationship by any affiliate of ours with such an issuer and (ii) whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding indebtedness to any of our affiliates. We have a number of related persons who may provide investment management and related financial services to our Program Clients. The advisory services these investment advisers offer are described more fully in their Disclosure Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services follows. • Wells Fargo also provides retail brokerage and investment advisory services through Wells Fargo Advisors Financial Network, LLC (“WFAFN”). • Wells Fargo Investment Institute, Inc. ("WFII") (known prior to November 1, 2014 as Alternative Strategies Group, Inc. and before that as Wachovia Alternatives Strategies, Inc.) is a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA. 596409 (Rev 05 - 03/26) Page 14 of 18  We and our affiliates may give advice and take action in the performance of our duties to you that differs from advice given, or the timing and nature of action taken, with respect to other Program Clients and/or Clients in other advisory Programs. Additionally, we and our affiliates, from time to time, may not be free to divulge or act upon certain information in their possession on behalf of investment banking or other Clients. Material Relationships with Allspring Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners renamed the business Allspring Global Investments. The Wells Fargo Asset Management business was wholly owned by Wells Fargo prior to the transaction and included the following companies: Wells Capital Management Incorporated; Wells Fargo Funds Management, LLC; Wells Fargo Asset Management (International), LLC; Wells Fargo Funds Distributor, LLC; and, Galliard Capital Management, Inc. These companies, which are no longer related persons of WFCS, served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the companies managed separately managed account strategies offered through WFCS. Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings, LLC. This group of companies includes Allspring Funds Management, investment adviser to mutual funds within the Allspring family of funds, Allspring Funds Distributor, LLC, the principal underwriter of Allspring mutual funds, and Allspring Global Investments, LLC, a model portfolio strategy provider and an investment adviser to pooled investment vehicles and separately managed accounts. Wells Fargo has no role in the management of Allspring. However, Wells Fargo retains less than a 10% equity ownership interest in Allspring and has continued to provide certain non-advisory transition services to Allspring for a fee since the close of the sale. WFCS also receives compensation from Allspring for the distribution, administrative and operational services that we provide to the Allspring mutual funds. Although Allspring is not a related person of WFCS, WFCS and its related persons continue to benefit from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a similar financial interest. Wells Fargo's equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services to Allspring for a fee provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account or model portfolio strategies. WFII charges Allspring research access fees for investment research services that WFII provides to Allspring. Allspring manages the Managed DSIP, Managed DSIP II, ESG Managed DSIP, Current Equity Income, and Income Multi Asset Portfolio strategies offered through WFA's Personalized Unified Managed Account advisory program (collectively, the "Equity Income Strategies") utilizing information derived, in part, from certain of the research services. The research access fees are calculated based on the assets invested in the strategies, meaning that WFII earns more money when more assets are invested in the strategies. The research access fees are assessed at rates that result in WFII receiving fees that are equivalent to substantially all of the Manager fees assessed in conjunction with the Income Multi Asset Portfolio, the Current Equity Income Strategy, and the Managed DSIP strategy, and approximately half or greater of the Manager fees assessed for the Managed DSIP II strategy and the ESG Managed DSIP strategy. The fee paid to WFII is for research services WFII provides to Allspring, including: investment research that WFII provides to Allspring; and access to certain WFII research analyst teams, strategists, and associates to discuss the research and/or obtain additional research commentary on covered names, insights into sectors, etc. (collectively "Research Services"). While WFII does not provide the Research Services to other third-party Managers for utilization in managing strategies, WFII does provide the Research Services to its affiliates, WFCS and WFAFN, who in turn, may utilize the Research Services to manage strategies and who provide the investment research at no cost to WFCS and WFAFN advisory clients, WFCS and WFAFN brokerage customers, and prospective clients and customers for their individual use. As such, investors in the Equity Income Strategies are indirectly paying for investment research that others receive at no cost, and that those same investors could receive from WFCS or WFAFN for their individual use outside of the Equity Income Strategies at no cost under other circumstances. Similar investment research may be available in the marketplace at no cost or for materially lower fees than are being charged to Allspring in conjunction with the Equity Income Strategies. WFII's receipt of a research access fee in conjunction with the Equity Income Strategies creates a material conflict of interest since it results in WFII, an affiliate of WFCS, earning more revenue when investors follow a WFCS recommendation to invest in the Equity Income Strategies than WFCS, WFII or their affiliates would earn if investors followed a recommendation from WFCS to invest in any of the other Model Manager strategies available through the 596409 (Rev 05 - 03/26) Page 15 of 18  Personalized UMA Program as WFCS and its affiliates earn no comparable additional revenue for investments in other Model Manager strategies. WFCS seeks to mitigate this conflict and its associated implications through disclosure, management of the financial incentive for financial advisors to recommend the Equity Income Strategies, and evaluation of the total costs of investing in the Equity Income Strategies relative to other Model Manager strategies. You should carefully consider the research access fee that is retained by WFII and our related conflict of interest when evaluating whether to invest in the Equity Income Strategies. The Equity Income Strategies are available through Wells Fargo Bank, N.A., including through Wealth & Investment Management Trust Services, and no research access fee is applied to assets invested in the Equity Income Strategies when the assets are custodied at Wells Fargo Bank, N.A. The research access fee is also not applied to assets invested in ERISA accounts. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our Associates are subject to a Code of Ethics that is designed to ensure our business activities are performed with the highest possible standards of ethics and business conduct, and to comply with all applicable laws, rules, and regulations that govern our businesses. Key requirements of our Code of Ethics are summarized below, and you may obtain a complete copy through your FA. • Conduct all aspects of Wells Fargo’s business activities in an honest, ethical, and legal manner, and in accordance with all applicable laws, rules, and regulations and our policies and procedures. • Provide accurate and complete information in dealings with Clients and others, including disclosure of conflicts of interest when they exist. • Prepare and maintain accurate business records. • Refrain from improper disclosure or misuse of confidential Client information and material, non-public information. Wells Fargo protects the private, personal, and proprietary information of Clients and others. • Avoid conflicts of interest in personal and business activities. • Rules specific to personal trading. Participation or Interest in Client Transactions With regards to our Fee-Based Planning Services, no specific investment recommendations are made and as a result, no Client transactions occur as part of these Services. You have the choice to implement all or a portion of our advice and recommendations through us, however implementation of our advice and recommendations is not a part of the contracted Services. We have certain restrictions, internal procedures and Client disclosures regarding conflicts of interest that we may have with respect to our participation or interest in Client transactions. We communicate our policies and procedures related to participation in Client transactions to our Associates through our compliance policies and procedure manuals and Program-specific policy guidelines. Personal Trading We maintain policies and procedures to mitigate conflicts of interest between transactions in our Associates’ personal investment Accounts, including Accounts of their immediate family members and transactions in our Clients’ Accounts. To ensure Associate trading requirements are observed, certain Associate trading activity is subject to pre-approval. All Associates are subject to regular review by their supervisors, independent oversight by our Compliance Department, and systemic controls that automatically restrict entry of certain orders and generate related surveillance reporting. Brokerage Practices Potential conflicts may arise between your interests and ours in executing transactions through us as a broker-dealer if you choose to implement all or part of our planning or our consulting advice through us. If you choose, at your sole discretion, to implement all or part of our planning or consulting services advice with us and execute transactions through us, we will act as a broker-dealer, not an investment adviser, unless we have otherwise agreed with you in writing. As a broker-dealer, we will execute transactions as agent or principal and will charge commissions, mark-ups, transaction fees, and/or other charges. These charges are in addition to the fees for this program. If you choose to implement our planning or consulting advice through a WFA brokerage or advisory Account, you should review the terms of the Client Agreement, Regulation Best Interest Disclosure, and if applicable Form ADV, Part 2A. These 596409 (Rev 05 - 03/26) Page 16 of 18  documents are provided at Account opening or upon request to your Financial Advisor. The FA who delivers the advice and recommendations under this program is a registered representative of ours and thus will receive a portion of the compensation paid to us in connection with the execution of transactions. This compensation is in addition to the compensation we and the FA receive in connection with preparing and presenting any planning or consulting services. Products recommended by us may include proprietary products of us or our affiliates. You should note that we have an incentive to recommend proprietary products because we or our affiliates earn more compensation from the sale of these products than from the sale of non-proprietary products. Review of Accounts The Services provided under this program is not ongoing advice. After the termination of your Agreement for the Services, you may request to continue advice and recommendations by completing a new Agreement for the Services with us and you may be subject to an additional fee. Client Referrals and Other Compensation From time to time, we initiate incentive programs for our Associates, including FAs. Incentive programs compensate our Associates and FAs for attracting new assets and Clients, referring business to our affiliates (such as referrals for banking services and accounts, mortgages, lending, trusts, or insurance services) or other FAs, promoting investment advisory services and promoting green initiatives (such as raising Client awareness of paperless options). We may also initiate programs that reward FAs who meet total production criteria, length of service requirements, participate in advanced training and improve Client service. FAs who participate in these incentive programs may be rewarded with cash and/or non-cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. Portions of these programs may be subsidized by external vendors and/or our affiliates, such as mutual fund companies, insurance carriers, or investment advisers. Therefore, FAs and other Associates may have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services we offer. We may also enter into arrangements with other persons to whom we pay compensation for referrals to our advisory Programs. This compensation is generally in the form of a percentage of the fees described in the Program contracts. The details of such arrangements and the amount of compensation will be described in a separate disclosure provided at the time of such referrals. Additionally, we also compensate employees of Wells Fargo Bank, N.A. for referrals to WFA. From time to time, we compensate Associates other than FAs for referrals of possible Clients to the Programs. Our FAs, not the referring Associate, will make the actual presentation and solicitation of these services. The referral compensation takes the form of a payment to the Associate of a percentage of the fees described in the Programs contracts and results in no additional fees to you or other Clients. Wells Fargo is a full-service financial services firm with many affiliates. Wells Fargo encourages its subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual business planning, business with our affiliates is included in establishing our sales goals. As a result, we may have an incentive to hire affiliate service providers for our advisory Programs. We may recommend affiliated mutual funds to Program Clients, and may hire other affiliates to provide trade execution, clearing, and platform administration services for the Programs. We intend, however, to make all recommendations independent of any such goals and based solely on our obligations to consider your objectives and needs. Custody If you elect to open an Account with us to implement all or a portion of our advice or recommendations, we will have custody of Client funds and securities for Program Accounts. You will receive brokerage statements at least quarterly. Investment Discretion The Services described in this brochure do not include the management or supervision of any securities accounts; therefore, with respect to the Services described herein, we do not have discretionary management authority, nor do we have any responsibility for the management or supervision of securities accounts on either a discretionary or non-discretionary basis. 596409 (Rev 05 - 03/26) Page 17 of 18  Voting Client Securities We do not vote on Client securities as part of these Services. Financial Information We have no financial condition that is likely to impair our ability to meet our contractual commitments to you. 596409 (Rev 05 - 03/26) Page 18 of 18 

Wrap Fee Brochure for Financial Advisor & Client Directed Advisory Programs: Asset Advisor CustomChoice Private Investment Management Fundamental Choice 801 - 37967 Investment Advisory Services of Wells Fargo Advisors Revised March 2026 One North Jefferson, St. Louis, MO 63103 Phone (314) 875-3000 www.wellsfargoadvisors.com This wrap fee brochure provides information about the qualifications and business practices of Wells Fargo Advisors and our Financial Advisor & Client Directed Advisory Programs (the "Programs"). This information should be considered before becoming a Client of one of these Programs. If you have any questions about the Programs or the contents of this brochure, please contact us at the telephone number above. This information has not been approved or verified by United States Securities and Exchange Commission or by any state securities authority. Additional Information about Wells Fargo Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov. Please note that registration as an investment adviser does not imply a certain level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involve risk, including the possible loss of principal. Investment and Insurance Products are: • Not Insured by the FDIC or Any Federal Government Agency • Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate • Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, Members SIPC, separate registered broker-dealers and non-bank affiliates of Wells Fargo & Company. Page 1 of 36 571264 (Rev 57 - 03/26)  Summary of Material Changes This section describes the material changes to Wells Fargo Clearing Services, LLC,’s (“WFCS”) Part 2A of Form ADV Appendix 1 (“Wrap Fee Program Brochure” or this “Brochure”) for the Financial Advisor & Client Direct Advisory Programs since the annual version of this Brochure dated March 2025. WFCS conducts business under the trade name Wells Fargo Advisors (“WFA”). The summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. Clients are encouraged to read this Brochure in detail and contact their Financial Advisor with any questions. Advisory Account Credit subsection of the Fees and Compensation for All Programs section has been updated to indicate that the maximum Account Value that is subject to the Platform Fee has been reduced from $50 million to $25 million. This means that going forward the Platform Fee will only apply to the first $25 million of the Account Value for Participating Accounts subject to the Platform Fee. Advisory Account Credit and Important Information about the Advisory Account Credit subsections of the Fees and Compensation for All Programs section have been updated to reflect that revenue sharing received from actively managed ETFs will be part of the Advisory Account Credit. The Mutual Funds and Exchange-Traded Funds subsection of the Fees and Compensation for All Programs section has been updated to describe revenue sharing from actively managed ETFs and advisory annuities and to remove the additional compensation categories titled intra-company compensation arrangements and other compensation for general service provided to funds. The maximum payment for Data Agreements has been updated to $1,150,000. Additional Payments Received from Funds sub-section of Fees and Compensation for All Programs has been renamed to “Additional Payments Received from Funds and Advisory Annuities.” This subsection has been updated to include description of payments we receive from insurance companies related to annuities held in advisory accounts. These payments are retained by us and do not form part of the Advisory Account Credit. The payments we receive increase as client assets invested in advisory annuities increase. Certain insurance companies have also agreed to pay state insurance initial appointment fees and appointment renewal fees on behalf of Wells Fargo & Company’s insurance agencies and Financial Advisors. Appointment fees typically do not exceed $100 per appointment. Fees and Compensation for All Programs has added information related to compensation for the financial professionals that service WFA clients. Compensation Related to Our Financial Advisors and Branch Management Financial Advisors. Financial Advisors providing service to Clients from either a WFA branch or an office located in a Wells Fargo Bank, N.A. branch receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Financial Advisors discount certain client fees and commissions, or client relationship asset levels are below minimums established by us. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFA advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor’s expense budget and bonus increase, and the Financial Advisor may qualify for recognition trips. Also, as mentioned above the payout schedule is reduced when certain fees are discounted, thus Financial Advisors are discouraged from providing discounts below certain thresholds when negotiating discounts to commissions for brokerage accounts and Program Fees for Advisor Program Accounts. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial Advisor has an incentive to recommend that you invest account assets in an advisory account which have ongoing Program Fees (discussed above) versus a brokerage account which have transaction-based fees. Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities-Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Solutions Team. Financial Advisors receive compensation for each client referred to the Solutions Team, described in the Personalized Unified Managed Account section above. However the Financial Advisor could provide these same services directly to the Client. As a result of the compensation details provided above, Financial Advisors have a financial incentive to not refer otherwise eligible clients to WFA Solutions due to the greater compensation if the Financial Advisor serves the client directly, as these assets will be attributed to those of the Financial Advisor for compensation pay- out, bonus and recognition purposes. Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Page 2 of 36 571264 (Rev 57 - 03/26)  Financial Advisors are also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include overall company performance, reaching certain production levels, tenure with the Firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices. These incentives—particular ones based on production levels (i.e., revenue and profit generated for the Firm), product mix, asset gathering and referrals to affiliates—result in Financial Advisors being encouraged to recommend courses of action that increase your usage of products and services offered by us and our affiliated companies such as Wells Fargo Bank, N.A. and Wells Fargo Securities, LLC. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following three components: an up-front payment; a deferred compensation component; and a back-end bonus arrangement based on new client assets transitioned/gathered over a three-year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFCS. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFCS. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFCS and WFCS's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of certain titles and/or education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Financial Consultants. Financial Consultants work with branch-based Financial Advisors in serving the Financial Advisor’s Clients. When licensed to do so, Financial Consultants can provide advice to clients with brokerage or advisory accounts. The revenue that the firm receives as a result of the Financial Consultant’s recommendations is attributed to the Financial Advisor with whom the Financial Consultant works. Financial Consultant compensation comprises a salary and, when agreed to between the Financial Consultant and Financial Advisor, the Financial Consultant’s compensation also includes a portion of the revenue the Firm pays to the Financial Advisor. Therefore, Financial Consultants, similar to Financial Advisor, have an incentive to make recommendations that result in Clients adding funds to WFA advisory and brokerage accounts, and selecting products and services that generate the most revenue and profit for the Firm. Phone-Based Financial Advisors. Centralized, phone-based Financial Advisors providing brokerage and advisory services via a call center are compensated by salary and discretionary performance bonus. For these Financial Advisors, their discretionary bonus is based on a number of factors including company performance and individual performance which takes into consideration a variety of factors including telephony metrics and production metrics such as funded accounts and net asset flows, client referrals to Wells Fargo Bank, N.A. for trustee or investment management services, and client usage of lending product and affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A. Supervisor Compensation. Branch Managers and Area Managers (who are responsible for supervising Financial Advisors operating from a Wells Fargo Bank, N.A. branch) are compensated based on the total revenue generated by the Financial Advisors subject to their supervision. A portion of the Branch Manager’s and Area Manager’s compensation is also based on the branch meeting business growth targets—such as net asset flows from clients, client usage of lending products, financial advisor recruitment and retention, and client usage of affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.—and branch profitability. Therefore, Branch Managers and Area Managers have an incentive to encourage Financial Advisors to recommend products and services that increase or maximize revenue and profit received for the Firm. When Branch Managers and Area Managers serve as Financial Advisors to brokerage and advisory account clients, the Branch Manager (or Area Manager) is compensated as described above for Financial Advisors. Market Growth Strategy Consultants. Market Growth Strategy Consultants support branch-based Financial Advisors and Branch Managers in the growth of WFA advisory accounts. Market Growth Strategy Consultants are compensated by salary and a bonus based on gross asset flows in in Advisory Program Accounts at the branches that they are responsible for supporting and on gross assets referred to the Wells Fargo Bank, N.A. trust services platform. Therefore, the Market Growth Strategy Consultant has a conflict of interest, and is incentivized to emphasize the potential benefits of WFA Advisory Program Accounts and trust and investment management services provided by Wells Fargo Bank, N.A. when providing support to Branch Managers, Financial Advisors, or when joining Financial Advisors in discussions with Clients considering an Advisory Program Account or contributing additional funds to an existing Advisory Program Account. Page 3 of 36 571264 (Rev 57 - 03/26)  Significant cash flow impacts & redemption risk portion of Mutual Fund Due Diligence Process – Mutual Fund Risks and Considerations has been amended to include the following addressing risk to mutual fund investors related to significant redemption requests: “For [mutual fund] shareholders, significant redemptions—whether initiated by us or our FAs or unrelated third-party investors—can result in unexpected capital gains liabilities that are materially higher compared to prior years.” Mutual Funds Risks and Considerations portion of the Portfolio Manager Selection and Evaluation section, a new paragraph describing the risks and considerations associated with investing in Cryptocurrency exchange-traded funds has been added. These risks include emerging technology risks, unsettled legal and governance frameworks, and product volatility. For the full description of risks, please refer to the new information below. Cryptocurrency ETF Risks and Considerations. Certain available Cryptocurrency Exchange Traded Products (“Cryptocurrency ETFs”) may hold underlying positions in cryptocurrencies such as Bitcoin, Ethereum, or other digital assets (collectively, “Digital Assets”). Cryptocurrency ETFs are exposed to Digital Assets that typically rely on blockchain technology. Digital Assets are not legal tender in the United States and are not required to be accepted as a form of payment. Digital Assets have experienced extreme volatility. Digital Assets can be traded through privately negotiated transactions and through Digital Asset exchanges around the world. The lack of a centralized pricing source poses valuation challenges. Digital Assets are part of a new and evolving industry, and neither the technology nor regulatory regime for Digital Assets is settled. The tax treatment of Digital Assets is uncertain. While Cryptocurrency ETFs are not intended to generate unrelated business taxable income (“UBTI”), this may change. Performance data relating to Digital Assets may not be verifiable, as pricing models are not uniform. Digital Assets can be permanently lost, stolen, destroyed or become inaccessible due to the loss or theft of the private key needed to access the Digital Asset. Certain Digital Asset exchanges have experienced failures or interruptions in service due to fraud, security breaches, operational problems, or business failure. Similar events could occur in the future and impact the value of your investment, regardless of whether the Cryptocurrency ETF relies on the impacted exchange. The performance of a Cryptocurrency ETF may be very dissimilar to the spot price performance of the Digital Asset tracked. Cryptocurrency ETFs are highly speculative and involve a high degree of risk. An investor could lose all or a substantial portion of their investment. Disciplinary Events sub-section of Additional Information has been updated to include: In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. Voting Client Securities and Corporate Actions sub-section of Additional information has replaced the Proxy and Reorganization section and details that proxies are now voted under proxy voting policies and guidelines established by Wells Fargo and administered by a third-party service provider. Other material amendments include removal of client’s ability to appoint an agent to receive and vote proxy materials. Cash Sweep Program sub-section of Additional Information was updated to indicate that the Expanded Bank Deposit Sweep program would be discontinued effective August 15, 2025. The Expanded Bank Deposit Sweep Program has now been discontinued, as a result, the Cash Sweep Program section of the Brochure has again been updated to remove language specific to the Expanded Bank Deposit Sweep Program from this section. Since all Program Banks are affiliated banks of WFA, all benefits that Program Banks receive from participating in the Bank Deposit Sweep Program accrue solely to banks affiliated with WFA. More information on how Program Banks benefit from participating in the Bank Deposit Sweep Program, as well as WFA’s economic incentives and conflicts of interest related to the program, can be found in the Bank Deposit Sweep Program section generally and the Spread Earned by Banks subsection of this disclosure Brochure. Services, Fee, and Compensation – Private Investment Management and Fundamental Choice section has been updated to describe a new program feature in which Portfolio Managers of Wells Fargo Bank, N.A. can partner with a Financial Advisor of Wells Fargo Clearing Services, LLC in the management of Fundamental Choice accounts. The General Information About Fees for Program Services section has been updated to address compensation conflicts with respect to this new arrangement. The Brokerage Practices section has also been updated with respect to this new program option, including that trades in WFA accounts directed by a Wells Fargo Bank, N.A. Portfolio Manager will not be aggregated with similar trades in Wells Fargo Bank, N.A. accounts and trading will occur on different trading platforms which could result in different execution price and timing. Services, Fee, and Compensation – Private Investment Management and Fundamental Choice section has been updated explaining that Financial Advisors in the PIM program or FC program may implement the same or substantially similar investment strategies as an FA Directed Strategy in the Personalized Unified Managed Account (“Personalized UMA”) program. The trading processes for the FA Directed Strategies in the Personalized UMA program differ from the trading processes of the PIM and FC programs. These trading process differences will result in trading the same or substantially similar strategies at different times as between an FA Directed Strategy in Personalized UMA and the same or similar strategy in PIM or FC. In conjunction with strategy updates, a Financial Advisor may individually review some or all accounts in the PIM and/or FC programs before implementing trades. An individual review will not occur for an FA Directed Strategy in the Personalized UMA program. This will result in differences in the timing of trading as between an FA Directed Strategy in Personalized UMA and the same or similar strategy in the PIM and FC programs. These program differences will result in Clients in the same or substantially similar strategies in the PIM and FC programs receiving different execution prices and investment results than Clients in an FA Directed Strategy in the Page 4 of 36 571264 (Rev 57 - 03/26)  Personalized UMA program. For more information on how this may impact your Account, please consult with your Financial Advisor. Services, Fee, and Compensation – Private Investment Management and Fundamental Choice and Methods of Analysis, Investment Strategies and Risk of Loss sections, we have removed explanation that that Some Portfolio Managers follow the investment recommendations that are the basis for investment decisions for Wells Fargo Compass strategies within the Personalized UMA Program for some or all assets in these Program Accounts. Portfolio Manager Selection and Evaluation section has been updated, removing the reference to the Financial Advisor training requirement, and explaining that Financial Advisors serving as Portfolio Managers on accounts in the Private Investment Management or Fundamental Choice advisory programs are required to meet firm or industry experience levels, plus any required industry examinations and registrations. Brokerage Practices sub-section of Additional information has been amended to permit principal trades in ERISA and IRA accounts enrolled in the Asset Advisor Program when addition requirements are met. Brokerage Practice sub-section of Additional information has been updated regarding aggregation of client orders. Aggregation of Client Orders. Orders in Accounts may be aggregated (i.e. combined with orders in the same security for other WFA advisory clients) –with orders of other WFA advisory clients depending upon several factors, including order size, type of order, the Program in which the Account is enrolled, the discretion of the Manager or Financial Advisor, and our advisory trading operations protocols. In client directed programs—Asset Advisor and CustomChoice Programs—Account orders are not aggregated with orders of other clients in the same security. In the Financial Advisor directed programs— Private Investment Management and Fundamental Choice Programs—orders are entered by the Financial Advisor, and the Financial Advisor is responsible for deciding whether or not to aggregate client orders. For Personalized UMA Program Accounts or portions of the Accounts thereof for which WFA acts as Model Manager, the Firm maintains protocols to systematically aggregate like orders in the same security—even if the orders are for multiple unrelated Models. For Personalized UMA Program Accounts that have selected one or more FA Directed Strategies, WFA serves as Model Manager for these portions of the Account and will aggregate in accordance with the aggregation protocols applicable to the Model trading that WFA performs as the Model Manager. When WFA or the Financial Advisor aggregate client orders, each Account participating in the aggregated order will receive the average per share price for the shares sold or purchased in the order. When an aggregated order receives partial execution rather than full execution, in most cases Accounts will participate on a pro-rata basis. In certain cases, typically due to the size of the order, partial executions will be allocated at the Account level to Accounts selected at random. For remaining Accounts that were not selected for allocation, another order in the security will be placed and partial fills will be again allocated to Accounts selected at random. When your Financial Advisor partners with a Bank PM in the management of a Fundamental Choice Account, the Bank PM will also be managing accounts for clients of Wells Fargo Bank, N.A. Investment management services at WFA and Wells Fargo Bank, N.A. are provided to each institution’s respective clients through separate account management and trading platforms. Orders in Fundamental Choice Accounts managed by a Bank PM will not be aggregated with similar trade orders that the Bank PM makes in Wells Fargo Bank, N.A. accounts. Therefore, transactions in the same security placed by the Bank PM at or close to the same time in each institution’s respective trading system could experience differences in timing of trade and price obtained. We have implemented processes to monitor accounts for equitable treatment by the Bank PM. Financial Advisors offering FA Directed Strategies may implement the same or substantially similar investment strategies in the Personalized UMA Program as well as in the Personalized Investment Management (“PIM”) program or Fundamental Choice (“FC”) program. The trading processes for the FA Directed Strategies in Personalized UMA differ from those utilized in PIM and FC Programs. These trading process differences will result in trade orders in the same or substantially similar strategies at different times as between an FA Directed Strategy and the same or similar strategy in PIM or FC. In conjunction with strategy updates, a Financial Advisor may individually review some or all accounts in the PIM and/or FC programs before implementing trades executing the orders. An individual review will not occur for an FA Directed Strategy. This will result in differences in the timing of trading order execution as between an FA Directed Strategy in Personalized UMA and the same or similar strategy in the PIM and FC programs. These program differences will result in Clients in the same or substantially similar strategies in the PIM and FC programs receiving different execution prices and investment results than Clients in an FA Directed Strategy in the Personalized UMA program. For more information on how this may impact your Account, please consult with your Financial Advisor. Page 5 of 36 571264 (Rev 57 - 03/26)  Table of Contents Page Summary of Material Changes .......................................................................................................................... 2 Services, Fees and Compensation ................................................................................................................... 7 The Asset Advisor Program ........................................................................................................................... 8 CustomChoice Program ................................................................................................................................ 8 Private Investment Management and Fundamental Choice Programs .............................................................. 9 Fees and Compensation ............................................................................................................................. 10 Account Termination ................................................................................................................................... 21 Account Requirements and Types of Clients .................................................................................................. 22 Portfolio Manager Selection and Evaluation ................................................................................................... 22 Services Tailored to Individual Client Needs ................................................................................................. 24 Client Restrictions and Instructions ............................................................................................................... 24 Performance-Based Fees and Side-By-Side Management ............................................................................. 24 Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................ 24 Voting Client Securities and Corporate Actions ............................................................................................. 25 Client Information Provided to Portfolio Managers ......................................................................................... 27 Client Contact with Portfolio Managers .......................................................................................................... 27 Additional Information .................................................................................................................................... 27 Disciplinary Information ............................................................................................................................... 27 Other Financial Industry Activities and Affiliations .......................................................................................... 29 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................... 30 Review of Accounts .................................................................................................................................... 31 Prospectus Delivery ..................................................................................................................................... 32 Client Referrals and Other Compensation ..................................................................................................... 32 Brokerage Practices .................................................................................................................................... 32 Cash Sweep Program ................................................................................................................................. 35 Financial Information ................................................................................................................................... 36 Page 6 of 36 571264 (Rev 57 - 03/26)  Wells Fargo Advisors (“WFA”) is a trade name used by Wells Fargo Clearing Services, LLC ("WFCS") and Wells Fargo Advisors Financial Network ("WFAFN"). WFA, whose predecessors span more than 150 years, is a leading national securities firm providing investment and other financial services to individual, corporate, and institutional Clients. It is a non-bank affiliate of Wells Fargo & Company ("Wells Fargo"), a publicly held company (NYSE: WFC), and financial holding company and bank holding company founded in 1852. Wells Fargo and its affiliates are engaged in a number of financial businesses, including retail brokerage and investment advisory services. WFCS is affiliated with WFAFN, a broker-dealer also providing advisory and brokerage services. Information about the advisory and brokerage services offered by WFAFN is available by contacting them directly. WFA is also affiliated with Wells Fargo Investment Institute, Inc. ("WFII"), a registered investment adviser that provides advisory services and research to WFA. The terms "Client," "you," and "your" are used throughout this document to refer to the person(s) or organization(s) who contract with us for the services described here. "WFA," "WFCS," "we," "our," and "us" refer to WFA together with our affiliates, including but not limited to, Wells Fargo & Company and its agents with respect to any services provided by those agents. "Affiliate" means any entity that is controlled by, controls or is under common control with WFA. Each affiliate is a separate legal entity, none of which is responsible for the obligations of the other. "Account" means collectively or individually any brokerage Account and/or any Advisory Program Account you have with us, including any and all funds, money, securities and/or other property you have deposited with us. "Securities and/or Other Property" means, but is not limited to, money, securities, financial instruments and commodities of every kind and nature and related contracts and options, distributions, proceeds, products and accessions of all property. "Program Assets" are the investment options available for purchase in the Financial Advisor and Client-Directed Advisory Programs. A Program Fee — see section "Fees and Compensation" below — is assessed on Program Assets. Services, Fees and Compensation Types of Advisory Services We sponsor a number of wrap fee advisory programs that are designed to help you meet your investment objectives and goals. They include Unified and Separately Managed Account Programs, Mutual Fund Advisory Programs, Financial Advisor ("FA") Directed Programs and Non-Discretionary, Client Directed Advisory Programs. We also offer Consulting and Financial Planning advisory services. This Disclosure Document is being provided pursuant to Section 204 of the Investment Advisers Act of 1940 and deals solely with our FA & Client Directed Advisory Programs: Asset Advisor, CustomChoice, Private Investment Management and Fundamental Choice (collectively referred to as "the Programs"). Descriptions of the services and fees for the other programs and services we offer can be found in separate disclosure documents, copies of which are available upon request. FA & Client Directed Advisory Programs Regardless of which Program you select, you will retain the right to: withdraw securities or cash; vote on shareholder proposals of beneficially owned security issues, or delegate the authority to vote on such proposals to another person; be provided, in a timely manner, with a written confirmation or other notification of each securities transaction, and all other documents required by law to be provided to security holders; and proceed directly as a security holder against the issuer of any security in your Account and not be obligated to join any person involved in the operation of the applicable Program, or any other Client of the applicable Program, as a condition precedent to initiating such proceeding. We will provide you with periodic monitoring and reporting of your portfolio’s performance. A Client request to establish or terminate program services, including contribution and withdrawal activity, is not considered a market order due to the administrative processing time needed to establish your advisory Account. We will initiate Program services for new Advisory Program Accounts within a reasonable amount of time, generally within 15 days, after your execution of any required Account documentation, approvals and funding of the account. Until we initiate Program services with respect a new Advisory Program Account, your assets will be held in a brokerage Account for which you will be solely responsible for making any investment decisions with respect to the assets. During such time, we will not act as an investment adviser with respect to the assets. If you transition from one Program to another, we will effectuate the transition within a reasonable amount of time, generally within 15 days, after our receipt of your instruction to make the change. As part of a transition from one Program to another and until such a transition is complete, a transitioning Account may for a reasonable period of time, generally not exceeding 15 days, hold positions that do not directly align with the newly selected strategy and Program or the strategy selected for the prior Program. As a result, transitioning Accounts may be subject to market volatility in a manner that is different than that associated with the prior or newly selected Program strategy. A transitioning Account will continue to be subject to the fees associated with the Program that it is being transitioned from until the transition is complete. As described below in the "Other Financial Industry Activities and Affiliations" section, we are engaged in a wide range of securities services. The advice given and action taken in the performance of our duties to you will differ from advice given, or the timing and nature of action taken, with respect to other Program Clients and/or Clients in other advisory Programs. Additionally, there are times that we are limited in our ability to divulge or act upon certain information we possess as a result of investment banking activities or other confidential sources. Page 7 of 36 571264 (Rev 57 - 03/26)  Client Directed Programs The Asset Advisor Program Asset Advisor is a non-discretionary, Client directed investment Program in which your Financial Advisor provides investment recommendations based on your investment objectives, financial circumstances and risk tolerance. You have the option of accepting these recommendations or selecting different investments for your Account. Program Assets eligible for purchase in an Asset Advisor Account include, but are not limited to, common and preferred stocks, exchange-traded funds ("ETF"), closed-end funds ("CEF"), fee-based unit investment trusts ("UIT"), corporate and government bonds, certificates of deposit ("CD"), options, structured products, certain open-end mutual funds whose shares can be purchased at net asset value, market-linked investments, certain advisory annuities and certain alternative investments. Alternative Investments include alternative investment vehicles that require execution by the client of either certain third-party fund documentation or other documentation to direct a specific investment (such as hedge funds, certain real estate funds, private equity funds, certain credit funds, certain interval funds, exchange funds that provide exposure to a diversified portfolio of securities in exchange for contributions of restricted securities, certain tender offer funds, as well as co-investments, special purpose vehicles, and other fund structures that provide exposure to private company securities and real estate) ("Alternative Investments"). Eligible mutual funds include, at any given time, asset allocation funds, alternative strategy mutual funds or other select funds that utilize derivatives, short-selling, leverage and other strategies to meet stated investments objectives, enhance diversification, hedge risks, accentuate returns or facilitate certain market exposures or more dynamic allocation changes. Alternative Investments are not suitable for all investors. Alternative Investments, particularly hedge funds, are complex investment vehicles that often use leverage and other speculative investment practices, such as short sales, options, derivatives, futures and illiquid investments that could increase the risk of investment loss. Managed futures are speculative investments that are subject to a significant amount of risk. Certain Alternative Investment products are illiquid and may have investment horizons of ten years or more. In addition, investors who purchase Alternative Investments will pay fees and expenses charged by the underlying Alternative Investment vehicle. These fees and expenses are significant and are in addition to the advisory fee we charge. Fees and expenses charged by Alternative Investments will reduce the value of your Account and return on your investment. Prospective investors must be provided a risk disclosure statement. This Disclosure Document is not a solicitation, recommendation or invitation to invest in Alternative Investments and is intended solely to disclose the availability of Alternative Investments. Over time, your total expenses to own an Alternative Investment inside your investment advisory Account will be greater than the total expenses to own a similar Alternative Investment outside your investment advisory Account. In making the decision to invest in an Alternative Investment, you should consider the risks associated with that investment and your ability to bear those risks, including the potential for substantial volatility, loss of the investment and lack of liquidity for substantial periods. You should also consider the value of the advisory services provided with respect to illiquid positions and whether it would be in your best interests to hold those Alternative Investments in a brokerage account that is not subject to ongoing asset-based fees. Certain assets, such as commodity futures contracts, options on such contracts, non-eligible annuities, limited partnership interests, and mutual funds that cannot be purchased at net asset value are not eligible as Program Assets, and are referred to collectively as Non-Program Assets. If you purchase or sell Non-Program Assets in your Account, these transactions will incur commissions or charges. While new-issue CDs are a Program Asset, the yield of new-issue CDs takes into account a sales concession in order to compensate the brokerage firms that sell the CDs. For certain advisory Accounts, the underwriter retains this sales concession. Although we do not receive the sales concession, it has an impact on the overall yield paid to you. Since we charge an advisory fee on all eligible assets within an advisory Account, you are effectively charged both the sales concession (retained by the underwriter) and the advisory fee on the CD. These charges reduce the overall yield on the CD and, in some cases, this results in a negative yield. You should be aware that you could obtain the same CDs without being subject to the advisory fee if you purchase it in a non-advisory brokerage Account. The CustomChoice Program CustomChoice is a non-discretionary investment advisory Program designed to help you allocate your assets among open-end mutual funds in accordance with your individual investment goals, objectives, and expectations. Based on your investment objectives and risk tolerance, your Financial Advisor will recommend an appropriate mix of affiliated or unaffiliated open-end mutual funds and money market funds and target allocation percentages. Funds on the Recommended List and Allowable List (described more fully below in the "Portfolio Manager Selection and Evaluation" section) can be included. Funds on the Recommended List and the Allowable List include, at any given time, asset allocation funds, alternative strategy mutual funds or other select funds that utilize derivatives, short-selling, leverage and other strategies to meet stated investment objectives, enhance diversification, hedge risks, accentuate returns or facilitate certain market exposures or more dynamic allocation changes. You have the option of accepting any of our recommendations, or selecting an alternative combination of eligible funds. We will implement your investment decisions, but will not have investment discretion over your Account, except for the limited discretion to rebalance your target asset allocation, if you authorize us to do so. Over time, as changes occur in the financial markets and/or your investment objectives and circumstances, we may recommend changes in your portfolio. In making these recommendations, we will take the updated information into consideration. In a taxable Account, you are advised that your decisions relating to investments in mutual funds will have tax consequences that should be discussed with your tax advisor. Page 8 of 36 571264 (Rev 57 - 03/26)  In order to maintain your portfolio in conformance with your target asset allocation, you may authorize us to rebalance your Account using our automated Rebalance Trading System. See the description of the Rebalance Trading System below. Your rebalance options include: quarterly, semi-annual or annual. Rebalance Trading System Domestic Clients may request periodic rebalancing of the mutual funds in their Account. We can rebalance your Account either at predetermined intervals (e.g., annually) or when you direct us to do so. The Rebalance Trading System reviews the actual allocation of mutual funds in your Asset Advisor or CustomChoice Account versus the target allocation established for your Account. Generally, subject to certain minimum constraints, if any of the funds in your Account vary by more established percentages from your Target Allocation on the predetermined interval you selected, we will rebalance the Account by initiating sell and buy transactions. We have the ability to change these tolerance percentages without notice. You are aware that any transactions initiated to rebalance these assets will cause you to incur tax consequences. The Rebalance Trading System will not rebalance any assets that are not offered through the Programs (i.e., Non-Program Assets). FA Directed Programs Private Investment Management and Fundamental Choice Programs For these Programs, certain WFA Financial Advisors (called Portfolio Managers) provide investment advisory and brokerage services to your Account on a discretionary basis. As a minimum criterion for providing advisory services, we require our Portfolio Managers to possess satisfactory past business experience, plus any required industry examinations and registrations. Your Financial Advisor will recommend a Program based on your investment objectives and individual needs. Fundamental Choice ("FC") is built on the foundation of both fundamental and quantitative equity research. Research for the Program is provided by WFA, WFA affiliates, and/or several non-affiliated research providers. Program Assets include stocks, investment grade bonds, cash and cash alternatives, eligible mutual funds, ETFs, CEFs, equity wrap UITs and CDs. Eligible mutual funds include, at any given time, asset allocation funds, alternative strategy mutual funds or other select funds that utilize derivatives, short-selling, leverage and other strategies to meet stated investment objectives, enhance diversification, hedge risks, accentuate returns or facilitate certain market exposures or more dynamic allocation changes. The Program guidelines are based on equity research ratings, diversification, percentage weightings within economic macro sectors and security concentration limits. In the FC Program, your Financial Advisor can partner with a Wells Fargo Bank, N.A. Portfolio Manager ("Bank PM") who manages accounts for our affiliate, Wells Fargo Bank, N.A., but who is also licensed through WFA. If your Financial Advisor engages a Bank PM partner, the Bank PM will develop your investment strategy and manage your Account assets on a discretionary basis. Private Investment Management ("PIM") is based on both fundamental and quantitative research and other independent research. Program Assets include stocks, bonds, cash and cash alternatives, eligible mutual funds, ETFs, CEFs, wrap UITs, CDs and covered options. Eligible mutual funds include, at any given time, asset allocation funds, alternative strategy mutual funds or other select funds that utilize derivatives, short-selling, leverage and other strategies to meet stated investment objectives, enhance diversification, hedge risks, accentuate returns or facilitate certain market exposures or more dynamic allocation changes. Individual PIM Portfolio Managers develop specific investment strategies using a mix of these analytic methods. They also establish quality and concentration requirements to provide overall discipline. Such strategies ordinarily include long and short-term securities purchases and, depending on your objectives and the Portfolio Manager's investment philosophy, supplemental covered option writing. In special circumstances, the strategies also include margin transactions, other option strategies and trading or short sale transactions. We also use WFA, WFII or third-party research to assist in developing security selection models for PIM and FC Portfolio Managers. When seeking to anticipate trends and identify undervalued securities with sound fundamentals, Portfolio Managers for PIM and FC may also use a security selection and portfolio modeling process that incorporates fundamental, technical and statistical analyses of historical data. Due to any number of factors, including timing of Client asset deposits, investment selection process or Client investment needs, certain Clients receive different execution prices and investment results. Financial Advisors in the PIM program or FC program may implement the same or substantially similar investment strategies as an FA Directed Strategy in the Personalized Unified Managed Account (“Personalized UMA”) program. The trading processes for the FA Directed Strategies in the Personalized UMA program differ from the trading processes of the PIM and FC programs. These trading process differences will result in trading the same or substantially similar strategies at different times as between an FA Directed Strategy in Personalized UMA and the same or similar strategy in PIM or FC. In conjunction with strategy updates, a Financial Advisor may individually review some or all accounts in the PIM and/or FC programs before implementing trades. An individual review will not occur for an FA Directed Strategy in the Personalized UMA program. This will result in differences in the timing of trading as between an FA Directed Strategy in Personalized UMA and the same or similar strategy in the PIM and FC programs. These program differences will result in Clients in the same or substantially similar strategies in the PIM and FC programs receiving different execution prices and investment results than Clients in an FA Directed Strategy in the Personalized UMA program. For more information on how this may impact your Account, please consult with your Financial Advisor. Portfolio Manager Termination If for any reason your Portfolio Manager is unable to render investment services to your Advisory Program Account, we will attempt to transfer the Account to another Financial Advisor to act as Portfolio Manager for your Account, and you will be notified of any Page 9 of 36 571264 (Rev 57 - 03/26)  such transfer. If we are unable to transfer your Advisory Program Account to another Financial Advisor who is eligible to provide investment services to the Account, then we will terminate the Account in accordance with the terms of the Agreement and you will be notified of such termination. This change to your account is not a recommendation by WFA. Fees and Compensation All of the Program Accounts described in this brochure are charged a Program Fee on Program Assets that covers advisory, execution, custodial, and reporting services. The Standard Program Fee Schedules for each Program are set forth below. The standard Program Fee is negotiable. For transactions in both Non-Program Assets and "Excluded Program Assets" (Program Assets for which we have agreed that the Program Fee will not be applied), you will pay all of our usual and customary commissions, transaction fees and other charges. Non-Program Assets and Excluded Program Assets are not included in the calculation of the Program Fee. Commissions and fees on Non-Program Assets and other charges will be assessed against your Account on or about the transaction date or another date when assessed by us. See below for details on fee exclusions, calculations, refunds and other information. Asset Advisor Program Fee The current standard Program Fee for the Asset Advisor Program, which is negotiable, is shown below. Some accounts opened prior to June 9, 2017 are subject to a different fee schedule. Please consult the Program Features and Fee Schedule of your Client Agreement. Program Fee (annualized, calculated on your Account Value) 2.00% Certain Asset Advisor Clients are eligible to participate in certain allowable syndicate/new issue transactions. Positions purchased via syndicate/new issue transactions within your Asset Advisor Account will be excluded from the calculation of the Asset Advisor Program fee for a period of 12 months. Mutual funds, ETFs, annuities and Alternative Investments have fees associated with them that you will pay above and beyond the Advisory Fee and Manager Fee. These fees are embedded within the price of the mutual fund, ETF, annuity or Alternative Investment. Please refer to the prospectus or applicable offering document for specific fees associated with a given mutual fund, ETF, annuity or Alternative Investment. Over time, your total expenses to own an advisory annuity or Alternative Investment inside your investment advisory Account will exceed the total expenses to own a similar annuity or Alternative Investment outside your investment advisory Account. For advisory annuities, consider any charges and fees, including mortality and expense charges, administrative charges, and investment management fees and applicable 12b-1 fees for the portfolio options. These charges and fees will reduce the value of your Account and return on your investment. If you have selected a rider, or optional feature, there is typically an additional cost. Annuity contracts are available in several price structures at WFA. In addition to the advisory annuity contract fees and expenses, you will be charged an advisory fee based on the terms set forth in your advisory Client Agreement. This advisory fee will not be taken from the variable annuity contract. Certain advisory annuities that are available in the Asset Advisor Program contain subaccounts that are managed by an affiliate of ours. In these instances you should understand that our affiliate is compensated for performing that service and this creates a potential conflict of interest whereby we, or our affiliates, earn additional compensation. We intend, however, to make all recommendations independent of such considerations and based solely on our obligations to consider your objectives and needs. CustomChoice Program Fee The current standard Program Fee for CustomChoice Program, which is negotiable, is shown below. Some Accounts opened prior to June 9, 2017 are subject to a different fee schedule. Please consult the Program Features and Fee Schedule of your Client Agreement. Program Fee (annualized, calculated on your Account Value) 2.00% PIM and Fundamental Choice Program Fee The current standard Program Fee for the PIM and Fundamental Choice Programs, which is negotiable, is shown below. Some Accounts opened prior to June 9, 2017 are subject to a different fee schedule. Please consult the Program Features and Fee Schedule of your Client Agreement. Page 10 of 36 571264 (Rev 57 - 03/26)  Program Fee (annualized, calculated on your Account Value) 2.00% Fees and Compensation for All Programs In certain limited instances, we negotiate a customized Program or Advisory Fee schedule with Clients that is different than the Program or Advisory Fee described herein ("Program Fee" hereinafter refers to the Program Fee for all advisory programs with a Program Fee and to the Advisory Fee with respect to the Personalized UMA Program). In these instances, Clients will be required to sign an additional addendum that will detail their Program Fee schedule. The initial Program Fee is calculated as of the date that the Account is accepted by us into the Program and covers the remainder of the calendar quarter. There is typically a short delay between Account inception and initial investment transactions. Subsequent Program Fees will be determined for calendar quarter periods and shall be calculated on the basis of the Account Value on the last business day of the prior calendar quarter. No fee adjustment will be made to the Program Fee during any fee period for appreciation or depreciation in the value of the assets in your Account during that period. The Account will be charged or refunded a prorated quarterly Program Fee on any net additions or net withdrawals in the Account during a month. Program Fees will be charged or refunded if the net addition or net withdrawal would generate a fee or refund of at least $40 for that quarter. Program Fees will be assessed in the month following the net addition or net withdrawal. Fees are based on the value of the assets in your Account on the date stated and other than those fees we will not otherwise be compensated on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of your funds (i.e., performance fee). No adjustment will be made to the fee for cash and/or securities added or withdrawn if the account terminates prior to our monthly fee adjustment for such activity. The Platform Fee A Platform Fee of 0.050% will also apply to certain Program Accounts ("Participating Accounts"). • ERISA plans, SEPs, SIMPLE IRAs, Accounts of unaffiliated introducing firms that clear their transactions through us, but for which we do not act as adviser, and Accounts held at a third party custodian to which WFA agrees to act as broker for you in the purchase and sale of securities on a delivery versus payment/receipt versus payment ("DVP/RVP") basis are not subject to the Platform Fee and are not considered Participating Accounts. • All other Program Accounts are considered Participating Accounts. The Platform Fee applies only to the first $25 million of Account Value (defined below) and does not apply to Participating Accounts of unaffiliated introducing firms for which we act as adviser, or to Participating Accounts that have not been invested in a Program for a full calendar quarter and accounts that are not open on the date that the Platform Fee is assessed to Accounts. The Platform Fee supports the administrative services we provide to maintain the platform on which the Program Accounts reside, including, for example, shareholder and omnibus recordkeeping services provided to mutual funds available through the Programs. The Platform Fee is in addition to the Program Fee and is non-negotiable. The Platform Fee is assessed quarterly in arrears to such Participating Accounts that are open as of the date the Platform Fee is assessed, which will generally be within 10 business days after the end of the calendar quarter, and is calculated based on your Account Value as of the last business day of such quarter. General Information About Fees for Program Services We act as service provider for the advisory Programs offered by our affiliate, WFAFN, as well as certain fully disclosed firms that clear their transactions through us. The fees charged by these firms could differ from those charged and required by us as stated in this Disclosure Document. Please refer to the Disclosure Document of those firms, as appropriate, to determine the fees they charge. You should be aware that fees charged for a particular Program could be higher or lower than those otherwise available if you were to select a separate brokerage service and negotiate commissions in the absence of the extra advisory service provided. Advisory Programs typically assume a normal amount of trading activity and, therefore, under particular circumstances, prolonged periods of inactivity will result in higher overall fees than if commissions were paid separately for each transaction and no advisory fee was paid. The overall costs associated with your relationship with us (and the compensation we receive) vary depending on several factors, including: • Your particular investment advice requirements and product preferences • The value of your Account or household relations with us and our affiliates • The frequency of trades and other account activity • The type, scope, and frequency of services provided Page 11 of 36 571264 (Rev 57 - 03/26)  The Program Fee is negotiable based upon these and other subjective factors, as well as our point-in-time views of the prevailing market prices for similar investment services. As a result of negotiated Program Fees, certain Clients have a lower Program Fee for their accounts than other Clients in the same Program. If you liquidate securities prior to initiating or after terminating Program services, you will be subject to customary brokerage charges with respect to that transaction, in addition to any fees for Program Services that are applicable during the period. For eligible securities purchased previously in a brokerage Account and subsequently moved into an advisory Account, these securities will be included in the calculation of fees for Program services, in addition to any previous brokerage charges paid. A portion of the Program Fee (but not the Platform Fee) will be paid to our Financial Advisors in connection with the introduction of Accounts as well as for providing Client-related services within the Programs. This compensation could be more or less than a Financial Advisor would receive if you paid separately for investment advice, brokerage, and other services. The exact portion of the Program Fee paid to the Financial Advisor will vary among advisors and depends on various factors. Because the Financial Advisor shares the Program Fee, he or she has an incentive not to negotiate a discount, or to minimize any such discount. WFA also benefits from a higher Program Fee because it retains a portion of the Program Fee. If Fundamental Choice services are provided by a Bank PM, your WFA Financial Advisor will receive reduced compensation and our affiliate Wells Fargo Bank, N.A. will be compensated through receipt of a portion of the client's Program Fee for the services the Bank PM provides. This creates an incentive for the WFA Financial Advisor (and WFA) not to partner with a Bank PM and an incentive not to negotiate a discount, or to minimize any such discount in order to minimize the impact of the reduced WFA Financial Advisor compensation. The Bank PM may provide similar services outside of the Fundamental Choice program to accounts managed through Wells Fargo Bank N.A. for lower fees than those assessed through the Fundamental Choice program and other costs of investment may be lower for similar services provided though Wells Fargo Bank, N.A. The standard Program Fee is the same across different programs offered in this brochure and other brochures offered by WFA and is subject to a negotiated discount. The Personalized UMA Program and the Private Advisor Network Program also require clients to pay separate third-party Manager fees, which add to the total cost of the Program. Those Manager fees are not shared with your Financial Advisor or retained by WFA but lead to higher overall Program costs for you. Because the Program Fee for all Programs is negotiable, Programs that do not require clients to pay additional Manager fees (such as FundSource, Customized Portfolios, Asset Advisor, CustomChoice, Private Investment Management, and Fundamental Choice) provide your Financial Advisor with the opportunity to provide less of a discount on the Program Fee (i.e., negotiate a higher Program Fee), which will benefit WFA as well as the Financial Advisor. The opportunity to charge a higher Program Fee for Programs without additional Manager fees provides the Financial Advisor (and WFA) with a financial incentive to recommend such Programs. Within the Personalized UMA Program and the Private Advisor Network Program, a similar conflict of interest results from differences in Manager fees. Manager fees may not be assessed on certain strategies (including those offered by WFII) and certain strategies have lower Manager fees than other strategies. Differences in Manager fees, or the absence of such fees, create a conflict of interest as such differences provide an opportunity for your Financial Advisor to negotiate a higher Program Fee for accounts expected to use strategies with lower or no separate Manager fees than they would when an account is expected to use strategies that charge higher Manager fees. The opportunity to negotiate a higher Program Fee creates a financial incentive for your Financial Advisor to recommend such lower or no fee strategies. The ability of the Financial Advisor to negotiate a higher Program Fee in these circumstances also provides a financial benefit to WFA, which retains a portion of the Program Fee. Unless agreed to otherwise in writing, you authorize us to deduct fees at the rates indicated in the Fee Schedule for your Program quarterly from your Account(s). The Program Fee will generally be applied in advance, while the Platform Fee will be applied in arrears. For the purposes of calculating fees in the CustomChoice Program, "Account Value" shall mean the sum of the long market value of all eligible mutual funds, including accrued income. For the purposes of calculating fees in the Asset Advisor, Private Investment Management and Fundamental Choice Programs, "Account Value" means the aggregate value of all eligible long positions, including accrued income, cash, and cash alternatives held in the Account, offset by the value of the short positions held in the Account. When you initially enter into a short position, the cash proceeds from the short sale will not affect your Account Value for billing purposes, but once the value of the short position changes, this change will be reflected in your Account Value. Accordingly, if your Account has a short position that reflects an unrealized gain, the Account Value will increase by the amount of that unrealized gain. Similarly, an unrealized loss will reduce your Account Value by the amount of such loss. Note that if you use the proceeds of a short sale to purchase additional securities, those securities are included in the long positions used to calculate your Account Value. Here are examples of how a short position can affect your Account Value – and thus the fees you pay: • Short proceeds not reinvested – If, on the date as of which your advisory fee is calculated, you hold a long position in XYZ stock that is valued at $1,000, and also hold $250 in cash, and during the billing period you took a short position of $200 in ABC stock that was unchanged in value, your Account Value for billing purposes would be $1,250. If ABC stock increases in value to $300 (meaning that you have an unrealized loss of $100 on the short position), your Account Value would fall to $1,150. If the ABC stock decreases in value to $100, reflecting an unrealized gain of $100 on your short position, then your Account Value would increase to $1,350. • Short proceeds reinvested – If you reinvest all the proceeds from the $200 ABC short sale in PQR stock, and the value of ABC stock remains unchanged, your Account Value will increase (or decrease) by the amount of the appreciation (or depreciation) in PQR stock. If the value of PQR stock increases from $200 to $500, your Account Value would increase from $1,250 to $1,550, reflecting the value of all long positions in XYZ and PQR stock ($1,500), plus the value of the cash ($250), and offset by the value of the short position ($200). If, in the same scenario, the short position experienced an unrealized gain of $100, your Account Value would be $1,650. Page 12 of 36 571264 (Rev 57 - 03/26)  Margin debit balances do not reduce the Account Value, and purchasing eligible securities with proceeds from a Margin Loan increases your Account Value by the value of those positions. If the Margin Loan proceeds are reinvested in securities, the Account Value will be affected by any changes in the value of those securities. You will also be charged margin interest on the debit balance in your Account. Margin interest is in addition to the Program Fee and Platform Fee. The interest charges, combined with the Program Fee and Platform Fee, may exceed the income generated by the assets in your Account and, as a result, the value of your Account may decrease. In determining the Account Value, we will use the closing prices or, if not available, bid prices of the last recorded transactions for listed securities, options and over-the-counter securities. For mutual funds, we will use the fund's most current net asset value, as computed by the fund company. We value alternative investments held in your advisory Account based on the most recent fund value that we have received from the fund sponsor. Alternative investments are typically valued by fund sponsors on a monthly or quarterly basis. We generally receive updated alternative investment valuations from fund sponsors thirty to forty-five days after month-end for funds valued on a monthly basis and three to six months after quarter-end for funds valued on a quarterly basis. As a result, the fund valuations that we rely on may not reflect changes in the value of alternative funds over the prior six-plus months, including changes associated with distributions. We will use information provided by quotation services believed to be reliable in determining the Account Value. If any such prices are unavailable or believed to be unreliable, we will determine prices in good faith so as to reflect our understanding of fair market value. The Program Fee and the Platform Fee will be applied to cash and cash alternatives (i.e., money market funds) included in the Account Value. Clients will, in certain interest rate environments, pay Wells Fargo Advisors more in fees with respect to sweep holdings than the interest they earn on the sweep deposits. Due to trade date or settlement date accounting, the treatment of accrued income, short positions and other factors, the Account Value used in the calculation of fees could differ from that shown on your monthly Account statement and/or performance report. Whenever there are changes to your fee schedule, the schedule charges previously in effect shall continue until the next billing cycle. We have the ability to amend your Client Agreement at any time. Any changes we make to your Client Agreement will be effective after 15 days written notice to you. Your continued use of the services indicates your agreement to the modified terms. Advisory Account Credit We will apply a credit (an "Advisory Account Credit") to all Participating Accounts that were charged the Platform Fee during the relevant calendar quarter. Program Accounts that are not charged the Platform Fee during any calendar quarter are not eligible to receive an Advisory Account Credit for that calendar quarter. The application of the Advisory Account Credit is designed to address conflicts of interest associated with certain payments we receive from mutual funds (and their affiliates) and actively managed ETFs (ETFs that are managed by a single or team of fund managers) that are based on investments held in Participating Accounts. Such payments are limited to amounts paid for networking and omnibus platform services and revenue sharing generated by Participating Accounts (collectively, "Platform Support"), and does not include all fees we collect (for example, revenues received from advisory annuities—described below— are not included in the Platform Support). See "Mutual Funds and Exchange Traded Funds in Advisory Programs" below for a description of payments and expense reimbursements not considered Platform Support for purposes of calculating the Advisory Account Credit. The Advisory Account Credit is calculated based on the Platform Support accrued or collected attributable to eligible assets in Participating Accounts, as adjusted for amounts carried over from a prior period not previously credited and amounts credited in a prior period but not actually received. The calculation of the Advisory Account Credit will also be adjusted for the costs of third- party administrative expenses, if any, directly associated with the collection, calculation, and distribution of the Platform Support and application of the Advisory Account Credit. The Advisory Account Credit for each Participating Account that is charged a Platform Fee will be based on the Account Value of the Participating Account calculated as a percentage of the aggregate value (determined as of the last day of such quarter) of all Participating Accounts (up to $25 million per Account) charged the Platform Fee. The Advisory Account Credit will be credited quarterly and will generally be calculated and applied on the same day that the Platform Fee is applied. The Advisory Account Credit received by each Participating Account will not be directly proportionate to the benefit received by the Firm attributable to that particular Account. The amount of the Advisory Account Credit will vary quarterly, will be equal to, less than or more than the Platform Fee, and could be $0. The amount of the Advisory Account Credit is dependent on the amount of the Platform Support, if any, that is collected as described herein. This amount varies based on factors such as changes in the allocation or value of mutual fund and actively managed ETF assets in Program Accounts, changes in our agreements with mutual fund and ETF companies, and market forces. For taxable accounts, to the extent your Advisory Account Credit exceeds the total amount of fees for Program services charged in any given year, the difference is treated as miscellaneous income for tax reporting purposes, and you will receive IRS Form 1099- MISC from Wells Fargo Clearing Services, LLC in the event your aggregate, annual miscellaneous income is $600 or greater. We reserve the right to stop collecting the Platform Support at any time and, if we do not receive Platform Support, the Advisory Account Credit will be $0. We have no obligation to attempt to maximize Platform Support during the time in which we are collecting it. Page 13 of 36 571264 (Rev 57 - 03/26)  Important Information about the Advisory Account Credit Although the Advisory Account Credit is intended to address our direct financial interests in, and conflicts with respect to, our receipt of Platform Support from mutual funds and actively managed ETFs, the structure of the Advisory Account Credit nevertheless results in other conflicts that you should understand. In calculating the Advisory Account Credit, Platform Support generated by mutual fund and actively managed ETF holdings in Participating Accounts will be credited on a pro rata basis (based on Account assets of up to $25 million) to all Participating Accounts that are charged the Platform Fee. As a result, Participating Accounts that are charged the Platform Fee will receive an Advisory Account Credit regardless of whether, and the extent to which, such Accounts invest in products that contribute to the Platform Support. The amount of the Advisory Account Credit a Participating Account receives will be equal to, more than or less than the amount of Platform Support generated by its actual mutual fund or actively managed ETF holdings, if any. Thus, certain Participating Accounts will benefit from the Platform Support attributable to the investments of other Participating Accounts. The mutual fund and actively managed ETF holdings in Participating Accounts for which we are not charging the Platform Fee (Participating Accounts of unaffiliated introducing firms for which we act as adviser and Participating Accounts that have not been invested in a Program for a full calendar quarter, as well as with respect to the portion of the Account Value of Participating Accounts in excess of $25 million) will generate Platform Support, but will not receive an Advisory Account Credit. As a result, the amount of Platform Support attributable to mutual fund and actively managed ETF holdings in these Participating Accounts (which are not subject to the Platform Fee) will be used for the benefit of the other Participating Accounts that were charged the Platform Fee. This is particularly the case for Participating Accounts of unaffiliated introducing firms for which we act as adviser, which we expect to generate Platform Support. As a result, it is expected that the mutual fund and actively managed ETF investments of unaffiliated introducing firms' Participating Accounts will increase the Advisory Account Credit available and applied to Wells Fargo Participating Accounts. We seek to address these conflicts of interest through a combination of disclosing it to you, and through our policies and procedures and related controls designed to ensure that we make investment decisions relating to mutual funds and actively managed ETFs available in advisory Program Accounts independent of any considerations that may impact the amount of any such Advisory Account Credit. Market Timing in Mutual Funds Market timing is defined as excessive short-term purchase and sale transactions or exchanges with the intention of capturing short-term profits in violation of the terms of the fund's prospectus. We will not support market timing strategies or activities for mutual funds or any extreme trading activity that we deem, in our sole discretion or by direction of the fund company, detrimental to the interest of average mutual fund shareholders, or contrary to the policies or interest of mutual fund companies with whom we maintain relationships. We, in our sole discretion or by direction of the fund company, reserve the right to reject any transactions or to assess a redemption fee for any partial or full liquidation executed in which the Account trading appears to be inconsistent with the fund's prospectus. Furthermore, when asked by a fund company, we will cooperate and aid in its attempt to identify and impede the efforts of anyone engaged in market timing or extreme trading activity. If the fund company notifies us to reject or cancel a trade for any reason, we reserve the right to cancel it without prior notice to you or any other Client. We will not be held accountable for any losses resulting from market timing activities or any action taken under our market timing policies. Finally, the frequency of mutual fund transactions and exchanges is subject to any limits established by the applicable mutual funds and us. Margin Loans and Securities-Based Loan Programs You may be eligible to use margin in your non-retirement Accounts or pledge your non-retirement Account assets as collateral for margin loans ("Margin Loans"). You may also be able to pledge your non-retirement Account assets as collateral for loans obtained through certain affiliated and unaffiliated loan programs ("Securities-Based Loan Programs"). It is important that you fully understand the costs, risks, and conflicts of interest involved in pledging your Account assets for a Margin Loan or Securities- Based Loan. Margin Loans Certain Advisory Programs may permit margin borrowing and trading. We will not extend margin in an advisory account unless authorized by you through a separate Margin Account Agreement. You are responsible for notifying us if you decide that you no longer want to use margin in your Account. You may also discontinue use of margin in your Account according to the terms of the Client Agreement. We are not responsible for any losses resulting from our failure or delay in implementing such instructions. Margin Loans Are Subject to Separate Terms and Conditions. If you take out a Margin Loan, the terms and conditions applicable to the Margin Loan are governed by the Margin Account Agreement, Margin Disclosure Statement and the Client Agreement. You should review carefully the terms, conditions, and risk disclosures for Margin Loans and understand that such risks are heightened in the event you hold a concentrated position in your pledged Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investable assets. Certain eligibility requirements must be met, and documentation in the form of a separate Margin Account Agreement must be completed prior to using margin. Page 14 of 36 571264 (Rev 57 - 03/26)  Costs Are in Addition to Advisory Fees. As discussed above, if you use margin to purchase additional securities, your Account Value increases and therefore the amount of fees you pay will increase. You will also be charged margin interest on the debit balance in your Account, which is in addition to the Program Fee and Platform Fee. This results in additional compensation to us. Interest rates for Margin Loans and Securities-Based Loans have different features and eligibility criteria. The interest charged on a Margin Loan is generally higher than the interest charged on affiliated Securities-Based Loans, including WF Bank PCL and WFA PCL. We Have an Incentive to Recommend the Use of Margin. The increased asset-based fee and interest that you pay on a Margin Loan provides an incentive for your Financial Advisor to recommend the use of margin. Your Financial Advisor also has an incentive to use margin to purchase additional securities and other assets instead of selling existing securities or other assets. We address these conflicts by disclosing them to you. Margin Loans May Not Be Suitable for You. Using margin is not suitable for all investors. As described in the next paragraph, the use of margin increases leverage in your Account and therefore increases risk to a portfolio. We generally believe the use of margin is most appropriate when short in duration. Before deciding to use margin, you should consider the intended duration and total cost of the Margin Loan, as well as other options available to you, such as alternative loan options or liquidating your Account assets. Using Margin Involves Higher Risks. Generally, we believe that the use of margin adds risk to a portfolio that you should not assume unless you are prepared to experience significant losses. Losses in the value of an asset purchased on margin will be magnified because of the use of borrowed money. You can lose more funds than amounts deposited in margin accounts. In addition, you generally will not benefit from using margin unless the performance of your Account exceeds interest expenses on the Margin Loan plus advisory fees incurred. You should also understand that the use of margin can negatively impact our ability to rebalance your account. You should carefully consider whether the additional risks are appropriate prior to using margin due to the increased potential for significantly greater losses associated with using margin. You assume full responsibility for the use of margin in your Account. Important: Please see the Margin Disclosure Statement and the Client Agreement for more details on the risks of margin use. You should read this documentation carefully. Securities-Based Loan Programs You may pledge your Account assets as collateral for Securities-Based Loan Programs with our consent and where you are eligible under the programs. The Securities-Based Loan Programs include, but are not limited to, the WF Bank Priority Credit Line (“WF Bank PCL”), offered by Wells Fargo Bank, N.A. (“Wells Fargo Bank”) in partnership with Wells Fargo Advisors, the Priority Credit Line ("WFA PCL") from Wells Fargo Advisors and various Securities-Based Loan Programs from our affiliate Wells Fargo Bank. The Secured PrimeLine program, offered by Wells Fargo Bank is available only in limited circumstances. The availability of these Securities-Based Loan Programs may vary over time. In order for your Account to be eligible to serve as collateral for a Securities-Based Loan, your Account may not also serve as collateral for a Margin Loan. If you wish to use your Account as collateral for a Securities-Based Loan, we will automatically discontinue the availability of margin for your Account. There are risks, costs, and conflicts of interests associated with Securities-Based Loan Programs. You are encouraged to speak with your Financial Advisor to the extent you have questions about how your Account may be used in connection with a Securities- Based Loan Program and how such arrangement should be taken into consideration when discussing the management of your Account. Securities-Based Loan Programs Are Subject to Separate Terms and Conditions. If you have elected to participate in a Securities-Based Loan Program, the terms and conditions applicable to that Securities-Based Loan Program are governed by the applicable Securities-Based Loan documents and other service agreements and are not included or described further in this brochure. You should review carefully the terms, conditions and any related risk disclosures for the Securities-Based Loan Program and understand that risks are heightened in the event you hold a concentrated position in your pledged Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investable assets. You should understand that WF Bank PCL, WFA PCL and other Securities-Based Loans that are "securities contracts" under the Bankruptcy Code provide more favorable protection for the lender (WFA or Wells Fargo Bank) in the event of your bankruptcy than other loan programs through us. Certain eligibility requirements must be met and documentation must be completed prior to obtaining Securities-Based Loans. Interest Rates for Securities-Based Loan Programs Differ. Interest Rates for Securities-Based Loan Programs are different and have different features and eligibility criteria. More than one Securities-Based Loan Program product may be available to you. The interest rate charged for one offering may be higher than interest rates available through another lender or offering. Costs Are in Addition to Advisory Fees. The costs, including interest, associated with a Securities-Based Loan Program are not included in the Program Fee or Platform Fee and will result in additional compensation to WFA, our affiliate, and our Financial Advisors. The interest charges on your Securities-Based Loan Program, combined with the Program Fee and Platform Fee, may exceed the income generated by your pledged Account assets and, as a result, the value of your Account may decrease. You are encouraged to consider carefully the total cost of taking out a Securities-Based Loan, and any additional compensation that WFA and your Financial Advisor will receive, when determining to take out and/or maintain a Securities-Based Loan against your Account assets. Page 15 of 36 571264 (Rev 57 - 03/26)  Financial Advisors Receive Compensation on Securities-Based Loans. In addition to receiving a portion of the Program Fee, Financial Advisors also receive compensation based on the outstanding loan balances of WF Bank PCL, WFA PCL and other Securities-Based Loan Programs from Wells Fargo Bank. The Financial Advisor's compensation is reduced if the interest rate on WF Bank PCL, WFA PCL or other Securities-Based Loan from Wells Fargo Bank is discounted below a certain level, which creates an incentive for the Financial Advisor to not request for you or to discourage interest rate discounts below a certain level. We Have an Incentive to Recommend the Use of Securities-Based Loan Programs. Since WFA and your Financial Advisor are compensated through asset-based advisory fees paid on your Account, we benefit if you draw down on your Securities-Based Loan, which preserves asset-based advisory fee revenue and generates additional loan-related compensation, rather than sell securities or other investments in your Account, which would reduce the assets in your Account and our asset-based advisory fee revenue. This presents a conflict of interest for your Financial Advisor when addressing your liquidity needs. In addition, where a Securities-Based Loan is secured by both brokerage and advisory assets, a Financial Advisor will benefit if your brokerage assets are liquidated prior to or instead of your advisory assets because the Financial Advisor would be able to maintain advisory Account assets subject to the Program Fee and Platform Fee. We address these conflicts by disclosing them to you. Securities-Based Loan Programs May Not Be Suitable for You. There are other lending products that may be suitable for you and for which we and your Financial Advisor would receive different or no compensation. You are responsible for independently evaluating if a Securities-Based Loan is appropriate for your needs, if the lending terms are acceptable, and whether the Securities-Based Loan will have potential adverse tax or other consequences for you. There Are Limitations on the Use of Securities-Based Loan Proceeds. Except for margin accounts, where the loan proceeds can be used to purchase, carry, or trade securities, the proceeds of the other Securities-Based Loans available from Wells Fargo Bank or WFA may not be used to: purchase, carry, or trade securities (or margin stock in the case of loans offered by Wells Fargo Bank); or reduce or retire any indebtedness incurred to purchase, carry, or trade securities (or margin stock in the case of loans offered by Wells Fargo Bank). If your Account is used as collateral for a Securities-Based Loan, the Account is pledged to support the Securities-Based Loan and you are not permitted to withdraw funds or other assets from your Account unless sufficient amounts of collateral remain to continue supporting the Securities-Based Loan (as determined under the applicable Securities-Based Loan Program). Although you are required to satisfy such collateral requirements, you can terminate your advisory relationship with WFA, at which time the funds and assets in your account will be treated as a brokerage account at WFA and the collateral requirements for the Securities-Based Loan will continue to apply. Additional Considerations Associated with Pledging Advisory Account Assets for Margin Loans and Securities-Based Loans In addition to the risks mentioned above, if your Account assets are pledged or otherwise used as collateral for Margin Loans or Securities-Based Loans, the exercise of the lender's (WFA or Wells Fargo Bank) rights and powers over your Account assets, including the disposition and sale of any and all assets pledged as collateral, may be contrary to your interests and the investment objective of your Account. There Are Collateral Maintenance Requirements. When you use margin to purchase securities or draw down on a Securities-Based Loan, your Account assets serve as collateral. For Margin Loans, WF Bank PCL, WFA PCL and some other Securities-Based Loans from Wells Fargo Bank, the lender can increase the maintenance requirements or call the loan at any time and for any reason, and is not required to provide you with advance written notice (although these approaches will be different for other loan programs from Wells Fargo Bank, and may be different for loans from unaffiliated lenders). If your Account assets decline in value, so does the value of the collateral. If the required collateral is not maintained, you may need to deposit additional cash or securities as collateral or repay a partial or the entire amount of the funds borrowed on short notice. You are not entitled to an extension of time on a maintenance call. The lender may refuse to fund any advance request due to insufficient collateral. Where the lender assigns different advance rates to different asset types, you may be able to satisfy collateral maintenance requirements by selling securities with a low advance rate and investing and/or holding the proceeds in assets that have a higher advance rate for the loan. Liquidation of Securities in a Maintenance Call. Failure to promptly meet requests for additional collateral or repayment, or other circumstances including but not limited to a rapidly declining market, will cause the liquidation of some or all of the collateral supporting any Margin Loans or Securities-Based Loans in order to meet the maintenance requirements. The lender can sell your Account assets without contacting you. Neither the lender nor WFA are required to notify you of a maintenance call. The details and timing of how the lender handles a maintenance call will be different for other loan programs from Wells Fargo Bank, and may be different for loans from unaffiliated lenders, but with Margin Loans and Securities-Based Loans, you will be responsible for any shortfall if your Account assets are insufficient to cover the maintenance deficiency. Even if the lender has notified you and provided a specific date by which you can meet a maintenance call, the lender can still take necessary steps to protect its financial interests, including immediately selling your Account assets without notice to you. You should understand that because your Account assets are collateral for the Margin Loans or Securities-Based Loans, in selling such assets, the lender will seek to protect or advance its interests over your interests. You should expect that the lender's interests will not be aligned with—and will be adverse to—your interests when the lender sells assets during a maintenance call, and that the lender may sell assets that you desire to keep or sell them at prices that may be less than the value that we or you believe the assets are worth. You are not entitled to choose which Account assets are liquidated or sold to meet a maintenance call. If there are Account assets that you desire to own during the term of your Margin Loan or Securities-Based Loan, you should not pledge them as collateral. Depending on market circumstances, the prices obtained for your Account Page 16 of 36 571264 (Rev 57 - 03/26)  assets may be less favorable and may be less than the value that we or you believe the assets are worth. If a maintenance call cannot be fully satisfied from your Account assets, you remain liable for the outstanding debt. Impact of Maintenance Calls on Management of Your Account. In a maintenance call, the lender might liquidate Account assets that you, your Financial Advisor, or your Manager otherwise would not sell, and that might not otherwise be in your best interests to sell, and you will not get to choose the assets that are liquidated. We or a third-party Manager will seek to manage your Account as agreed under your advisory Client Agreement and applicable Program Features and Fee Schedule, provided that, if a maintenance call takes place, you should expect that we or your Manager will not be able to manage your Account consistent with our or the Manager's overall strategy. In addition, in order to preserve sufficient collateral value to support the loan and avoid a maintenance call, depending on your leverage, a Financial Advisor may be inclined to invest your Account in more conservative investments, which may result in lower investment performance than more aggressive investments (depending on market conditions). We mitigate this risk by requiring and monitoring to ensure that your Account is managed consistent with your respective investment strategies. No Legal or Tax Advice. WFA, our affiliates and your Financial Advisor do not provide legal or tax advice. You should consult with your own legal counsel and independent tax advisor before using securities as collateral for loans in order to fully understand the tax implications associated with pledging your Account as loan collateral and the potential liquidation of pledged assets. Other Account Fees The fees for Program services do not include certain dealer markups or markdowns, odd lot differentials, transfer taxes, exchange fees, execution fees (foreign and/or domestic) when applicable, ADR custodial pass through fees, foreign financial transaction taxes when applicable, and any other fees required by law. Cash balances in an Account may be invested in money market mutual funds including, as permitted by law, those with which we have agreements to provide advisory, administrative, distribution, and other services and for which we receive compensation for the services rendered. You should understand that, depending on interest rates and other market factors, the yield that you earn on cash and cash alternatives, including cash sweep deposits, CDs and money market funds in an Account, has been, and may continue in the future to be, lower than the aggregate advisory fees you pay on cash assets held in an Account. As a result, depending on the interest rate environment, you may experience a negative overall investment return with respect to cash held in an Account. Furthermore, in some instances, the effective return on a cash sweep may be negative. If you invest in foreign stocks or American depository receipts (“ADRs”), you will be subject to foreign tax withholding on the dividends paid or interest earned. An ADR represents underlying shares of a foreign corporation which are held and issued by a bank. While ADRs are traded on U.S. markets, the income and tax withholding are subject to the rules and regulation of the foreign tax authorities with jurisdiction over the underlying corporation. When dividends or interest is paid to investors on such foreign securities, the tax authorities for that country requires the payor to withhold taxes for certain foreign investors. This can negatively impact the rate of return on your investment. U.S. clients could be eligible to reclaim a portion of foreign taxes that are withheld and/or receive a preferential foreign tax rate on foreign securities by filing specific tax forms seeking such relief. We do not provide tax advice. Please consult your tax advisor for specific information on foreign tax withholding, your eligibility to reclaim a portion of taxes withheld and/or receiving a preferential foreign tax rate and the costs associated with these filings. Any non-brokerage fees that are not included in the fees for Program Services will be charged to your Account separately. Your Financial Advisor may suggest that you use other products and services that we offer, but that are not available through the Program you select. Non-Program Assets are not charged a Program Fee or a Platform Fee, are not considered in determining the Advisory Account Credit, and are not considered a part of the Program or Program services. We generally recommend that you hold these Non-Program Assets in a separate brokerage Account. If a Non-Program Asset purchased for or transferred into your Account later becomes a Program Asset, the Program Fee and Platform Fee will apply to that Asset without prior notice to you. In Asset Advisor, if that Asset is a mutual fund it may then become subject to the Rebalance Trading System. You will incur any usual and customary brokerage charges and fees imposed on transactions in Non-Program Assets which could include: any dealer markups and odd lot differentials, transfer taxes, and other fees; charges imposed by broker-dealers and custodians other than us and fees for other products and services that we offer; offering discounts, commissions and related fees in connection with underwritten public offerings of securities; margin interest and operational fees and charges; IRA fees; and any redemption fees, exchange fees and/or similar fees (among which SEC fees are included) imposed in connection with mutual fund transactions whereby we or your Financial Advisor receive additional compensation on these Non-Program Assets. Where these fees apply, the more transactions you enter into, the more compensation that we and your Financial Advisor receive. This compensation creates an incentive for us to recommend that you buy and sell, rather than hold, these investments. We also have an incentive to recommend that you purchase investment products that carry higher fees, than investment products that carry lower fees or no fees at all. If you choose to use Trust services provided by our affiliate, Wells Fargo Bank, N.A., additional costs apply that are in addition to the advisory fees disclosed above. These Trust services would include custody of your account at Wells Fargo Bank, N.A. The fees for these services will be separately agreed upon and disclosed to you by the bank and compensation for those services will be paid directly to the bank separate from the advisory fee. Compensation Related to Our Financial Advisors and Branch Management Financial Advisors. Financial Advisors providing service to Clients from either a WFA branch or an office located in a Wells Fargo Bank, N.A. branch receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout Page 17 of 36 571264 (Rev 57 - 03/26)  schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Financial Advisors discount certain client fees and commissions, or client relationship asset levels are below minimums established by us. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFA advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor’s expense budget and bonus increase, and the Financial Advisor may qualify for recognition trips. Also, as mentioned above the payout schedule is reduced when certain fees are discounted, thus Financial Advisors are discouraged from providing discounts below certain thresholds when negotiating discounts to commissions for brokerage accounts and Program Fees for Advisor Program Accounts. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial Advisor has an incentive to recommend that you invest account assets in an advisory account which have ongoing Program Fees (discussed above) versus a brokerage account which have transaction-based fees. Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities-Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Solutions Team. Financial Advisors receive compensation for each client referred to the Solutions Team, described in the Personalized Unified Managed Account section above. However the Financial Advisor could provide these same services directly to the Client. As a result of the compensation details provided above, Financial Advisors have a financial incentive to not refer otherwise eligible clients to WFA Solutions due to the greater compensation if the Financial Advisor serves the client directly, as these assets will be attributed to those of the Financial Advisor for compensation pay-out, bonus and recognition purposes. Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Financial Advisors are also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include overall company performance, reaching certain production levels, tenure with the Firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices. These incentives—particular ones based on production levels (i.e. revenue and profit generated for the Firm), product mix, asset gathering and referrals to affiliates—result in Financial Advisors being encouraged to recommend courses of action that increase your usage of products and services offered by us and our affiliated companies such as Wells Fargo Bank, N.A. and Wells Fargo Securities, LLC. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following three components: an up-front payment; a deferred compensation component; and a back-end bonus arrangement based on new client assets transitioned/gathered over a three-year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFCS. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFCS. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFCS and WFCS's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of certain titles and/or education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Financial Consultants. Financial Consultants work with branch-based Financial Advisors in serving the Financial Advisor’s Clients. When licensed to do so, Financial Consultants can provide advice to clients with brokerage or advisory accounts. The revenue that the firm receives as a result of the Financial Consultant’s recommendations is attributed to the Financial Advisor with whom the Financial Consultant works. Financial Consultant compensation comprises a salary and, when agreed to between the Financial Consultant and Financial Advisor, the Financial Consultant’s compensation also includes a portion of the revenue the Firm pays to the Financial Advisor. Therefore, Financial Consultants, similar to Financial Advisor, have an incentive to make recommendations that result in Clients adding funds to WFA advisory and brokerage accounts, and selecting products and services that generate the most revenue and profit for the Firm. Page 18 of 36 571264 (Rev 57 - 03/26)  Phone-Based Financial Advisors. Centralized, phone-based Financial Advisors providing brokerage and advisory services via a call center are compensated by salary and discretionary performance bonus. For these Financial Advisors, their discretionary bonus is based on a number of factors including company performance and individual performance which takes into consideration a variety of factors including telephony metrics and production metrics such as funded accounts and net asset flows, client referrals to Wells Fargo Bank, N.A. for trustee or investment management services, and client usage of lending product and affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A. Supervisor Compensation. Branch Managers and Area Managers (who are responsible for supervising Financial Advisors operating from a Wells Fargo Bank, N.A. branch) are compensated based on the total revenue generated by the Financial Advisors subject to their supervision. A portion of the Branch Manager’s and Area Manager’s compensation is also based on the branch meeting business growth targets—such as net asset flows from clients, client usage of lending products, financial advisor recruitment and retention, and client usage of affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.—and branch profitability. Therefore, Branch Managers and Area Managers have an incentive to encourage Financial Advisors to recommend products and services that increase or maximize revenue and profit received for the Firm. When Branch Managers and Area Managers serve as Financial Advisors to brokerage and advisory account clients; the Branch Manager (or Area Manager) is compensated as described above for Financial Advisors. Market Growth Strategy Consultants. Market Growth Strategy Consultants support branch-based Financial Advisors and Branch Managers in the growth of WFA advisory accounts. Market Growth Strategy Consultants are compensated by salary and a bonus based on gross asset flows in in Advisory Program Accounts at the branches that they are responsible for supporting and on gross assets referred to the Wells Fargo Bank, N.A. trust services platform. Therefore, the Market Growth Strategy Consultant has a conflict of interest, and is incentivized to emphasize the potential benefits of WFA Advisory Program Accounts and trust and investment management services provided by Wells Fargo Bank, N.A. when providing support to Branch Managers, Financial Advisors, or when joining Financial Advisors in discussions with Clients considering an Advisory Program Account or contributing additional funds to an existing Advisory Program Account. IRA Rollovers – Conflicts and Incentives to Transfer Assets from Employer-Sponsored Qualified Retirement Plans to WFA Financial Advisors have an incentive to recommend that you roll over assets from an employer-sponsored Qualified Retirement Plan ("QRP"), such as a 401(k), to an Individual Retirement Account ("IRA") with us. If you are rolling over assets, you should carefully evaluate all choices which are typically available. We have a conflict of interest in connection with a rollover of your assets into an IRA and the investment of the assets with us as opposed to leaving the assets in your former employer's plan or electing another option. The conflict arises because we will likely earn no compensation if you were to leave the assets in your former employer's plan or transfer to your new employer's plan. In addition, the costs of maintaining and investing assets in an IRA with us will generally involve higher costs than the other options available to you. While we typically offer a broader range of investment options and services than an employer-sponsored QRP, there are no guarantees that the additional investment options will outperform your employer-sponsored QRP. Mutual Funds and Exchange-Traded Funds in Advisory Programs When structuring our advisory Program offerings, we determine the universe of mutual funds and ETFs that will be made available to advisory Program Clients. Although mutual fund companies typically offer multiple share classes of each of their mutual funds with varying levels of fees and expenses, we generally choose a single share class of each mutual fund for our advisory Program platform. We do not seek to offer mutual funds or share classes through our advisory Programs that are necessarily the least expensive. Investing in mutual funds will generally be more expensive than other investment options available in your advisory Account, including many ETFs. In addition to the Program Fee and the Platform Fee, you will also bear a proportionate share of each fund’s expenses, including investment management fees that are paid to the fund’s investment adviser, and distribution, shareholders services or other fees paid to us and our affiliates. These expenses are an additional expense to you and not covered by the fees for Program services; rather, they are embedded in the price of the fund. You should carefully consider these underlying expenses, in addition to the Program Fee and Platform Fee, when considering any advisory Program and the total compensation we receive. Other funds and share classes may have different charges, fees, and expenses, which may be lower than the charges, fees, and expenses of the funds and share classes we make available. These funds and share classes are available through other broker-dealers and financial intermediaries, including our affiliates, and the Funds directly, including where lower-cost share classes are made available. An investor who holds a less-expensive share class of a fund will pay lower fees over time—and earn higher investment returns—than an investor who holds a more expensive share class of the same fund. When we select a fund or fund family for our advisory Program platform, we consider a number of factors, including our costs to operate the platform and additional compensation factors. In many circumstances, we receive payments and compensation from fund companies, including where we effect transactions for, or provide services to, the funds, and not all of these payments and compensation constitute Platform Support. We generally choose the lowest cost share class for our Advisory platform that pays us an acceptable level, as determined in our discretion, of Platform Support and other compensation discussed below. Generally, the Platform Support compensation from mutual funds for omnibus services performed is paid at a rate up to $25 per year, per position or at a rate of up to 30 basis points on assets; compensation for networking service performed is paid at a rate of up to $12 per year, per Client position or at a rate of 12 basis points on assets for networking services performed; and revenue sharing is paid at a rate of up to 20 basis points for domestic funds and up to 55 basis points for offshore fund companies on aggregate Client assets. The Platform Support compensation attributable to revenue sharing for actively managed ETFs is Page 19 of 36 571264 (Rev 57 - 03/26)  calculated based on client account holdings of actively managed ETFs using a tiered rate that increases along with the management fee of the ETF. Sponsors pay revenue sharing compensation which ranges up to a maximum rate of 15% of total net expense ratio per year. The mutual funds we include on our advisory Program platform do not pay us 12b-1 fees. Additional compensation and support received in connection with mutual funds and ETFs is described in more detail below and is also described in the "Guide to Investing in Mutual Funds" and "Guide to Investing in Exchange-Traded Products" at www.wellsfargoadvisors.com. Additional compensation and support received in connection with advisory annuities is described in the "Guide to Buying Annuities" at www.wellsfargoadvisors.com. Additional compensation and support received in connection with advisory annuities is not considered Platform Support. The additional compensation and support we receive from fund companies, which is not considered Platform Support, is for ongoing educational and training services performed by us and compensation we receive in connection with data agreements. This additional support varies between fund companies and even from fund to fund and share classes within the same fund company. As a result, and notwithstanding amounts we credit to Accounts through the Advisory Account Credit or otherwise, to the extent that we retain these payments, we have a financial incentive to offer one fund on our advisory Program platform over a similar fund due to the compensation we retain from one fund versus another or one share class of a fund versus another. This additional compensation poses a conflict of interest and influences the selection of funds, share classes, and fund companies that we make available on the Advisory platform. We seek to address these conflicts of interest through a combination of disclosing it to you, implementation of the Platform Fee and Advisory Account Credit, and through our policies and procedures and related controls designed to ensure that the fees we charge are fair and reasonable, including, as applicable, the Program Fee and Platform Fee and the additional compensation we receive from funds other than Platform Support. If we did not receive support payments and additional compensation, we might charge higher fees or other charges to you for the services we provide (or the Advisory Account Credit, where applicable, would be less or $0). When evaluating the reasonableness of our fees and the total compensation we receive, you should consider not just the Program Fee and the Platform Fee, where applicable, but also the additional payments and compensation we and our affiliates receive from funds (and their affiliates), including compensation other than Platform Support, and your eligibility for, and the amount of the, Advisory Account Credit. For a listing of all share classes that a given fund offers, please refer to the fund’s prospectus. Please call your Financial Advisor for more information about any limitations on share classes available through us. Over time, given funds may offer share classes with lower fees. In these instances, we will determine, from time to time in our discretion, whether and in what manner to offer these share classes to our advisory Clients. This may result in shares you own of the given fund being converted to the share class with lower fees or such share class with lower fees being available only for new purchases. We review our policies, procedures and systems from time to time in our discretion to determine whether to continue to offer funds with these multiple share classes, and reserve the right to no longer offer certain share classes within our advisory Program platform. Additional Payments Received from Funds and Advisory Annuities We typically receive support payments and compensation paid by fund complexes for ongoing Account maintenance, marketing support, and education and training services we perform. This additional compensation can be broken down into general categories: • Networking and omnibus platform services compensation • Revenue sharing • Training and education support • Data Agreements This additional compensation is described below, including which compensation is not considered Platform Support and is therefore retained by Wells Fargo. Networking and omnibus platform service fees We or our service providers typically collect from mutual funds in which you invest, compensation for recordkeeping, sub- accounting, shareholder communications, administrative, and other similar services we provide to a fund for your benefit. In addition, we generally collect other asset-based fees for the execution of fund share purchases, or the performance of clearance, settlement, custodial or other ancillary functions. We or our service providers collect such fees directly or indirectly from some or all of the mutual funds in which you invest. When providing advisory services, WFCS does not pay any portion of these fees to its FAs. The compensation paid for networking and omnibus platform services, if any, is negotiated separately with each fund company, and the amount varies depending on the fund company and share class of each individual fund. In addition, not all mutual funds pay network and omnibus platform service fees, as a result we have an incentive to include funds on our platform and recommend funds that pay networking and omnibus platform service fees. Advisory Clients are not permitted to restrict their Accounts to only mutual funds that do not pay networking and omnibus platform service fees. We do not collect networking and omnibus payments on Program Accounts for ERISA plans, SEPs, and SIMPLE IRAs. Networking and omnibus platform service fees generated based on mutual fund positions and assets under management in Participating Accounts are considered Platform Compensation and included in the Advisory Account Credit. Page 20 of 36 571264 (Rev 57 - 03/26)  Revenue sharing Revenue sharing is paid by a mutual fund's investment advisor, distributor, or other fund affiliate to us for providing continuing due diligence, training, operations and systems support and marketing to Financial Advisors and Clients with respect to mutual fund companies and their funds. Revenue sharing fees are usually paid as a percentage of our aggregate value of Client assets invested in the funds. Revenue sharing is also paid to us for actively managed ETFs. Revenue sharing rates can differ depending on the fund family, and in some cases we receive different revenue sharing rates for certain funds and share classes within a particular fund family. In addition, not all mutual funds and actively managed ETFs pay revenue sharing, as a result we have an incentive to include funds on our platform and recommend funds that pay revenue sharing and/or pay a higher rate. Advisory Clients are not permitted to restrict their Accounts to only mutual funds or ETFs that do not pay revenue sharing. We do not collect revenue sharing payments on Program Accounts for ERISA plans, SEPs, and SIMPLE IRAs. Revenue sharing payments generated based on mutual fund and actively managed ETF assets under management in Participating Accounts are considered Platform Support and included in the Advisory Account Credit. Training and education support Certain mutual fund families, ETF providers and investment managers have agreed to dedicate resources and funding to provide training and education in local branch offices or in larger group settings, including at the national level. This commitment could lead our FAs to focus on the products offered by these firms versus products offered by firms not represented during these training and education sessions. These meetings or events are held to teach Financial Advisors about the product characteristics, sales materials, suitability, customer support services and successful sales techniques as they relate to various products. We select the firms that participate in the training and education events based on a variety of qualitative and quantitative criteria and may provide supplemental sales and financial data to these firms. The subset of firms that offer this support and participate in nationally- organized training and education events changes periodically. The resources and funding for training and education are not considered Platform Support and are not included in the Advisory Account Credit. Data Agreements We work with various mutual fund complexes, ETF providers, annuity companies and Alternative Investment advisors and/or managers to provide aggregated sales data. Payments for Data Agreements are not considered Platform Support and are not included in the Advisory Account Credit. Generally, the payments range up to $1,150,000 per year for data agreements from mutual fund complexes, ETF providers, annuity companies and Alternative Investment advisors/managers. For more information about our compensation derived from mutual funds, please see “A Guide to Investing in Mutual Funds” or the “General Account Agreement and Disclosure Document.” Payments from Advisory Annuities For advisory annuities, held in non-qualified Accounts (i.e., Accounts other than an IRA or Accounts subject to ERISA) for a period longer than one year, we receive up to 0.10% annually of the dollar value of the advisory annuity. In addition, marketing support payments are made to WFA to cover costs WFA incurs such as training and education of our financial advisors, client meetings, and recordkeeping. These payments benefit us since they cover expenses we would otherwise incur when carrying out these functions. To the extent these payments exceed the related expenses they are intended to cover, WFA retains the excess. As stated above in the “Advisor Account Credit” section, these payments do not form part of the Advisory Account Credit and are retained by us. Because of this, we have an incentive and conflict of interest when recommending clients purchase advisory annuities. The payments we receive increase as client assets invested in advisory annuities increase. For more information on the marketing support services that we receive from insurance carriers and a list of insurance carriers making such payments to us, please see WFA’s “Guide to buying annuities.” Our “Guide to buying annuities” is available online or by request to your Financial Advisor. Certain insurance companies have also agreed to pay state insurance initial appointment fees and appointment renewal fees on behalf of Wells Fargo & Company’s insurance agencies and Financial Advisors. Appointment fees typically do not exceed $100 per appointment. Account Termination You or we may terminate an Advisory Program Account by notifying the other party in writing of the Advisory Program Account to be terminated and termination will become effective upon the receipt of the notice. Our termination of an Advisory Program Account does not, by itself, constitute a recommendation. If an Advisory Program Account is terminated, we will make a pro-rata refund to you of fees paid to us pursuant to the Agreement for the period after the date of effectiveness of such termination through the end of the then current fee period. The Platform Fee is charged in arrears and will not be refunded. Client Agreements terminated prior to the application date of any Advisory Account Credit will not be entitled to any portion of such credit (nor shall such account be subject to the Platform Fee for such quarter). If you choose to terminate your Agreement with any of our investment advisory Programs, we can liquidate your Account if you instruct us to do so. If so instructed we will liquidate your Account in an orderly and efficient manner. We do not charge for such redemption; however, you should be aware that certain mutual funds impose redemption fees as stated in their fund prospectus. For taxable Accounts, you should also keep in mind that the decision to liquidate security issues or mutual funds will result in tax consequences that should be discussed with your tax advisor. We will not be responsible for market fluctuations in your Account from the time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Factors that affect the orderly and efficient Page 21 of 36 571264 (Rev 57 - 03/26)  liquidation of an Account might be size and types of issues, liquidity of the markets, and market makers' abilities. Should the necessary securities' markets be unavailable and trading suspended, efforts to trade will be done as soon as possible following their reopening. Due to the administrative processing time needed to terminate an advisory Account, termination orders cannot be considered market orders. It could take several business days under normal market conditions to process your request. Upon termination of the Account or transfer of the Advisory Share Class into a WFA retail brokerage account, you authorize us to convert, at our discretion, the Advisory Share Class to the mutual fund's primary share class, typically A shares, without incurring a commission or load without your prior consent. You understand that the primary share class generally has higher operating expenses than the Advisory Share Class, which will negatively affect your performance. Certain mutual fund shares are required to be redeemed as part of the Account termination, as stated in their prospectus. If a Program Account is terminated, but you maintain a brokerage Account with us, the money market fund used in a "sweep" arrangement could be changed and/or your shares exchanged for shares of another series of the same fund. You will bear a proportionate share of the money market fund's fees and expenses. You are subject to the customary brokerage charges for any securities positions sold in your Account after the termination of Program services. Class Action Services Beginning January 2025, all WFA accounts will be automatically enrolled in the Class Action Service also described in the Client Agreement. The Class Action Service authorizes WFA to automatically file a claim on your behalf if WFA receives notice of a class action lawsuit that impacts securities purchased in your Account. The terms of the Class Action Service apply to your Account unless you have opted out. You are not obligated to continue to use the Class Action Service and you may opt out at any time by notifying your Financial Advisor. The Class Action Service is a separate administrative service, is not part of the advisory services included in any Advisory Program and WFA does not act in an advisory capacity when making this service available to you. WFA will not provide legal advice regarding your participation in any class action. Broadridge Investor Communication Solutions, Inc. ("Broadridge") administers the Class Action Service and, in exchange for administering the Class Action Service, Broadridge will retain ten percent (10%) from any class action settlement payment received on your behalf. The remainder of the class action settlement payment will be credited to your Account and will be subject to the fees described in your Client Agreement and the Program Features and Fee Schedule incorporated into your Client Agreement. In cases where WFA elects not to submit a claim for any class action for which you are otherwise entitled to submit a claim, WFA will notify you in writing in advance of the submission deadline and provide you with the individual class action notice so you may submit a claim directly to the claims administrator if you so choose. You are encouraged to carefully review the complete terms and conditions of the Class Action Service, which can be found in the Client Agreement, or to contact us should you have questions. Account Requirements and Types of Clients Account Requirements A minimum initial Account value of at least $50,000 is required to establish a PIM or FC Account. The minimum Account value to establish an Asset Advisor or CustomChoice Account is $25,000. At our discretion, we can choose to waive the minimum Account size. Certain investment options require initial investments greater than the Program minimum Account value. We act as service provider for the advisory Programs offered by our affiliate, Wells Fargo Advisors Financial Network, LLC, as well as for certain fully-disclosed firms that clear their transactions through us. The minimum and maximum Account sizes that these firms require could differ from those required by WFA as stated in this Disclosure Document. Please refer to the Disclosure Document of those firms, as appropriate, to determine their Account requirements. We have the right to terminate Client Accounts with written notice if they fall below minimum Account value guidelines established by the Firm. This change to your account is not a recommendation by WFA. Types of Clients We provide the advisory services described in this brochure to individuals, pension or profit sharing plans, trusts, estates or charitable organizations, corporations or other business entities, governmental entities and educational institutions, as well as banks or thrift institutions. Portfolio Manager Selection and Evaluation As described above in the "Services, Fees and Compensation" section, PIM and FC Financial Advisors serve as Portfolio Managers and are required to meet firm or industry experience levels, plus any required industry examinations and registrations. The PIM and FC Portfolio Managers develop portfolios based on certain established guidelines and your investment objectives and individual needs. The Programs are designed to provide a disciplined advisory approach to meet your objectives and needs. Portfolio Managers that do not continue to meet our guidelines will be removed from the Programs. We classify the mutual funds available in our advisory Programs as either Recommended List or Allowable List rosters of funds. We determine the Recommended List and Allowable List rosters by utilizing due diligence provided by our affiliate, WFII. The processes used by WFII to evaluate the Recommended List and Allowable List Rosters have many common elements, but are different in their application. For the Recommended List, WFII uses both qualitative and quantitative criteria when evaluating and rating these funds. WFII will typically meet with the fund company portfolio managers and research staff to discuss the underlying investment philosophy of the Page 22 of 36 571264 (Rev 57 - 03/26)  fund and how that philosophy is manifested in security buy and sell decisions. The WFII research team also seeks to understand the capabilities of the portfolio manager or team managing the fund to assess how the investment process performed in different market environments. Additional factors influencing the rating of a mutual fund typically includes a statistical analysis of the fund's past performance record and management style; the assessed quality of the investment process; changes in investment process or personnel; the number, continuity, and experience of the investment professionals. WFII maintains due diligence and database information on each of the funds we include on the Recommended List. The due diligence process is a continuing one, and we will add or remove funds from the Recommended List based on WFII’s ongoing assessments. We will remove a mutual fund from the Recommended List based on reasons which include, but are not limited to, the fund’s failure to adhere to expected investment objectives or a given management style, material changes in the professional staff managing the fund, unexplained poor performance, a change of the investment management process, or the identification of a better alternative. WFII will, at their discretion, determine whether any or all of these factors are material when deciding to recommend a replacement for the Recommended List. For the Allowable List, WFII and WFA conduct a review of packaged investment products (mutual funds, exchange traded funds, closed end funds and unit investment trusts) prior to making them available on an Allowable List. This initial review includes a quantitatively-oriented due diligence review of fundamental and performance-based attributes using information from the investment manager and third-party data providers. On a periodic basis, WFII will conduct a quantitatively-oriented review of Allowable List packaged investment products, considering criteria similar to the initial investment review to determine Allowable List eligibility. Certain packaged investment products are not available to all Clients because of Program eligibility, Account types, minimum purchase requirements, geographic availability, fund closures or other factors. WFA and WFII use information, financial data and investment research from a variety of sources to evaluate mutual funds. We believe the information we collect is reliable and accurate, but we make no guarantee to its accuracy or completeness. Mutual Funds Risks and Considerations Significant cash flow impacts & redemption risk. From time to time, one or more of the mutual funds held in a Program Account could experience relatively large cash flows (i.e. investments or redemptions by investors in a mutual fund). Significant cash flows can result from a variety of reasons, such as, research that we make available to our FAs and clients, WFII’s removal of the mutual fund from the Recommended List, model recommendations that we and/or Russell make in the FundSource and Pathways programs and/or investment decisions made by unrelated third-party decision makers that make significant investments in or redemptions from the particular mutual fund held in a Program Account. For certain mutual funds, our advisory clients, in the aggregate, could constitute a majority or full ownership of the mutual fund’s shares. This can increase the chance of significant redemption events when we decide to reduce in full or in part our client’s allocation to the fund. Significant redemptions and investments can adversely affect the mutual funds given the process and time required to sell portfolio securities as a result of redemptions or to invest the cash that results from additional purchases. For shareholders, significant redemptions — whether initiated by us or our FAs or unrelated third-party investors — can result in unexpected capital gains liabilities that are materially higher compared to prior years. In cases of significant redemptions in declining markets or periods of depressed market prices, risks to mutual fund shareholders include: declining share price as portfolio securities are sold into an already declining or depressed market resulting in lower redemption prices for redeeming shareholders and lower share price for our remaining shareholder advisory clients; delayed redemptions during which time fund shareholder capital remains at risk of continued market decline; and the possibility of the mutual fund exercising its right to redeem shares “in-kind” to the shareholder. Representing the interests of our Clients, to the extent possible, we take measures to minimize the adverse impact of such transactions. However, we cannot guarantee that such measures will be effective in any particular circumstance or that losses related to significant investment or redemption decisions can be avoided. With respect to significant cash flows resulting from decisions of unaffiliated third-party investors, we cannot control their actions, nor do we have advance knowledge of such decisions. The same risks and considerations regarding significant cash flows described here generally apply to ETFs as well. Aggregate ownership concentration and management. We monitor the overall aggregate ownership of mutual funds, ETFs, and other registered funds (collectively “registered funds” for purposes of this subsection) controlled by us, our affiliates, and our or our affiliates’ Client Accounts in order to avoid potential restrictions on our ability or the ability of our affiliates to engage in other transactions with specific registered funds. As a result of these aggregate ownership limit levels, from time to time, we may impose limits or restrictions on Client Accounts to invest in particular registered funds. Investment allocations in registered funds are on a “first come, first served” basis, therefore a Client Account could be precluded from investing in a registered fund that may have been previously available and recommended for investment for other Client Accounts prior to having reached our current aggregate ownership limit. Redemptions by third-party investors or tender offers and buy backs by registered funds can increase the percentage ownership held by us, our affiliates and our advisory clients and, as a result we may temporarily preclude investments by us, our affiliates and discretionary account clients until we decide to permit further investment into the registered fund. The forgoing does not apply to self-directed brokerage accounts. Because we include ownership by different entities or business units of ourself and our affiliates in monitoring and managing aggregate ownership levels, these considerations create conflicts of interest for us with respect to availability of investment opportunities for our Client Accounts in registered funds. When we or an affiliate purchase shares of a mutual fund or ETF, there is a corresponding reduction in availability of that registered fund for our discretionary clients. Finally, from time to time, we may determine that certain registered funds will not be subject to the aggregate ownership limits, which increases the risks associated with large ownership positions described in sub-section “Significant Cash Flow Impacts & Redemption Risk,” above. Page 23 of 36 571264 (Rev 57 - 03/26)  Share class conversions. We, at our discretion, undertake share class conversions of mutual funds if an advisory or institutional share class becomes available, as long as the fund company allows the conversion to be processed on a tax-free exchange basis. If there is a retail brokerage share class available, we will convert mutual fund shares back to non-advisory or institutional share class shares if you leave the Program. Certain mutual funds not available to all Clients. Certain mutual funds are not available to all Clients because of Account types, minimum purchase requirements, geographic availability, fund closures or other factors. Cryptocurrency ETF Risks and Considerations Certain available Cryptocurrency Exchange Traded Products (“Cryptocurrency ETFs”) may hold underlying positions in cryptocurrencies such as Bitcoin, Ethereum, or other digital assets (collectively, “Digital Assets”). Cryptocurrency ETFs are exposed to Digital Assets that typically rely on blockchain technology. Digital Assets are not legal tender in the United States and are not required to be accepted as a form of payment. Digital Assets have experienced extreme volatility. Digital Assets can be traded through privately negotiated transactions and through Digital Asset exchanges around the world. The lack of a centralized pricing source poses valuation challenges. Digital Assets are part of a new and evolving industry, and neither the technology nor regulatory regime for Digital Assets is settled. The tax treatment of Digital Assets is uncertain. While Cryptocurrency ETFs are not intended to generate unrelated business taxable income (“UBTI”), this may change. Performance data relating to Digital Assets may not be verifiable, as pricing models are not uniform. Digital Assets can be permanently lost, stolen, destroyed or become inaccessible due to the loss or theft of the private key needed to access the Digital Asset. Certain Digital Asset exchanges have experienced failures or interruptions in service due to fraud, security breaches, operational problems, or business failure. Similar events could occur in the future and impact the value of your investment, regardless of whether the Cryptocurrency ETF relies on the impacted exchange. The performance of a Cryptocurrency ETF may be very dissimilar to the spot price performance of the Digital Asset tracked. Cryptocurrency ETFs are highly speculative and involve a high degree of risk. An investor could lose all or a substantial portion of their investment. Services Tailored to Individual Client Needs All of our investment recommendations for Program Accounts are based on an analysis of your individual financial needs. They are drawn from research and analysis we believe to be reliable and appropriate to your financial circumstances. Each of the advisory services we offer is tailored to a specific type of investor and designed to meet their individual investment objectives, financial needs and tolerance of risk. A detailed description of these Programs is provided in the "Services, Fees and Compensation" section. Client Restrictions and Instructions We will comply with any reasonable instructions and/or restrictions you give us when making recommendations for your Account. Reasonable instructions generally include the designation of particular securities or types of securities that should not be purchased for the Account, or that should be sold if held in the Account. If your restrictions are unreasonable or if we or your Financial Advisor believe that the restrictions are inappropriate, we will notify you that, unless they are modified, we will remove your Account from the Program. You will not be able to provide instructions that prohibit or restrict the investment advisor of an open-end or closed-end mutual fund or exchange-traded funds, with respect to the purchase or sale of specific securities or types of securities within the fund. Upon inception, we generally liquidate your preexisting securities portfolio and bring the Account into conformity with your target allocations. If you wish to hold certain positions for tax or investment purposes, you should consider holding these positions in a separate Account. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees in any of our investment advisory Programs. We do not have any side-by-side management situations. Methods of Analysis, Investment Strategies and Risk of Loss As stated above in the "Services, Fees and Compensation" section, FC Portfolio Managers generally rely on both fundamental and quantitative research to develop their investment management discipline. FC research is obtained from both affiliated and third- party sources. PIM Portfolio Managers utilize both fundamental and quantitative research as well as other independent research. Portfolio Managers develop a specific investment philosophy using the mix of these analysis methods. Quality and concentration requirements are established to provide an overall discipline and quality element to the Program. Such strategies ordinarily include long and short-term purchase of securities and, depending on your objectives and the Portfolio Manager's investment philosophy (if so used), supplemental covered option writing. However, in special circumstances the strategies also include margin transactions, other option strategies and trading or short sale transactions. Risk of Loss All investments shall be at your risk exclusively, and you must understand that we do not guarantee any return on the investments recommended or advised upon and will not be responsible for losses resulting from such trading or for any transactions that we have not recommended to you. Page 24 of 36 571264 (Rev 57 - 03/26)  Voting Client Securities and Corporate Actions Proxy Voting Practices Responsibility for voting the proxies of the securities in your Account depends on the Program in which your Account is enrolled and the type of security held within your Account. In certain Programs identified below, unless you decide to opt out, by the terms of the applicable Program Features and Fee Schedule you authorize proxies for securities in your Account to be voted as described in this section. When authorized on an Account, except as otherwise described below and in the applicable Program Features and Fee Schedule, we typically will vote proxies in accordance with Wells Fargo Wealth & Investment Management’s proxy voting policy (“WIM Proxy Policy”). For all Programs, you may rescind authorization to us and retain such authority for yourself. Your request to rescind will be effective upon our receipt and processing of your written request. Programs in Which WFA is Responsible for Voting Client Securities Unless you opt out, the WIM Proxy Policy will be used to instruct proxy voting for securities (except with respect to securities issued by Funds, as defined below) in Accounts enrolled in the following Programs: Personalized Unified Managed Account (except Accounts enrolled in a Single Manager Strategy managed by an unaffiliated Discretionary Manager, which are discussed below); FundSource; Private Investment Management; Fundamental Choice; and Customized Portfolios. Proxy Committee. Wells Fargo’s Wealth & Investment Management division (“WIM”) has established the WIM Proxy Committee (“Committee”) to ensure that proxies are voted in accordance with established policy and the best long-term economic interest of the Client. The Committee is comprised of members representing the advisory and fiduciary services businesses that make up WIM—WFCS, WFAFN, WFII, Wells Fargo Bank, N.A., and the Wells Fargo Delaware Trust Company, N.A. WIM Proxy Policy. The WIM Proxy Policy provides a set of voting instructions for specific proposal types. The proxy voting team, under the oversight of the Committee, has developed the WIM Proxy Policy in accordance with the general voting principles contained in the Policy Guidelines. The WIM Proxy Policy voting instructions are applied by a third-party Proxy Administrator (described below) to specific proxy proposals for securities in your Account. The WIM Proxy Policy is not applied to proxies related to securities issued by funds registered or regulated under the Investment Company Act of 1940 or Alternative Investments. Proxy Voting Policy, Procedures, and Guidelines. The Policy Guidelines provide an overview of the policies, procedures, and general principles upon which the WIM Proxy Policy is based in seeking to guide consistent voting decisions that are in the best long-term economic interest of Clients, while addressing potential material proxy-related conflicts of interest. The Policy Guidelines provide general voting orientations for a variety of voting topics and proposal types such as those related to boards of directors, compensation, auditors, capitalization, shareholder rights, environmental and social shareholder proposals, strategic transactions, proxy contests, and miscellaneous items. The Committee reviews and approves the Policy Guidelines at least annually and directs updates as warranted based on changes in policy or other considerations. A copy of the Policy Guidelines is available via www.wellsfargo.com/proxyvoting or upon request to your Financial Advisor. Case-by-Case Votes, Exceptions and Overrides. Except with respect to proxy votes involving a material conflict of interest (as discussed below), in certain cases—e.g. unique company circumstances or proposal types—the best interests of our Clients may warrant specific case-by-case reviews, or consideration of voting in exception to or in override of the WIM Proxy Policy. Certain proposal types can also be designated for additional assessment of the broader context or specific factors before a final voting decision is made. Votes made in exception to or in override of either the WIM Proxy Policy or Policy Guidelines are reviewed and affirmed by the Committee. Proxy Administrator. A third-party administrator (“Proxy Administrator”) has been retained to facilitate voting operations and processing. The Proxy Administrator provides various services, including: providing notice of proxy meetings and dates, applying designated proxy voting policies—either our WIM Proxy Policy or third-party voting policies—to specific proposals; preparing proxies for submission; providing access to data pertinent to voting decisions; and third-party research and voting policies. The Committee maintains oversight of the Proxy Administrator through the due diligence conducted by the proxy voting team and can elect to change the administrator at any time. Conflicts of Interest. Wells Fargo offers a broad range of financial services to different client and customer constituencies. This can result in conflicts of interest arising between different parts of the organization and clients served. Although it is not possible to anticipate every potential conflict of interest that could arise, generally such potential occurrences include business or personal relationships of Wells Fargo management, officers, board of directors, or business units that could create a vested interest which could favor voting in ways that benefit Wells Fargo or employees of Wells Fargo rather than voting in the best long-term economic interests of Clients as shareholders in a particular company. In cases where the Committee determines that a material conflict of interest exists with respect to a proxy vote that cannot otherwise be appropriately addressed through application of the WIM Proxy Policy, vote instructions will be provided by an independent firm (“Independent Voting Advisor”) pre-selected by Wells Fargo. The Independent Voting Advisor will also be responsible for providing vote instructions on all proxies related to securities issued by Wells Fargo & Company. The Independent Voting Advisor is subject to change with at least 90-days (calendar days) notice to the Independent Voting Advisor. Information on the current Independent Voting Advisor is available upon request to your Financial Advisor. Directing Individual Proxy Votes. We do not permit Clients to instruct us on how to vote their securities for a particular proxy Page 25 of 36 571264 (Rev 57 - 03/26)  proposal. If you want to ensure that a proxy is voted in a particular manner, you should retain voting authority for yourself in which case you will be responsible for voting all proxies of all securities in your Account. Obtaining Information on Voting. You may obtain information about how your securities were voted by contacting your Financial Advisor. Voting Client Securities Issued by Mutual Funds and Exchange-Traded Funds For regulatory compliance purposes, neither WFA, WIM nor the Committee will provide voting instruction for or influence on the proxies of any securities issued by funds registered and/or regulated under the Investment Company Act of 1940 (including mutual funds, closed-end funds, unit investment trusts and exchange-traded funds) (“Funds”). Therefore, for the proxies of Funds in Accounts enrolled in the Personalized Unified Managed Account (except Accounts enrolled in a Single Manager Strategy managed by an unaffiliated Discretionary Manager), FundSource, Private Investment Management, Fundamental Choice, and Customized Portfolios, proxies will be voted under policies developed by an independent third-party proxy voting advisor (“Independent Fund Voting Policy”). The Independent Fund Voting Policy is selected by the Committee. We will not under any circumstances override or seek to influence the development or application of the Independent Fund Voting Policy. We reserve the right to instruct the Proxy Administrator to replace the Independent Fund Voting Policy if deemed necessary, and with at least 90- days (calendar days) notice to the Proxy Administrator prior to their implementation of the change. You can obtain the current Independent Fund Voting Policies at www.ejproxy.com/methodology and selecting "Wealth-Focused Policy” or by request to your Financial Advisor. Any proxy solicitations related to unit investment trusts will also be handled in the same manner described in this subsection. Personalized UMA Single Strategy Accounts For Accounts enrolled in Personalized UMA Program with a Single Strategy managed by an unaffiliated Discretionary Manager (both terms used as described in the Services, Fee and Compensation section above), your Program Features and Fee Schedule authorizes the Discretionary Manager to vote the securities—including securities issued by Funds—in your Account. In order for the Discretionary Manager to vote the securities in your Account, we will forward proxy materials, annual reports and other issuer- related materials to the Discretionary Manager. The Discretionary Manager will either vote the proxies for the securities in your Account or delegate these responsibilities to a proxy voting service that they have retained. When the Discretionary Manager or their delegate votes (or refrains from voting) proxies, you will not receive proxy materials or annual reports related to the securities that the Discretionary Manager is authorized to vote. The “Voting Client Securities” section of the Discretionary Manager’s Form ADV Part 2A—provided to you upon appointment of the Discretionary Manager to your Account—describes their voting practices, how to obtain their proxy voting policies and procedures, and indicates whether you can direct your vote on a particular solicitation. Neither we nor the Committee review the Discretionary Manager’s voting policies or practices. If the Discretionary Manager for your Account is WFII or WFA, proxies will be voted in accordance with WIM Proxy Policy unless, as described above, the proxies are for securities issued by Funds, Alternative Investments, or issuers for which we have identified a conflict of interest. Rescinding Authority To Vote Securities in Your Account You may rescind authorization to vote proxies from us or any Discretionary Manager at any time by submitting your written request to revoke. Your request will be effective upon our receipt and processing of your written request to rescind. If you rescind such authorization, you will be responsible for voting all proxies for the securities held in your Account. Effect of Non-Program Assets in Accounts Except for Accounts enrolled in the FundSource Program, holding Non-Program Assets in your Account will result in responsibility for voting proxies for all securities in your Account reverting to you until all Non-Program Assets have been removed from the Account and we have received and processed your written authorization for us to resume voting as described above. For Advisory Program Accounts enrolled in the FundSource Program, you are responsible for voting all proxies related to Non-Program Assets. Alternative Investments Held in Program Accounts For securities issued by Alternative Investments in an Account, we will not be responsible for voting the proxies for these securities. Voting the proxies for these securities is your responsibility. You will directly receive information regarding voting for any Alternative Investments, and it is your responsibility to vote. We will not render any advice on your proxy solicitations for these securities. Accounts Subject to ERISA and Internal Revenue Code Section 4975 For Accounts subject to ERISA or Section 4975 of the Internal Revenue Code, the same voting practices described herein will be applied when exercising shareholder rights on securities in such Accounts. You are responsible for reviewing and monitoring our practices and where applicable the WIM Proxy Policy, Independent Voting Advisor and their voting policies, and Independent Fund Voting Policy. If you determine that either the WIM Proxy Policy or those of the Independent Voting Advisor or Independent Fund Voting Policies are not appropriate for your plan based on its investment objectives and investment horizons, you should assume responsibility for exercising shareholder rights by revoking our authority to do so or that of the Discretionary Manager. As described above, the Policy Guidelines direct that all proxies are to be voted in the best long-term economic interests of the client for whom this service is being performed. Page 26 of 36 571264 (Rev 57 - 03/26)  Securities in Portfolios with Nonfinancial Objectives Securities in portfolios with nonfinancial objectives will be voted in the same manner described above, irrespective of the objectives of the strategy. Clients that intend that proxies in these portfolios to be voted in a different manner should retain voting authority for themselves. Programs in Which Authorization and Responsibility to Vote Securities Remains with the Client You are responsible for voting the proxies for the securities in your Account for the following Programs: Asset Advisor; CustomChoice; and Private Advisor Network (unless the Private Advisor Network Manager for your Account has accepted your delegation of authorization to vote). In these Programs we will not have nor accept proxy voting authority for any securities in your Account. If we become aware of a proxy solicitation for a specific security, our responsibility will be limited to forwarding to you any materials or other information regarding the solicitation. We will not render any advice on your proxy solicitations. If your Account is maintained at a custodian other than us—generally in the form of a delivery-versus-payment arrangement— delegation of proxy voting authority to any party cannot be accommodated for any Program. Voluntary Corporate Actions Except as provided below, WFA—not the Committee—will handle any voluntary corporate action or proposal that does not require a proxy (e.g. tender offers, repurchase offers, or corporate reorganizations) for securities in Accounts for which we have discretionary trading authority. However, for corporate actions or proposals related to Funds, we will refrain from responding. For example, in the case of a repurchase offer by a Fund, your shares will not be offered for repurchase. For the Personalized Unified Managed Account and the Private Advisor Network Programs, the Discretionary Manager, Model Manager and Private Advisor Network Manager will instruct us on how to handle any voluntary corporate action or proposal that does not require a proxy (e.g. tender offers, repurchase offers, or corporate reorganizations) including actions for mutual funds and exchange-traded funds subject to their supervision. Therefore, we will forward all information related to corporate actions and reorganizations to the unaffiliated Discretionary Manager or Model Provider (we will not send these notices or copies thereof to you), and act on their instructions. Please note that we might not be able to act if we do not receive the instruction from Discretionary Manager or Model Provider at least 3 calendar days prior to the response deadline. For Private Investment Management and Fundamental Choice Program Accounts, the Financial Advisor serving as your Account’s portfolio manager will handle voluntary corporate actions for securities in your Account. If your Advisory Program Account is enrolled in the Customized Portfolios, Asset Advisor or CustomChoice Programs, you are responsible for instructing us on to how respond to voluntary corporate actions. If your Advisory Program Account is enrolled in the FundSource Program, you are responsible for instructing us on how to respond to all voluntary corporate actions related to Non-Program Assets. Client Information Provided to Portfolio Managers All Clients must provide information on their investment objectives, financial circumstances, risk tolerance and any restrictions they wish to impose on investment activities. We will notify you in writing at least annually to update your information and indicate if there have been any changes in your financial situation, investment objectives or instructions; and you agree to inform us in writing of any material change in your financial circumstances that might affect the manner in which your assets should be invested. Your Financial Advisor will be reasonably available to you for consultation on these matters, and will act on any changes deemed to be material or appropriate as soon as practical after we become aware of the change. Client Contact with Portfolio Managers In the FA Directed Programs, your FA is acting in the capacity of Portfolio Manager. You have no restrictions in contacting your FA. Additional Information Disciplinary Information We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of the broker-dealer, investment advisor or predecessor firms. For more information on broker/dealer related disciplinary events, please visit: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ . Our investment advisory disciplinary history is available by going to: http://www.adviserinfo.sec.gov/. In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. Page 27 of 36 571264 (Rev 57 - 03/26)  In January 2025, WFCS and WFAFN agreed to a settlement with the SEC regarding allegations that they failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to their cash sweep program, specifically, their use of a bank deposit sweep program. The order found that WFCS and WFAFN did not adopt and implement reasonably designed policies and procedures that considered the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; or addressed the duties of WFCS and WFAFN financial advisors in managing client cash in advisory accounts, in willful violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. WFCS and WFAFN, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28 million by WFCS and $7 million by WFAFN. In August 2023, WFCS and WFAFN (collectively, the "Firm") agreed to a settlement with the SEC regarding allegations that from at least 2002 through December 2022, the Firm and its predecessor firms overcharged approximately 10,945 accounts of advisory clients, for accounts opened through 2014, for more than $26.8 million in advisory fees and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the over billing in willful violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells Fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells Fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the Firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected account holders. Without admitting or denying the findings, the Firm consented to a settlement that included a cease and desist order, censure and civil money penalty of $35,000,000. In December 2021, WFCS and WFAFN agreed to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti- money laundering Customer Identification Program (CIP) in the required non-erasable and non-writable "Write Once, Read Many" (WORM) format in violation of Exchange Act Rule 17A-4(F)(2)(II)(A) and failed to notify FINRA prior to using the non-WORM compliant storage platform in violation of Exchange Act rules 17A-4(F)(3)(V) and 17A-4(F)(2)(I). Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine, jointly and severally, of $2,250,000. On August 27, 2020, WFCS agreed to a settlement with FINRA regarding allegations that the Firm failed to reasonably supervise the activities of two former registered representatives, thus violating its own written supervisory procedures along with NASD Rule 3010(a) and FINRA Rules 3110(a) and 2010. Between November 2012 and October 2015, the two representatives recommended that many of their customers invest a substantial portion of their assets in four high-risk energy securities, which generated multiple red flags regarding over concentration and suitability in their customers' accounts that the firm failed to reasonably investigate. The Firm has previously compensated 67 clients over $9.7 million for losses in these investments. Without admitting or denying the findings, the Firm agreed to a settlement that included a censure, a fine of $350,000 and restitution in the amount of $201,498 plus interest to additional specified clients. On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against WFCS and WFAFN, following the Firms' offers of settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds ("ETFs") without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The Commission found that the Firms willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 203(e)(6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained in the Order, to: cease and desist from committing or causing any violations and any future violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; be censured; and jointly and severally pay a civil monetary penalty in the amount of $35,000,000. In 2018, WFCS and WFAFN elected to participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative ("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling $17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms self-reported. In December 2017, Wells Fargo Advisors agreed to a settlement with the State of Illinois Securities Department regarding allegations that it received, reviewed and/or analyzed documents and information from a financial advisory firm concerning certain money manager strategies that contained information that was later found to be false and misleading. The findings stated that we included the financial advisory firm's money manager strategies in certain of our externally managed Separately Managed Account Programs, but that we did not utilize inaccurate historical performance data in connection with our decision to onboard the money Page 28 of 36 571264 (Rev 57 - 03/26)  manager strategies and we did not incorporate inaccurate performance data in our advertisements or Program marketing materials. Without admitting or denying the findings, the Firm agreed to a total monetary payment of $270,000. On December 21, 2016, WFCS and WFAFN agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also found that the Firms failed to implement an audit system for those records, failed to provide its third party vendors full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce written procedures. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,500,000. The Firms also consented to a review of its policies and procedures. On December 5, 2016, WFCS and WFAFN agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through available applications. The findings stated that these applications allowed the Firms' representatives to manually enter information regarding customers' external accounts, assets and liabilities into a centralized table which the Firms maintained. This information would then be used to populate reports, including those that would be sent to the Firms' customers. FINRA found that the Firms did not have systems in place to review the contents of the reports, including information about customer holdings away from the Firms. In addition, the Firms' supervisory systems and procedures were inadequate because there was no mechanism allowing representatives to designate which reports were actually provided to customers and the system could not distinguish between draft reports and completed reports that were sent to customers, which should have been subject to the Firms' supervisory systems designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,000,000. Other Financial Industry Activities and Affiliations We are a national securities firm providing investment and other financial services to individual, corporate and institutional Clients. We are a registered broker-dealer and investment adviser. WFCS is a member of all principal stock exchanges in the United States, including the New York Stock Exchange and NASDAQ. WFCS is also a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). Unless otherwise stated as the case, the investment advisory services offered and the underlying stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not insured or otherwise protected by the Federal Deposit Insurance Corporation (“FDIC”) or another government agency. They are not obligations of any bank or any affiliate of us; are not endorsed or guaranteed by Wells Fargo, WFA, or any bank or any affiliate of us; and involve investment risk including possible loss of principal. Cash balances in Client Accounts may be held in a depository product sponsored by Wells Fargo Bank, N.A. Wells Fargo Clearing Services, LLC is not an FDIC-insured depository institution; FDIC deposit insurance only protects against the failure of an insured depository institution. Banking products and services provided by Wells Fargo Bank, N.A. Member FDIC. Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible for securities we sell or purchase. As a general matter, unless otherwise stated, we do not act as principal or engage in underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to issuers whose securities may be sold to you. From time to time, a bank or thrift affiliated with us lends money to an issuer of securities underwritten or privately placed by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will disclose to the extent required by applicable securities laws: the existence of any material lending relationship by any affiliate of ours with such an issuer; and whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding indebtedness to any of our affiliates. We have a number of related persons who provide investment management and related financial services to certain of our Program Clients. The advisory services these investment advisers offer are described more fully in their Disclosure Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services follows. • Wells Fargo also provides retail brokerage and investment advisory services through WFAFN. • WFII is a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA. WFII also provides research and strategy recommendations to other affiliates of WFA. While all the affiliates have similar access to the research, due to operational differences and manner and size of the advisory programs, certain affiliates could have the ability to implement and trade on these recommendations prior to another affiliate. The ability to implement and trade on these recommendations first gives the clients of one affiliate an advantage over clients of other affiliates. Certain cash sweep vehicles that we offer as part of our Cash Sweep Program may also be used by our affiliates. The rate of return paid when invested in these cash sweep vehicles with our affiliates could be greater than the rate of return paid when invested in these cash sweep vehicles with WFA. Page 29 of 36 571264 (Rev 57 - 03/26)  Material Relationships with Allspring Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners renamed the business Allspring Global Investments. The Wells Fargo Asset Management business was wholly owned by Wells Fargo prior to the transaction and included the following companies: Wells Capital Management Incorporated; Wells Fargo Funds Management, LLC; Wells Fargo Asset Management (International), LLC; Wells Fargo Funds Distributor, LLC; and, Galliard Capital Management, Inc. These companies, which are no longer related persons of WFCS, served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the companies managed separately managed account strategies offered through WFCS. Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings, LLC. This group of companies includes Allspring Funds Management, investment adviser to mutual funds within the Allspring family of funds, Allspring Funds Distributor, LLC, the principal underwriter of Allspring mutual funds, and Allspring Global Investments, LLC, a model portfolio strategy provider and an investment adviser to pooled investment vehicles and separately managed accounts. Wells Fargo has no role in the management of Allspring. However, Wells Fargo retains less than a 10% equity ownership interest in Allspring and has continued to provide certain non-advisory transition services to Allspring for a fee since the close of the sale. WFCS also receives compensation from Allspring for the distribution, administrative and operational services that we provide to the Allspring mutual funds. Although Allspring is not a related person of WFCS, WFCS and its related persons continue to benefit from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a similar financial interest. Wells Fargo’s equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services to Allspring for a fee provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account or model portfolio strategies. WFII charges Allspring research access fees for investment research services that WFII provides to Allspring. Allspring manages the Managed DSIP, Managed DSIP II, ESG Managed DSIP, Current Equity Income, and Income Multi Asset Portfolio strategies offered through WFA’s Personalized Unified Managed Account advisory program (collectively, the “Equity Income Strategies”) utilizing information derived, in part, from certain of the research services. The research access fees are calculated based on the assets invested in the strategies, meaning that WFII earns more money when more assets are invested in the strategies. The research access fees are assessed at rates that result in WFII receiving fees that are equivalent to substantially all of the Manager fees assessed in conjunction with the Income Multi Asset Portfolio, the Current Equity Income Strategy, and the Managed DSIP strategy, and approximately half or greater of the Manager fees assessed for the Managed DSIP II strategy and the ESG Managed DSIP strategy. The fee paid to WFII is for research services WFII provides to Allspring, including: investment research that WFII provides to Allspring; and access to certain WFII research analyst teams, strategists, and associates to discuss the research and/ or obtain additional research commentary on covered names, insights into sectors, etc. (collectively “Research Services”). While WFII does not provide the Research Services to other third-party Managers for utilization in managing strategies, WFII does provide the Research Services to its affiliates, WFCS and WFAFN, who in turn, may utilize the Research Services to manage strategies and who provide the investment research at no cost to WFCS and WFAFN advisory clients, WFCS and WFAFN brokerage customers, and prospective clients and customers for their individual use. As such, investors in the Equity Income Strategies are indirectly paying for investment research that others receive at no cost, and that those same investors could receive from WFCS or WFAFN for their individual use outside of the Equity Income Strategies at no cost under other circumstances. Similar investment research may be available in the marketplace at no cost or for materially lower fees than are being charged to Allspring in conjunction with the Equity Income Strategies. WFII’s receipt of a research access fee in conjunction with the Equity Income Strategies creates a material conflict of interest since it results in WFII, an affiliate of WFCS, earning more revenue when investors follow a WFCS recommendation to invest in the Equity Income Strategies than WFCS, WFII or their affiliates would earn if investors followed a recommendation from WFCS to invest in any of the other Model Manager strategies available through the Personalized UMA Program as WFCS and its affiliates earn no comparable additional revenue for investments in other Model Manager strategies. WFCS seeks to mitigate this conflict and its associated implications through disclosure, management of the financial incentive for financial advisors to recommend the Equity Income Strategies, and evaluation of the total costs of investing in the Equity Income Strategies relative to other Model Manager strategies. You should carefully consider the research access fee that is retained by WFII and our related conflict of interest when evaluating whether to invest in the Equity Income Strategies. The Equity Income Strategies are available through Wells Fargo Bank N.A., including through Wealth & Investment Management Trust Services, and no research access fee is applied to assets invested in the Equity Income Strategies when the assets are custodied at Wells Fargo Bank N.A. The research access fee is also not applied to assets invested in ERISA accounts. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our Associates are subject to a Code of Ethics that is designed to ensure our business activities are performed with the highest possible standards of ethics and business conduct, and to comply with all applicable laws, rules, and regulations that govern our businesses. Key requirements of our Code of Ethics are summarized below: Page 30 of 36 571264 (Rev 57 - 03/26)  • Conduct all aspects of Wells Fargo’s business activities in an honest, ethical, and legal manner, and in accordance with all applicable laws, rules, and regulations and our policies and procedures. • Provide accurate and complete information in dealings with Clients and others, including disclosure of conflicts of interest when they exist. • Prepare and maintain accurate business records. • Refrain from improper disclosure or misuse of confidential Client information and material, non-public information. Wells Fargo protects the private, personal, and proprietary information of Clients and others. • Avoid conflicts of interest in personal and business activities. • Rules specific to personal trading. Participation or Interest in Client Transactions Under the Programs, we are generally appointed as sole and exclusive broker by you with respect to the referenced Account for the execution of transactions. Our Program Fee covers transaction costs when transactions are executed through us. On occasion, Clients designate, or the law requires, the use of other brokers. Investment advisers also elect to execute transactions with other firms as they deem appropriate, taking into account a number of factors such as best execution, research services and other qualitative factors. When transactions are executed with other firms, including transactions executed through our affiliates, the cost of execution is imbedded in the price of the security. Any imbedded execution costs on trades done away from us are in addition to our Program Fee and Platform Fee. In connection with these transactions, we act as agent or, where permitted by law, principal (including instances wherein we are acting as underwriter or selling group members). We effect and execute brokerage transactions, including on a national exchange, as permitted by current provisions of Section 11(a) of the Securities Exchange Act of 1934, as amended (the "Exchange Act") and rules promulgated thereunder including any future amendments or changes to such statutes and rules. In circumstances where permitted by law, when we or our affiliates trade on a principal basis with Clients, we have a financial interest in the transaction since we earn a spread—i.e. the difference between the price we paid for the security versus the price sold to you, or the difference in the price at which we purchase the security from you and subsequently sell to another purchaser— which can result in a profit or potential for profit depending on market circumstances at time of each transaction. We address this conflict through disclosure to you and subject to our broker-dealer obligation to attain best execution for the customer for whom we are executing the transactions. We do not apply a mark-up/mark-down on principal transactions in Advisory Program Accounts. With respect to cash sweep vehicles investments, you receive disclosures about our affiliates and the advisory and other fees paid to affiliates by such cash sweep vehicles. These disclosures are contained in the prospectuses for the money market funds in which you invest and in our Disclosure Documents and Client Agreements, as applicable. Additional information and disclosures are provided below under the section entitled "Cash Sweep Program." We or our affiliates maintain investment banking or other relationships with certain publicly traded companies. From time to time, these relationships require us to restrict trading in the securities of these companies. As a result of these investment banking or other activities, our affiliates acquire confidential or material non-public information that prevents us or our affiliates, for a period of time, from purchasing, selling or recommending particular securities for your Account. We and our affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. Additionally, we may be restricted or limited in our ability to purchase or sell particular securities or make investment recommendations as a result of these affiliated activities. We have certain restrictions, internal procedures and Client disclosures regarding conflicts of interest that we have with respect to our participation or interest in your transactions. We communicate our policies and procedures related to participation in Client transactions to Associates through our compliance policies and procedure manuals and Program-specific policy guidelines. Personal Trading Our Portfolio Managers have the ability to purchase securities for their own accounts that they also purchase for their Clients. We maintain policies and procedures to mitigate conflicts of interest between transactions in our Portfolio Manager's and Associates’ personal investment Accounts, including Accounts of their immediate family members and transactions in our Clients’ Accounts. To ensure Associate trading requirements are observed, certain Associate trading activity is subject to pre-approval. All Associates are subject to regular review by their supervisors, independent oversight by our Compliance Department, and systemic controls that automatically restrict entry of certain orders and generate related surveillance reporting. Review of Accounts Program services include review and monitoring of your Account by our personnel and facilities. We will provide you with an annual report of your portfolio's performance and it will also be available to you on an ad hoc basis. This will include a statistical presentation of the performance of your Account(s), based on the information on our records, and ongoing comparisons with selected industry indices or benchmarks. Normally, the periodic portfolio monitoring report is calculated based on the activity of the Account since its inception in our Program. Page 31 of 36 571264 (Rev 57 - 03/26)  We will transmit the following to you: trade confirmations reflecting all transactions in securities; and at least a quarterly statement of your Account, if there is no activity to warrant a monthly statement. For FA Directed Programs, you have the option to receive periodic statements of Account activity in lieu of transaction-by-transaction confirmations to the extent permitted by Rule 10b-10 under the Exchange Act. When you open a Program Account, your investment objectives and strategy are reviewed for consistency with each Program's guidelines. As applicable, we examine adherence to criteria and Program guidelines on security selections, concentration, diversification, activity and restrictions. Our reviews are performed by the branch office manager, and to the extent applicable, home office personnel, who are assisted by various data processing reports, as the reviews relate to their supervisory and oversight responsibilities, respectively. We review these guidelines periodically and can modify them without notice. Prospectus Delivery With respect to certain of the Advisory Programs through which WFA has investment discretion over the day-to-day management of assets in an Account, WFA is authorized to accept on your behalf delivery of the prospectuses for funds registered under the Investment Company Act of 1940 (including mutual funds, closed-end funds, UIT's and ETFs). More specifically, WFA has authorization to accept delivery of such prospectuses on your behalf with respect to: Accounts that participate in the Private Investment Management Program; and Accounts that participate in the Fundamental Choice Program. If WFA accepts delivery of prospectuses on your behalf, WFA will generally not deliver a prospectus directly to you unless you request one. You may obtain a prospectus at any time by contacting your Financial Advisor. Notwithstanding the authorization described in this paragraph and apart from any requests you may make for prospectuses, WFA may, in its sole discretion, choose to deliver prospectuses directly to you. Client Referrals and Other Compensation From time to time, we initiate incentive programs for our Associates, including FAs. Incentive programs compensate our Associates and FAs for attracting new assets and Clients, referring business to our affiliates (such as referrals for banking services and accounts, mortgages, lending, trusts, or insurance services) or other FAs, promoting investment advisory services and promoting green initiatives (such as raising Client awareness of paperless options). We may also initiate programs that reward Financial Advisors who meet total production criteria, length of service requirements, participate in advanced training and improve Client service. Financial Advisors who participate in these incentive programs may be rewarded with cash and/or non-cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. Portions of these programs may be subsidized by external vendors and/or our affiliates, such as mutual fund companies, insurance carriers, or investment advisers. Therefore, Financial Advisors and other Associates have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services we offer. We also enter into arrangements with other persons to whom we pay compensation for referrals to our advisory Programs. This compensation is generally in the form of a percentage of the fees described in the Program contracts. The details of such arrangements and the amount of compensation will be described in a separate disclosure provided at the time of such referrals. Additionally, we also compensate employees of Wells Fargo Bank, N.A. for referrals to WFA. From time to time, we compensate Associates other than Financial Advisors for referrals of possible Clients to the Programs. Our Financial Advisors, not the referring Associate will make the actual presentation and solicitation of these services. The referral compensation takes the form of a payment to the Associate of a percentage of the fees described in the Programs contracts and results in no additional fees to you or other Clients. Wells Fargo & Company is a full-service financial services firm with many affiliates. Wells Fargo & Company encourages its subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual business planning, business with our affiliates is included in establishing our sales goals. As a result, we have an incentive to hire affiliate service providers for our advisory Programs. We recommend affiliated mutual funds to Program Clients, and hire other affiliates to provide trade execution, clearing, and platform administration services for the Programs. We intend, however, to make all recommendations independent of any such goals and based solely on our obligations to consider your objectives and needs. Brokerage Practices Under the Programs, you will generally appoint us as sole and exclusive broker with respect to the referenced Account for the execution of transactions which we may execute through our affiliate and from which such affiliate will derive benefits, including benefits as a result of increased trading volumes. In connection with these transactions, we act as agent or, where permitted by law, principal (including instances wherein we or an affiliate are an underwriter or selling group member). You authorize us to effect and execute brokerage transactions, including on a national exchange, as permitted by current provisions of Section 11(a) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”) and rules promulgated under that Act, including any future amendments or changes to such statutes and rules. WFA treats equity and options advisory client orders with the same priority and procedural flow, seeking best execution based on available liquidity and prevailing market conditions, as non-advisory brokerage orders, except to accommodate the trading restrictions placed on these Accounts with respect to principal trades and agency cross transactions. Fixed income orders for advisory and brokerage clients are handled similarly; but by separate traders. Traders responsible for execution of fixed income orders for advisory accounts are prohibited from trading with either us or with our affiliate Wells Fargo Securities, LLC—which we treat as principal trades (see further information on principal trading below)—even in cases where one of these entities is offering Page 32 of 36 571264 (Rev 57 - 03/26)  the best bid or offer. For Asset Advisor Accounts that have consented to principal transactions, fixed income order may be filled by us or our affiliate Wells Fargo Securities, LLC, on a principal basis subject in cases where they are offering the best price. When handling multiple orders—including multiple orders in the same security—for advisory clients at the same time, client orders are generally executed in the order in which they are received. This can result in advisory clients receiving different execution prices for orders in the same security entered at or near the same time. We route advisory account orders for listed equity securities and over-the-counter equities on an agency basis to execution venues, including through our affiliate Wells Fargo Securities, LLC (through which a majority of such trades are routed) with best execution being the highest priority. We consider a number of factors when determining where to send Client orders, including execution speed and price, price improvement opportunities, the availability of efficient and reliable order-handling systems, the level of service provided, and the cost of executing orders. We may utilize non-affiliated third party authorized participants (“APs”) when transacting large blocks of ETFs. APs are typically large institutions like market makers or specialists who can create ETFs by trading the underlying securities. For fixed income securities, as a result of the over-the-counter nature of fixed income securities, the available trading methods differ from that of equity securities. Consistent with the overriding principle of best execution and subject to applicable regulatory requirements, we use our discretion in selecting the appropriate alternative trading system (“ATS”) and/or broker-dealers with which to execute your orders. We consider a number of factors when determining where to execute orders, including the product type, the liquidity of the market and the size of the order. With respect to fixed income securities purchased or sold on an ATS, the terms of usage can incentivize us to use the ATS. A certain ATS—on which we generally conduct the vast majority of our ATS trading—provides for trade-related credits paid in cash to us. Credits begin after executing a certain aggregate volume of trades on the ATS during the year and are paid quarterly thereafter. These credits can range from 6% to 19.75% of the aggregate revenue earned by the ATS on the trades that we execute through the ATS. As a result, the potential to earn credits can be an additional factor in determining where we execute fixed income orders. We use unaffiliated smart routers to route option orders to execution venues. We regularly review options transactions each smart router transacts as part of our duty to obtain best execution for our clients. Aggregation of Client Orders. Orders in Accounts may be aggregated (i.e., combined with orders in the same security for other WFA advisory clients) with orders of other WFA advisory clients depending upon several factors, including order size, type of order, the Program in which the Account is enrolled, the discretion of the Manager or Financial Advisor, and our advisory trading operations protocols. In client directed programs—Asset Advisor and CustomChoice Programs—Account orders are not aggregated with orders of other clients in the same security. In the Financial Advisor directed programs—Private Investment Management and Fundamental Choice Programs—orders are entered by the Financial Advisor, and the Financial Advisor is responsible for deciding whether or not to aggregate client orders. For Personalized UMA Program Accounts or portions of the Accounts thereof for which WFA acts as Model Manager, the Firm maintains protocols to systematically aggregate like orders in the same security—even if the orders are for multiple unrelated Models. For Personalized UMA Program Accounts that have selected one or more FA Directed Strategies, WFA serves as Model Manager for these portions of the Account and will aggregate in accordance with the aggregation protocols applicable to the Model trading that WFA performs as the Model Manager. When WFA or the Financial Advisor aggregate client orders, each Account participating in the aggregated order will receive the average per share price for the shares sold or purchased in the order. When an aggregated order receives partial execution rather than full execution, in most cases Accounts will participate on a pro- rata basis. In certain cases, typically due to the size of the order, partial executions will be allocated at the Account level to Accounts selected at random. For remaining Accounts that were not selected for allocation, another order in the security will be placed and partial fills will be again allocated to Accounts selected at random. When your Financial Advisor partners with a Bank PM in the management of a Fundamental Choice Account, the Bank PM will also be managing accounts for clients of Wells Fargo Bank, N.A. Investment management services at WFA and Wells Fargo Bank, N.A. are provided to each institution’s respective clients through separate account management and trading platforms. Orders in Fundamental Choice Accounts managed by a Bank PM will not be aggregated with similar trade orders that the Bank PM makes in Wells Fargo Bank, N.A. accounts. Therefore, transactions in the same security placed by the Bank PM at or close to the same time in each institution’s respective trading system could experience differences in timing of trade and price obtained. We have implemented processes to monitor accounts for equitable treatment by the Bank PM. Financial Advisors offering FA Directed Strategies may implement the same or substantially similar investment strategies in the Personalized UMA Program as well as in the Personalized Investment Management (“PIM”) program or Fundamental Choice (“FC”) program. The trading processes for the FA Directed Strategies in Personalized UMA differ from those utilized in PIM and FC Programs. These trading process differences will result in trade orders in the same or substantially similar strategies at different times as between an FA Directed Strategy and the same or similar strategy in PIM or FC. In conjunction with strategy updates, a Financial Advisor may individually review some or all accounts in the PIM and/or FC programs before executing the orders. An individual review will not occur for an FA Directed Strategy. This will result in differences in the timing of order execution as between an FA Directed Strategy in Personalized UMA and the same or similar strategy in the PIM and FC programs. These program differences will result in Clients in the same or substantially similar strategies in the PIM and FC programs receiving different execution prices and investment results than Clients in an FA Directed Strategy in the Personalized UMA program. For more information on how this may impact your Account, please consult with your Financial Advisor. Trade Errors. If WFA is responsible for a trade processing error, it is WFA’s policy to correct the issue as soon as possible and return the account to the economic position that it would be in absent the error. If correction processing generates a shortfall to the account, we make the account whole by paying the shortfall. If correction processing generates an overage (i.e., an amount in Page 33 of 36 571264 (Rev 57 - 03/26)  excess of what would be in the account if the error did not occur), WFA retains the overage. Mutual Fund Orders. We have policies and procedures in place to ensure that we execute Client orders for the purchase and sale of mutual funds in compliance with the cutoff times established by the mutual fund companies. These times vary, depending on the mutual fund company. At our discretion, we recognize the earliest mutual fund company cutoff time when determining the cutoff time for a particular Client Account. Orders received before the cutoff time will receive that day's closing price, while those after the cutoff time will receive the next day's closing price. If we are unable to obtain a closing price for your order of a mutual fund, we will not execute any trades in that mutual fund for your Account on that day. Directed Brokerage. Clients that instruct that trades in their Advisory Program Account be executed through broker-dealers other than WFA will pay commissions and fees charged by that broker-dealer. These fees are in addition to your Program Fee. Principal Trades and Syndicate Transactions. As a matter of policy, we do not execute principal trades or agency cross transactions in these advisory Programs with the exception of the Asset Advisor Program. In the Asset Advisor Program, principal trades are permitted in Accounts when additional requirements are met. Although in some instances, we are able to provide a more favorable market price to you if we participate in a principal trade or an agency cross transaction with Client Accounts, we do so only when consistent with our obligations to provide best execution, due to regulatory requirements when executing such transactions. Therefore, with the exception of certain Asset Advisor Clients, you will generally not have access to new issues or syndicate offerings in these Accounts. You have the ability to make such purchases in a retail brokerage Account, and you should be aware that they will be subject to the customary fees and commissions charged in such Accounts. In the CustomChoice, Private Investment Management and Fundamental Choice Program we enter principal trades and agency-cross trades on a case-by-case exception basis, in which, as required by law, we will provide specific disclosures and obtain your consent prior to effecting the principal transaction. Conflicts of interest and our financial interests in trades fulfilled as principal are addressed above in “Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.” When you place an indication of interest in a syndicate/new issue transaction (i.e., an initial public offering) or other offering, there are no guarantees that you will receive shares in the offering. WFA, in its sole discretion, determines how to allocate shares to branch locations, Financial Advisors, and Clients. WFA uses an internal formula to rank branch locations and FAs in the allocation process for initial public offering and follow-on offerings. Your Financial Advisor’s rank in the index is based on internal credits or points accumulated during previous qualifying offerings for total production, syndicate production, and the length of your and other Clients’ holding period (up to 90 days) of previous offerings. Whether you receive an allocation of any given offering, and the amount of the allocation is dependent on your Financial Advisor’s rank in the index and the rank of your Financial Advisor’s branch. Financial Advisors with higher rankings in the index generally receive a greater allocation of shares of an oversubscribed offering than Financial Advisors with lower rankings. In addition, when you receive an allocation in an offering, your holding period and the holding period of your Financial Advisor’s other Clients will impact the points accumulated by your Financial Advisor. Specifically, the longer you and your Financial Advisor Clients hold offerings (up to 90 days), the more points they accumulate in the index. As a result, your Financial Advisor’s has an incentive (for up to 90 days after an offering) to recommend that you hold the shares purchased in the offering. For certain offerings, allocating shares via the Financial Advisors index is not necessary due to availability of sufficient shares to satisfy all indications of interest placed by Clients. Fractional Shares. Limitations exist within Client trading systems and the Automated Customer Account Transfer Service (“ACATS”) whereby only whole share positions are traded or transferred. If your advisory Account maintains fractional shares of equity securities, we will accommodate the liquidation by trading them through a Firm principal trading account, while any whole share positions will be liquidated on an agency basis. The price at which the fractional shares sell could, in some instances, differ from the price in which the whole shares trade. Accounts Held at Unaffiliated Custodians and Broker-Dealers In certain cases, clients may choose to custody their Account assets at a financial institution unaffiliated with WFCS. Generally, these custodial arrangements take the form of a delivery-versus-payment account (“DVP Account”) at an unaffiliated institution or as a brokerage account held at an unaffiliated broker-dealer (“Held-Away Account”). A DVP Account allows the client to custody their Account assets at a custodian unaffiliated with WFCS. Even though an unaffiliated custodian maintains the assets in the DVP Account, like other Advisory Program Accounts maintained at WFCS, WFCS executes the securities transactions in the DVP Account. Conversely, for a Held-Away Account, WFCS does not execute the securities transactions in the Held-Away Account. For Held-Away Accounts, the unaffiliated broker-dealer maintains custody of the Account assets and executes securities transactions. Clients should carefully review any specific DVP Account and/or Held-Away Account provisions in their Client Agreement. For both DVP Accounts and Held-Away Accounts, the services provided and conflicts of interest described in this Brochure will differ in the following respects: SIPC Coverage. DVP Accounts and Held-Away Away Accounts are not subject to WFCS’s Securities Investor Protection Corporation (“SIPC”) coverage. Trade Execution, Investment Options & Share Class Selection. For Held-Away Accounts, securities transactions will be carried out by the unaffiliated broker-dealer that the client has selected for the account. This arrangement is considered client directed brokerage. In these arrangements, WFCS plays no role in executing the trade and therefore is not responsible for obtaining best execution (i.e. achieving net transaction costs or proceeds that are most favorable to the client under the circumstances) with respect to these securities transactions. Thus, using a Held-Away Account could result in greater costs; reasons include: Held-Away Accounts will not participate in aggregated trades (i.e. block trades) prepared by WFA—as described in “Brokerage Practices” section; Managers usually cannot engage in trade-away transactions—transactions completed by a broker-dealer other than the broker-dealer carrying the Held-Away Account—which could result in less Page 34 of 36 571264 (Rev 57 - 03/26)  favorable execution on the transaction; The unaffiliated broker-dealer’s product platform could differ from ours and limit or alter our services on the Held-Away Account; Regarding mutual share class selection, an unaffiliated broker-dealer may not offer the same share classes of mutual funds available at WFCS. Therefore, mutual fund share classes in a Held-Away Account could be more or less expensive than the share classes used in an account held at WFCS. With respect to fractional shares, not all broker-dealers offer the ability to buy and sell fractional shares. Payments from Funds and Platform Support Compensation. For DVP and Held-Away Accounts, we do not receive any payments from mutual funds held in these accounts; thus, account credits described in this Brochure do not apply. Regarding Platform Support Compensation described in this Brochure, we do not receive this type of compensation when fund shares are held in DVP or Held-Away Accounts. Custodian/Broker-Dealer Fees. The client is responsible for paying any fees or charges that the unaffiliated custodian or broker-dealer may impose on the DVP or Held-Away Account. These fees and charges are not covered by the Program Fee. Program Fee & Billing. DVP and Held-Away Accounts will be billed at the rate and manner described in this Brochure. It is client’s responsibility to arrange for our ability to directly deduct the Program Fee from a DVP or Held-Away Account. Otherwise, the client will receive an invoice for Program Fees owed. The Program Fee will be based upon account information received from the unaffiliated custodian or broker-dealer. Platform Fees and Advisory Account Credits. These fees do not apply to DVP Accounts or Held-Away Accounts. Proxy Voting. We will not be able to facilitate the delegation of proxy voting or corporate actions. Voting proxies and exercising other shareholder rights for assets held in a DVP or Held-Away Account are the client’s responsibility. Cash Sweeps & Securities-Based Lending Programs. The Cash Sweep Programs, Bank Deposit Sweep Program, Money Market Sweep Funds and Securities-Based Lending Programs described in this Brochure are not available to DVP and Held- Away Accounts. DVP Accounts and Held-Away Accounts will be limited to the programs offered by the unaffiliated custodian or broker-dealer. Non-Program Assets. All assets in your DVP or Held-Away Account will be considered Program Assets and will be assessed the applicable Program Fee. You are responsible for ensuring that Account assets are free of any liens, restrictions or encumbrances in order to allow the Manager to manage the DVP or Held-Away Account. Reports, Account Reviews, Statements and Trade Confirmations. The unaffiliated custodian or broker-dealer will be responsible for providing the client with account statements and trade confirmations. The client must arrange for duplicate delivery to WFCS; otherwise, account reviews and/or performance reporting will differ from the standard practices described in this Brochure. We will rely on information contained in account statements, trade confirmations and other information provided by the unaffiliated custodian or broker-dealer. Transmittal Errors; Trade Errors; Safekeeping of Assets; Financial Condition of Designated Custodian. We are not responsible for any acts or errors committed by an unaffiliated custodian or broker-dealer. While this is not an exhaustive list of all possible types of errors, errors could include mistakes in the transmission of account assets in DVP Accounts; errors in executing trades in Held-Away Accounts; or in the safekeeping of your account assets or personal information. Additionally, we will not assess or monitor the financial condition of an unaffiliated custodian or broker-dealer. Cash Sweep Program Clients provide consent through the general account opening agreement to use our Cash Sweep Program. Through our Cash Sweep Program, you may earn a rate of return on the uninvested cash balances in your Account by automatically placing ("sweeping") cash balances into a sweep program account until such balances are invested in securities or otherwise needed to satisfy obligations arising in connection with your Account. Available cash sweep options, eligibility for which depends on the specific advisory program and account type, currently consist of interest-bearing deposit accounts at affiliated banks (“Affiliated Banks”) in our Bank Deposit Sweep Program, and one or more affiliated and unaffiliated Money Market Mutual Funds ("Money Market Sweep Funds"). The Bank Deposit Sweep Program offers FDIC insurance; money market funds do not. Please refer to the Cash Sweep Program Disclosure Statement for details about the terms and conditions of the Program. Once you sign the general account opening agreement, you will opt into the “default” Cash Sweep option for your respective advisory program and account type. You may elect not to participate in the Cash Sweep Program. If you choose not to participate in the Cash Sweep Program, you will not, except in the case of retirement accounts, earn a rate of return on cash balances prior to direct investment. You may also periodically invest cash balances directly in available money market mutual funds or other products offered as direct investments outside of the Cash Sweep Program, options which will likely generate a higher rate of interest or yield than the Cash Sweep Program. You may invest your cash in other products by providing instructions to your investment professional. Available cash will not be automatically swept into any money market mutual fund or other investment that you purchase outside of the Cash Sweep Program; each such purchase must be requested by you or your financial advisor or manager. As returns in the Cash Sweep Program, your personal financial circumstances, and other factors change, it may be in your financial interest to change your Cash Sweep option (if another option is available for your account type), or to invest cash balances in products offered outside of the Cash Sweep Program, options which likely generate a higher rate of interest or yield. Page 35 of 36 571264 (Rev 57 - 03/26)  Prior to receipt of the general account opening documents, cash deposited in the client's account and not otherwise invested will be held as a free credit balance and not placed in the Cash Sweep Program until written consent is provided to participate in the Cash Sweep Program. While any cash remains in free credit balance, Wells Fargo Advisors will retain any interest earned on assets awaiting investment or disbursement. You understand and agree that this interest (generally referred to as "float") will be retained by us as additional compensation for the provision of services with respect to the account. Except for retirement accounts, while any cash remains in free credit balance, you will not earn any interest on such balance. Bank Deposit Sweep Programs The Bank Deposit Sweep Program consists of interest-bearing accounts at up to two Affiliated Banks. Each Affiliated Bank is a depository institution regulated by bank regulatory agencies under various federal banking laws and regulations. Wells Fargo Advisors will establish and periodically update the interest rate paid on deposits held at the Affiliated Banks, coordinating with the Affiliated Banks to implement any change. Note that these rates of interest are typically lower than money market fund yields. Wells Fargo Advisors benefits financially from cash balances held in the Bank Deposit Sweep Program through payments Wells Fargo Advisors receives from the Affiliated Banks. The Affiliated Banks benefit financially from cash balances held in the Bank Deposit Sweep Programs through the “spread” the Affiliated Banks earn on deposits, as described in more detail below. In addition, the management personnel and certain other employees of Wells Fargo Advisors and its affiliates receive incentive compensation based on a number of factors, including the amount of Wells Fargo Advisors Client Bank Deposit Sweep assets held in Affiliated Banks, and the profitability of Affiliated Banks and their joint parent company, Wells Fargo & Company. Wells Fargo Advisors has a conflict of interest as a result of these benefits because it and its affiliates benefit financially from the Bank Deposit Sweep Programs and Wells Fargo Advisors chooses to include these options as default Cash Sweep options in advisory programs, instead of selecting other cash investment options that would not generate these financial benefits, and that typically pay you higher rates of interest. Moreover, the Affiliated Banks deduct client interest from the payments they make to Wells Fargo Advisors. The higher the rate paid to clients, the lower the amount paid to Wells Fargo Advisors. Therefore, Wells Fargo Advisors has an incentive to maintain lower rates in the Bank Deposit Sweep Program. Spread Earned by Banks As with other depository institutions, the profitability of the Affiliated Banks in the Bank Deposit Sweep Program is determined in large part by the difference or "spread" between the interest they pay on deposit accounts, such as the Bank Deposit Sweep Program, and the interest or other income they earn on loans, investments, and other assets. The banks in the Bank Deposit Sweep Program pay rates of interest on the Bank Deposit Sweep Program deposits that are typically significantly less than the spread banks earn on deposits. The participation of the Affiliated Banks in the Bank Deposit Sweep Programs increases their respective deposits and, accordingly, overall profits. Wells Fargo & Company’s periodic filings include high-level information on deposit spreads and are available at https://www.wellsfargo.com/about/investor-relations/filings/. Bank Payments to Wells Fargo Advisors As noted above, Wells Fargo Advisors receives payments from the Affiliated Banks, which are calculated as a percentage of the client assets deposited in the Cash Sweep Program. The interest paid to client accounts in the Bank Deposit Sweep Program is deducted from these payments, and Wells Fargo Advisors receives the remainder. Accordingly, Wells Fargo Advisors has an incentive to pay lower interest rates to participating client accounts. Note that the fee Wells Fargo Advisors receives from the Affiliated Banks usually exceeds the interest paid to participating client accounts by a substantial amount. Moreover, note that the rates paid out to clients will typically be substantially lower than the Federal Funds Effective Rate, and may not increase as quickly as the Federal Funds Effective Rate. In the Bank Deposit Sweep Program, Wells Fargo Advisors receives from the Affiliated Banks payments in an amount not to exceed a percentage (equivalent to Federal Funds Target plus 30 basis points (0.30%)) of the daily total deposit balances at the Affiliated Banks. Money Market Sweep Funds The Cash Sweep Program includes some money market funds that are managed by third parties. Mutual fund companies typically offer multiple share classes with different levels of fees and expenses. When selecting the share class for the Money Market Fund used in the Cash Sweep Program, we do not necessarily select the share class with the lowest fees that is available from the fund company. The use of a more expensive share class of a Money Market Fund in the Cash Sweep Program will negatively impact your overall investment returns. Additional Information For additional information, see the Cash Sweep Program Disclosure Statement, which we provided to you when you opened your Account. For additional information about the Cash Sweep Program, including information about how we and our affiliates benefit from the Cash Sweep Program, see the Cash Sweep Program. Financial Information We have no financial condition that is likely to impair our ability to meet our contractual commitments to you. Page 36 of 36 571264 (Rev 57 - 03/26) 

Part 2A of Form ADV Firm Brochure for: Institutional Consulting Services 801-37967 Investment Advisory Services of Wells Fargo Advisors Revised March 2026 One North Jefferson, St. Louis, MO 63103 Phone (314) 875-3000 www.wellsfargoadvisors.com This brochure provides information about the qualifications and business practices of Wells Fargo Advisors and our Institutional Consulting Services. This information should be considered before becoming a Client. If you have any questions about these services or the contents of this brochure, please contact us at the telephone number above. This information has not been approved or verified by United States Securities and Exchange Commission or by any state securities authority. Additional Information about Wells Fargo Advisors is also available on the SEC's website at www.adviserinfo.sec.gov . Please note that registration as an investment adviser does not imply a certain level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involve risk, including the possible loss of principal. Investment and Insurance Products are: • Not Insured by the FDIC or Any Federal Government Agency • Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate • Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, Members SIPC, separate registered broker-dealers and non-bank affiliates of Wells Fargo & Company. Page 1 of 17 583598 (Rev 30 - 03/26)  Summary of Material Changes This section describes the material changes to Wells Fargo Clearing Services, LLC's ("WFCS") Part 2A of Form ADV ("Brochure") for the Institutional Consulting Services Program since the annual version of this Brochure dated March 2025. WFCS conducts business under the trade name Wells Fargo Advisors ("WFA"). The summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. Clients are encouraged to read this Brochure in detail and contact their Financial Advisor with any questions. Fees and Compensation section of the document has updated the fee schedule for retirement plan clients. This schedule applies to client engagements starting August 1, 2025. Fees and Compensation section of the document has been updated to add the following information: The fees for our traditional Institutional Consulting Services are negotiable. In certain cases—depending on initial expected program assets and services sought—the annual fee could be greater than the annual fees stated in the section below. Fee rates are fixed and do not change unless both parties agree to a new rate that shall apply to future billing periods. For Retirement Plan Clients receiving services under this Program, Percentage Fee Arrangements and Flat Fee Arrangements entered into prior to August 1, 2025 are subject to different fee ranges. Disciplinary Events sub-section of Additional Information has been updated to include: In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. Fees and Compensation section has added information related to compensation for the financial professionals that service WFA clients. Compensation Related to Our Financial Advisors and Branch Management Financial Advisors. Financial Advisors providing service to Clients from either a WFA branch or an office located in a Wells Fargo Bank, N.A. branch receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Financial Advisors discount certain client fees and commissions, or client relationship asset levels are below minimums established by us. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFA advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor’s expense budget and bonus increase, and the Financial Advisor may qualify for recognition trips. Also, as mentioned above the payout schedule is reduced when certain fees are discounted, thus Financial Advisors are discouraged from providing discounts below certain thresholds when negotiating discounts to commissions for brokerage accounts and Program Fees for Advisor Program Accounts. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial Advisor has an incentive to recommend that you invest account assets in an advisory account which have ongoing Program Fees (discussed above) versus a brokerage account which have transaction-based fees. Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities-Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Solutions Team. Financial Advisors receive compensation for each client referred to the Solutions Team, described in the Personalized Unified Managed Account section above. However the Financial Advisor could provide these same services directly to the Client. As a result of the compensation details provided above, Financial Advisors have a financial incentive to not refer otherwise eligible clients to WFA Solutions due to the greater compensation if the Financial Advisor serves the client directly, as these assets will be attributed to those of the Financial Advisor for compensation pay-out, bonus and recognition purposes. Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Page 2 of 17 583598 (Rev 30 - 03/26)  Financial Advisors are also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include overall company performance, reaching certain production levels, tenure with the Firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices. These incentives—particular ones based on production levels (i.e. revenue and profit generated for the Firm), product mix, asset gathering and referrals to affiliates—result in Financial Advisors being encouraged to recommend courses of action that increase your usage of products and services offered by us and our affiliated companies such as Wells Fargo Bank, N.A. and Wells Fargo Securities, LLC. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following three components: an up-front payment; a deferred compensation component; and a back-end bonus arrangement based on new client assets transitioned/gathered over a three-year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFCS. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFCS. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFCS and WFCS's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of certain titles and/or education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Supervisor Compensation. Branch Managers and Area Managers (who are responsible for supervising Financial Advisors operating from a Wells Fargo Bank, N.A. branch) are compensated based on the total revenue generated by the Financial Advisors subject to their supervision. A portion of the Branch Manager’s and Area Manager’s compensation is also based on the branch meeting business growth targets—such as net asset flows from clients, client usage of lending products, financial advisor recruitment and retention, and client usage of affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.—and branch profitability. Therefore, Branch Managers and Area Managers have an incentive to encourage Financial Advisors to recommend products and services that increase or maximize revenue and profit received for the Firm. When Branch Managers and Area Managers serve as Financial Advisors to brokerage and advisory account clients; the Branch Manager (or Area Manager) is compensated as described above for Financial Advisors. Market Growth Strategy Consultants. Market Growth Strategy Consultants support branch-based Financial Advisors and Branch Managers in the growth of WFA advisory accounts. Market Growth Strategy Consultants are compensated by salary and a bonus based on gross asset flows in Advisory Program Accounts at the branches that they are responsible for supporting and on gross assets referred to the Wells Fargo Bank, N.A. trust services platform. Therefore, the Market Growth Strategy Consultant has a conflict of interest, and is incentivized to emphasize the potential benefits of WFA Advisory Program Accounts and trust and investment management services provided by Wells Fargo Bank, N.A. when providing support to Branch Managers, Financial Advisors, or when joining Financial Advisors in discussions with Clients considering an Advisory Program Account or contributing additional funds to an existing Advisory Program Account. Page 3 of 17 583598 (Rev 30 - 03/26)  Table of Contents Page Summary of Material Changes .......................................................................................................................... 2 Advisory Business ............................................................................................................................................... 5 Firm Description and Ownership ...................................................................................................................... 5 Types of Advisory Services .............................................................................................................................. 5 Institutional Consulting Services ....................................................................................................................... 5 Services Tailored to Individual Client Needs ..................................................................................................... 7 No Portfolio Management Services .................................................................................................................. 7 Assets Under Management .............................................................................................................................. 7 Fees and Compensation ................................................................................................................................... 7 Termination .................................................................................................................................................. 10 Performance-Based Fees and Side-By-Side Management .............................................................................. 10 Types of Clients .............................................................................................................................................. 11 Methods of Analysis, Investment Strategies and Risk of Loss ....................................................................... 11 Disciplinary Information .............................................................................................................................................12 Other Financial Industry Activities and Affiliations ........................................................................................ 13 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................. 15 Brokerage Practices ....................................................................................................................................... 16 Review of Accounts ........................................................................................................................................ 16 Client Referrals and Other Compensation ....................................................................................................... 16 Custody .......................................................................................................................................................... 17 Investment Discretion ..................................................................................................................................... 17 Voting Client Securities .................................................................................................................................. 17 Financial Information ...................................................................................................................................... 17 Page 4 of 17 583598 (Rev 30 - 03/26)  Advisory Business Firm Description and Ownership Wells Fargo Advisors (“WFA”) is a trade name used by Wells Fargo Clearing Services, LLC ("WFCS") and Wells Fargo Advisors Financial Network ("WFAFN"). WFA, whose predecessors span more than 150 years, is a leading national securities firm providing investment and other financial services to individual, corporate, and institutional Clients. It is a non-bank affiliate of Wells Fargo & Company (“Wells Fargo”), a publicly held company (NYSE: WFC), and financial holding company and bank holding company founded in 1852. Wells Fargo and its Affiliates are engaged in a number of financial businesses, including retail brokerage and investment advisory services. WFCS is affiliated with WFAFN, a broker-dealer also providing advisory and brokerage services. Information about the advisory and brokerage services offered by WFAFN is available by contacting them directly. WFA is also affiliated with Wells Fargo Investment Institute, Inc. (“WFII”), a registered investment adviser that provides advisory services and research to WFA. The terms “Client,” “you,” and “your” are used throughout this document to refer to the person(s) or organization(s) who contract with us for the services described herein. “WFA,” “we,” “our,” and “us” refer to WFA together with our Affiliates, including but not limited to, Wells Fargo & Company and its agents with respect to any services provided by those agents. “Affiliate” means any entity that is controlled by, controls or is under common control with WFA. Each Affiliate is a separate legal entity, none of which is responsible for the obligations of the other. Types of Advisory Services We sponsor a number of wrap fee advisory programs ("Wrap Fee Programs") that are designed to help you meet your investment objectives and goals. They include Unified and Separately Managed Account Programs, Mutual Fund Advisory Programs, Financial Advisor-Directed Programs and Non-Discretionary Advisory Programs (“Programs”). We also offer Consulting and Financial Planning advisory services. This Disclosure Document is being provided pursuant to Section 204 of the Investment Advisers Act of 1940 and deals solely with our Institutional Consulting Services Program. Descriptions of the services and fees for the other programs and services we offer can be found in separate disclosure documents, copies of which are available upon request. Institutional Consulting Services Program The Institutional Consulting Services Program is a service in which Financial Advisors (“FAs”) provide a la carte consulting services and/or full retainer consulting services, for a fee, to Clients generally valued at over $10 million in investable assets. This Program allows your FA to provide highly tailored services to select Clients needing customized consulting services. This service is a non-discretionary service which means your FA cannot choose and will not take any actions without your direction. The final decisions are yours. You choose to act upon any or all of the information provided to you. For separate accounts custodied at WFA subject to Institutional Consulting Services Program agreement and concurrently enrolled in a Wrap Fee Program, services related to the Wrap Fee Program are provided under the terms and conditions applicable to the Wrap Fee Program. In the event that the terms of the Institutional Consulting Services contract conflict with the terms of any other brokerage or Wrap Fee Program agreements you have executed with us, the terms of the Institutional Consulting Services contract will govern with respect to the implementation of services covered under the Institutional Consulting Services contract. When services rendered under this program are for the benefit of a retirement plan subject to the Employee Retirement Income Security Act of 1974 ("ERISA"), we are fiduciaries within the meaning of ERISA and/or the Internal Revenue Code, as applicable, when we provide "investment advice," as defined under Title I ERISA. The services to the plan for which we are a fiduciary within the meaning of ERISA are intended to be limited to those investment-related services that constitute investment advice under Section 3(21) of ERISA. The way we make money creates some conflicts with your interests, so when we operate as a fiduciary under ERISA for your plan we operate under a special rule, Prohibited Transaction Exemption 2020-02, that requires us to act in your best interest and not put our interest ahead of yours. To the extent that particular communications to you or services are considered "investment education" or otherwise nonfiduciary under ERISA, we expressly disclaim that we have any fiduciary duties or obligations in connection with such communications or services. The Institutional Consulting Services Program offers one or more of the following services: Investment Policy Statement: Upon your request, we will assist you in preparing an Investment Policy Statement (“IPS”) that identifies the objectives, risk tolerance and constraints for the management of the investments. The development of the IPS will be based on information provided by you and is designed to outline the investment philosophy, and establish the management procedures for use by you and the investment manager(s) for the effective management of the investments. Our IPS services do not include the management of the investments or making specific recommendations regarding specific securities or other investment vehicles. You shall be responsible for review, final approval and adoption of the IPS. If you request ongoing review of the IPS that you have approved and adopted, we will conduct such review of the IPS on an agreed upon reasonable basis. No assurance has been or can be given that the investment objectives reflected in your IPS will be achieved. Asset Allocation Review: Upon your request, we will prepare a strategic asset allocation using statistical measures such as correlation coefficient, standard deviation and covariance to measure risk, and forward-looking capital market assumptions to project return characteristics for various asset classes to identify one or more portfolios of varying risk levels. Our analysis will evaluate these portfolios based on the expected risk and return of each allocation and the desired return for the funds. We will rely Page 5 of 17 583598 (Rev 30 - 03/26)  upon your investment policy statement to identify appropriate asset classes and constraints in our analysis. Upon your request, we will utilize the statistical measures mentioned above to evaluate the current portfolio structure. This analysis will review the current asset allocation against your investment policy statement. Based on our review, we may recommend to you strategic rebalancing of the existing portfolio or the consideration of additional asset classes to assist you in achieving your investment goals. The formulation of an asset allocation strategy will be based on information provided by you. You shall be solely responsible for determining whether the information taken into account in formulating an Asset Allocation Review is accurate. Our asset allocation services do not involve the management of your assets or the making of recommendations regarding specific securities or other investment vehicles. Investment Manager Search and Recommendation: Upon your request, we will provide an Investment Manager Search Report to you. This report will provide you with a list of investment managers whose investment philosophies and policies are, in our judgment, compatible with your investment objectives, policies and constraints and risk tolerance, as provided to us by you. We shall identify such investment managers from a universe of investment managers that is maintained by our affiliate, Wells Fargo Investment Institute, Inc, a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA, based on their qualitative and quantitative due diligence process. The decision to invest with or retain any particular manager, or offer any investment manager to participants as an investment option is made by you. In this regard, we do not assume responsibility for your decision to invest with or make available any particular manager or for the manager’s investment decisions, performance, or compliance with applicable laws or regulations, or for other matters within the control of the manager. You understand that the investment options that we will consider for recommendation to you will be limited to the investment options on your selected custodian's platform. With respect to our investment manager search and recommendation, we cannot guarantee that the investment manager we recommend will ultimately agree to serve as an investment manager to you. You also understand that we will not recommend, and make no representations concerning any manager chosen by you without or contrary to our recommendation, nor shall we assume any liability for any loss, claim, damage or expense attributable to your selection of any manager that has not been recommended by us. Further, an investment manager’s past performance is not necessarily indicative of future performance. We will only include non- affiliated managers in our search, but at your or your Financial Advisor’s request will include affiliated managers, and notify you regarding the affiliation, accordingly. Investment Manager Due Diligence: Upon your request, we will monitor the investment manager to ensure policy compliance within established guidelines; analysis of portfolio style characteristics, performance, and investment process and philosophy may additionally be offered. We will not be held liable for misinformation provided to us. Investment Fund Search and Recommendation: Upon your request, we will provide an Investment Fund Search Report designed to provide you with a list of investment funds, including mutual funds and/or collective investment funds, whose investment philosophies and policies are, in our judgment, compatible with your investment objectives, policies and constraints, as specified by you. The decision to invest in any particular investment fund rests with you. In this regard, we do not assume responsibility for your decision to invest in any particular investment fund, nor are we responsible for the investment fund's investment decisions, performance, or compliance with applicable laws or regulations, or for other matters within the control of the investment fund. An investment fund's past performance is not necessarily indicative of future performance. Performance Reporting: Upon your request, we will provide periodic Performance Reports to assist you in evaluating the investment manager(s) (options include separate account managers mutual funds, money market, fixed income, or group annuity contracts) and in your monitoring the performance of your portfolio over various time periods, as well as comparing various aspects of such performance to benchmarks identified in the IPS. The investment managers will be analyzed based on their risk level and performance as they relate to the investment and diversification objectives, policies, constraints, and risk tolerance, as specified in the IPS and/or you. These reports may include a combination of market commentary; plan asset allocation summary; risk and return analysis; attribution; investment research; and overall review for comparison to the IPS. Account data will be derived from custodial statements or data flows for each period. We will not be responsible for verification of the information supplied by the custodian. While we are not responsible for and will not separately monitor the investments for your plan, we will provide you with Performance Reports on an agreed upon periodic basis so that you can monitor such investments. We also do not assume responsibility for the investment manager’s performance or compliance with applicable laws or regulations, or for other matters within the control of those who manage or control the investment option you select. Further, an investment manager’s past performance is not necessarily indicative of future performance. Past Performance Review: Upon your request, we will provide a Past Performance Review evaluating the historical performance of your portfolio for a mutually agreed upon time period and comparing various aspects of such performance to mutually agreed upon benchmarks. Account data will be derived from custodian statements or other sources for the agreed upon time period. We will not be responsible for verification of the information supplied by the custodian. Additional Services for Employee Benefit Plans: Upon your request, we will provide general consulting services for plans including 401(k) and other retirement plans. General consultation will be offered on a plan sponsor level only; participant level consultation is not provided under the program contract. Diversification Review: For certain qualified plans, upon your request we will provide a diversification review designed to identify particular asset classes that we feel should be included in the plan’s list of investments options made available to the participants Page 6 of 17 583598 (Rev 30 - 03/26)  based on the investment policy statement provided by you. Based on our review, we may recommend to you additional asset classes to complement the plan’s existing investment options. The Diversification Review will be based on information provided by you. You shall be solely responsible for determining whether the information taken into account in formulating a Diversification Review is accurate. Our Diversification Review service does not involve the management of your assets or the making of recommendations regarding specific securities or other investment vehicles. Service Provider Search and Review: Upon your request, we will request retirement plan proposals from a group of record keeping platforms based on stated goals, objectives and demographics of the plan, and subsequently prepare a report to summarize the results. The summary report is designed to provide comparison of the features, benefits, available investment options and fees of a specific recordkeeper product that can be analyzed in comparison to the stated criteria. This search and review process will be performed on an as-needed basis for the employer’s fiduciary due diligence file or upon request to provide the employer information needed in making informed decisions on a product solution. Plan Committee Meetings: Upon your request, we will provide summary reports and statistical updates to the plan committee. These may include: participation level and demographic reports; a review of goals and results of the education policy statement; updates on participant meetings, regulatory updates and market updates. Plan Fees and Services Benchmarking: Upon your request, we will provide plan benchmarking reports that identify and compare specific plan-design elements such as: plan features; investment-related information; participant behaviors, plan oversight as well as plan-related fees with other plans in similar industries; plan size and/or demographics. The benchmarking report will be comprehensive and include all elements or a summary of specific items and fees. These reports will be prepared on an as-needed basis or as part of the overall annual review. Participant Education: Upon your request, we will provide investment education to and for the benefit of participants in your plan(s) which are subject to ERISA. The parties agree that the education services are not intended to include personal investment advice and are limited to providing Investment Education as described in Department of Labor ("DOL") Interpretive Bulletin 96-1, 29 C.F.R. Section 2510.3-21 or any successor DOL regulations describing the scope of non-fiduciary participant education. Other Services: Other services provided to you by us will be assessed on an individual basis. These services would include special, one-time or ongoing services that are more complex and unique than those listed above. Prior to delivery of the services, appropriate supervisors will approve such services. Services Tailored to Individual Client Needs Each of the advisory services we offer is tailored to you and designed to meet your individual investment objectives, financial needs and tolerance of risk. They are drawn from research and analysis we believe to be reliable and appropriate to your financial circumstances. No Portfolio Management Services We do not act as a portfolio manager for the services provided under the Institutional Consulting Services Program. We act as portfolio manager for certain Wrap Fee Programs that we offer to Clients separate from this Program and collect a fee for performing that service. Assets Under Management As of December 31, 2025, we manage $478,834,872,430 of Client assets on a discretionary basis and $192,586,970,269 of Client assets on a non-discretionary basis. Fees and Compensation The fee for our Institutional Consulting Services Program services and other terms of the Client Agreement are negotiable. Fees paid by Clients who have selected the same payment option will vary, depending on several factors. Those factors include, among other things, the size and type of the Account, the relative complexity of servicing the Account, and/or the level of customization. Under this Program, you will incur trade execution costs separately. “Fixed Fee” Arrangements Under a “Fixed Fee” arrangement, you agree to pay us (1) one or more agreed-upon amounts on one or more agreed-upon dates. Fees payable for “Fixed Fee” arrangements cover only the consulting services provided by us and do not cover any securities transactions or custodian fees, nor does the fee cover the investment management fees for investment advisers retained by you. “Percentage Fee” Arrangements Under a “Percentage Fee” arrangement, you agree to pay us a quarterly fee, covering all charges for consulting services provided by us under the Client Agreement. Each pro rata quarterly fee will be payable in advance or arrears for the period for which services are to be rendered. The initial fee will be based on the value of the Account as of the commencement date of the Client Page 7 of 17 583598 (Rev 30 - 03/26)  Agreement. Subsequent fees will be based on the value of the Account as of the prior quarter’s ending value. Fees payable under “Percentage Fee” arrangements cover the consulting services provided by us and, as specified in the agreement, will not cover any securities transactions or custodian fees, nor does the fee cover the investment management fees for investment advisers retained by you. The fees for our Institutional Consulting Services are negotiable. In certain cases—depending on initial expected program assets and services sought—the annual fee could be greater than the annual fees stated in the section below. Fee rates are fixed and do not change unless both parties agree to a new rate that shall apply to future billing periods. For Retirement Plan Clients receiving services under this Program, Percentage Fee Arrangements and Flat Fee Arrangements entered into prior to August 1, 2025 are subject to different fee ranges. Non-Retirement Plan Clients Percentage Fee Arrangements Annual Fee Range Ongoing Consulting Service (Clients with $10 million or more in program assets) Negotiable Negotiable Ongoing Consulting Service (Clients with less than $10 million in program assets) Flat Fee Arrangements Fee Range Ongoing Consulting Service Negotiable Other Negotiable Retirement Plan Clients – Percentage Fee Arrangements Plan Size AUM Annual Minimum Fee Annual Maximum Fee Under $1 million 0.10% 1.00% $1 – 5 million 0.10% 0.70% $5 – 10 million 0.10% 0.50% $10+ million 0.01% 0.25% Retirement Plan Clients – Flat Fee Arrangements Plan Size AUM Annual Minimum Fee Annual Maximum Fee Under $1 million $500 $10,000 $1 – 5 million $1,000 $30,000 $5 – 10 million $3,500 $40,000 $10+ million $5,000 $100,000 In addition, clients may select any of the services listed below and the fees for those services are negotiable. The table below represents a typical fee range for each service: Page 8 of 17 583598 (Rev 30 - 03/26)  Flat Fee Arrangements (One-Time Service Request) Fee Range Investment Policy Statement $1,500 - $4,000 Asset Allocation Review $3,000 - $10,000 Investment Manager Search $3,000 - $10,000 Mutual Fund Search $1,500 - $3,000 Investment Adviser Due Diligence $2,000 - $5,000/yr per mgr Performance Monitoring Report (InvestorForce) $2,000 (per mgr w/min $10,000/yr) Performance Monitoring Report (Zephyr) $4,000 (per mgr w/min $20,000/yr) Past Performance Review $5,000 - $10,000 Diversification Review $3,000 - $10,000 Service Provider Search and Review $3,000 - $55,000 Plan Committee Meetings $2,000 - $4,000 Plan Fees and Service Benchmarking Participant Education $1,000 - $25,000 By the day ($2,000 - $4,000), By the seminar ($500 - $2,000), By the employee ($10 - $75), or a fee based on a percentage of plan assets; additionally, costs for travel, incidental expenses and materials incurred during the provision of Participant Education Services will be charged separately. Frequency and Method of Payment Fees for one-time services are payable immediately after services are provided. Fees for ongoing services are assessed quarterly in advance or in arrears. Clients may choose to pay fees by invoice to client or the custodian; or authorize us to directly deduct our fee from a designated account. Compensation Related to Our Financial Advisors and Branch Management Financial Advisors. Financial Advisors providing service to Clients from either a WFA branch or an office located in a Wells Fargo Bank, N.A. branch receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Financial Advisors discount certain client fees and commissions, or client relationship asset levels are below minimums established by us. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFA advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor’s expense budget and bonus increase, and the Financial Advisor may qualify for recognition trips. Also, as mentioned above the payout schedule is reduced when certain fees are discounted, thus Financial Advisors are discouraged from providing discounts below certain thresholds when negotiating discounts to commissions for brokerage accounts and Program Fees for Advisor Program Accounts. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial Advisor has an incentive to recommend that you invest account assets in an advisory account which have ongoing Program Fees (discussed above) versus a brokerage account which have transaction- based fees. Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities-Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Solutions Team. Financial Advisors receive compensation for each client referred to the Solutions Team, described in the Personalized Unified Managed Account section above. However the Financial Advisor could provide these same services directly to the Client. As a result of the compensation details provided above, Financial Advisors have a financial incentive to not refer otherwise eligible clients to WFA Solutions due to the greater compensation if the Financial Advisor serves the client directly, as these assets will be attributed to those of the Financial Advisor for compensation pay-out, bonus and recognition purposes. Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Page 9 of 17 583598 (Rev 30 - 03/26)  Financial Advisors are also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include overall company performance, reaching certain production levels, tenure with the Firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices. These incentives—particular ones based on production levels (i.e. revenue and profit generated for the Firm), product mix, asset gathering and referrals to affiliates—result in Financial Advisors being encouraged to recommend courses of action that increase your usage of products and services offered by us and our affiliated companies such as Wells Fargo Bank, N.A. and Wells Fargo Securities, LLC. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following three components: an up-front payment; a deferred compensation component; and a back-end bonus arrangement based on new client assets transitioned/gathered over a three-year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFCS. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFCS. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFCS and WFCS's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of certain titles and/or education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Supervisor Compensation. Branch Managers and Area Managers (who are responsible for supervising Financial Advisors operating from a Wells Fargo Bank, N.A. branch) are compensated based on the total revenue generated by the Financial Advisors subject to their supervision. A portion of the Branch Manager’s and Area Manager’s compensation is also based on the branch meeting business growth targets—such as net asset flows from clients, client usage of lending products, financial advisor recruitment and retention, and client usage of affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.—and branch profitability. Therefore, Branch Managers and Area Managers have an incentive to encourage Financial Advisors to recommend products and services that increase or maximize revenue and profit received for the Firm. When Branch Managers and Area Managers serve as Financial Advisors to brokerage and advisory account clients; the Branch Manager (or Area Manager) is compensated as described above for Financial Advisors. Market Growth Strategy Consultants. Market Growth Strategy Consultants support branch-based Financial Advisors and Branch Managers in the growth of WFA advisory accounts. Market Growth Strategy Consultants are compensated by salary and a bonus based on gross asset flows in Advisory Program Accounts at the branches that they are responsible for supporting and on gross assets referred to the Wells Fargo Bank, N.A. trust services platform. Therefore, the Market Growth Strategy Consultant has a conflict of interest, and is incentivized to emphasize the potential benefits of WFA Advisory Program Accounts and trust and investment management services provided by Wells Fargo Bank, N.A. when providing support to Branch Managers, Financial Advisors, or when joining Financial Advisors in discussions with Clients considering an Advisory Program Account or contributing additional funds to an existing Advisory Program Account. Termination In the event the Client Agreement is terminated, you shall have no obligation to make additional payments that would otherwise be required to be made, but we may submit to you an accounting of the services theretofore provided to you (which may include an accounting of our preparations to provide services that would have been provided by us but for such termination) and you shall be liable to us for the amount set forth thereon (which amount will not exceed the total amount of our compensation as agreed to by you and us in the Client Agreement) (the “Termination Obligation”). In the event you have paid any payments prior to such termination: if the amount of such payments exceeds the Termination Obligation, you shall be entitled to a refund of such excess, and we shall be entitled to retain the remainder in full satisfaction of the Termination Obligation; and if the Termination Obligation exceeds the amount of such payments, and you shall promptly pay the amount of such excess in order to satisfy the Termination Obligation. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees in any of our investment advisory programs. We do not have any side-by-side management situations. Page 10 of 17 583598 (Rev 30 - 03/26)  Types of Clients We provide the services described in this brochure to individuals, pension or profit-sharing plans, trusts, estates or charitable organizations, corporations or other business entities, governmental entities and educational institutions, as well as banks or thrift institutions. Methods of Analysis, Investment Strategies and Risk of Loss Under our Institutional Consulting Services Program, our recommendations may vary based on the scope of the services for which we are engaged to advise upon. Our consulting services are provided to many types of institutional clients such as individuals, corporations, endowments, foundations and retirement plans, both those subject to ERISA and not subject to ERISA. For retirement plans subject to ERISA, we will carry out our duties and responsibilities in accordance with ERISA as it applies to the services we are rendering. To the extent not contrary to ERISA, we will take into consideration the goals and objectives as provided and/or communicated by the plan. If in our view, any investment instruction, guideline or requirement received from a plan fiduciary is inconsistent with or contrary to ERISA, we will disregard such provision or instruction when carrying out our duties and will act in accordance with our responsibilities under ERISA and the regulations promulgated thereunder. Retirement Plan Clients For the purposes of our non-discretionary Investment Fund Search and Recommendation services to retirement plans subject to ERISA, if the plan does not provide written investment instructions or objectives such as an IPS, we will focus on identifying a menu of diversified investment options, each with differing risk and return characteristics appropriate for a plan participant or beneficiary. The investment options we recommend could include active and passive investment vehicles, as well as target-date investment options. When we are hired to provide Investment Manager Search and Recommendation services for plans subject to ERISA, we seek to identify and recommend one (or more when appropriate) investment managers to manage a plan’s assets— either in their entirety or a portion thereof. In doing so, we will recommend investment manager(s) that we believe are capable of carrying out their responsibilities in compliance with ERISA, while adding value on a risk-adjusted basis. When reviewing potential investment managers, we take into consideration the overall stated objectives of the assets which will vary based on: plan type; and whether the investment manager’s mandate will be limited to a specific asset class or investment category within a broader pool of assets. If the retirement plan is not subject to ERISA and we are hired to provide Investment Fund Search and Recommendation services —we will recommend a specified number of investment funds for the plan to consider making available to plan participants. We will recommend a diversified set of investment funds—ranging from conservative to aggressive growth investment choices—which could include active and passive investment vehicles in our recommendations, as well as target-date investment options. When we are hired to provide Investment Manager Search and Recommendation services for plans not subject to ERISA, we seek to identify and recommend one (or more when appropriate) investment managers to manage a plan’s assets—either in their entirety or a portion thereof. In doing so, we will recommend investment manager(s) that we believe are capable of adding value on a risk- adjusted basis. When reviewing potential investment managers, we take into consideration the overall stated objectives of the assets which will vary based on: plan type; and whether the investment manager’s mandate will be limited to a specific asset class or investment category within a broader pool of assets. Methods of Analysis In performing the investment advisory services, our analyses and recommendations are based on modern portfolio theory and other general diversification philosophies. WFA makes available to its financial advisers: reports and analyses on investment products and asset managers from WFA’s affiliate investment adviser Wells Fargo Investment Institute, Inc. (Wells Fargo Investment Institute, Inc. is an investment adviser registered with the Securities and Exchange Commission. It is a subsidiary of Wells Fargo Bank, N.A. Registration as an investment adviser does not imply a certain level of skill or training. Wells Fargo Investment Institute, Inc. and Wells Fargo Bank, N.A. are subject to the control of Wells Fargo & Company (NYSE: WFC), a financial holding company.); and third-party databases, analytics tools and presentation tools. These resources are used individually or in combination in both initial investment product and investment manager selection. When evaluating and recommending investment options or investment managers to manage the plan’s assets, WFA generally considers the following (List includes common relevant considerations but is not intended to be exhaustive; nor will all be necessarily relevant to a particular plan’s needs.): • General principles of diversification of assets and modern portfolio theory • Legal and regulatory considerations • Plan imposed restrictions • Time horizons • Need for current income • Investment objectives • Management fees • Shareholder fees • Asset class • Performance Page 11 of 17 583598 (Rev 30 - 03/26)  Investing carries risk of loss. Separately managed accounts managed by investment managers, mutual funds and exchange-traded funds, and individual securities are all subject to risk of loss. With respect to an investment manager that we may recommend to a plan, each manager will have investor materials addressing the risks associated with the particular manager’s strategies. Investment Strategies When we provide Investment Manager Search and Recommendation services, we do not provide personalized investment advice to plan participants. When we provide Investment Manager Search and Recommendation Services, information regarding the investment strategies (generally investment risks, investment methods of analysis, and types of securities used) offered by the investment manager that we recommend to the plan will be contained in each manager’s Form ADV Part 2A, or similar document, and other informational materials of the manager. Risk of Loss All investments shall be at your risk exclusively, and you must understand that we do not guarantee any return on the investments recommended or advised upon and will not be responsible for losses resulting from such trading or for any transactions that we have not recommended to you. Disciplinary Information We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of the broker-dealer, investment advisor or predecessor firms. For more information on broker-dealer related disciplinary events you may visit: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/. Our investment advisory disciplinary history is available by going to: http://www.adviserinfo.sec.gov/. In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. In January 2025, WFCS and WFAFN agreed to a settlement with the SEC regarding allegations that they failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to their cash sweep program, specifically, their use of a bank deposit sweep program. The order found that WFCS and WFAFN did not adopt and implement reasonably designed policies and procedures that considered the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; or addressed the duties of WFCS and WFAFN financial advisors in managing client cash in advisory accounts, in willful violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. WFCS and WFAFN, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28 million by WFCS and $7 million by WFAFN. In August 2023, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC (collectively, the "Firm") agreed to a settlement with the SEC regarding allegations that from at least 2002 through December 2022, the Firm and its predecessor firms overcharged approximately 10,945 accounts of advisory clients, for accounts opened through 2014, for more than $26.8 million in advisory fees and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the over billing in willful violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells Fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells Fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the Firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected account holders. Without admitting or denying the findings, the Firm consented to a settlement that included a cease and desist order, censure and civil money penalty of $35,000,000. In December 2021, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti-money laundering Customer Identification Program (CIP) in the required non-erasable and non-writable “Write Once, Read Many” (WORM) format in violation of Exchange Act Rule 17A-4(F)(2) (II)(A) and failed to notify FINRA prior to using the non-WORM compliant storage platform in violation of Exchange Act rules 17A-4(F)(3)(V) and 17A-4(F)(2)(I). Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine, jointly and severally, of $2,250,000. On August 27, 2020, Wells Fargo Clearing Services, LLC agreed to a settlement with FINRA regarding allegations that the Firm failed to reasonably supervise the activities of two former registered representatives, thus violating its own written supervisory Page 12 of 17 583598 (Rev 30 - 03/26)  procedures along with NASD Rule 3010(a) and FINRA Rules 3110(a) and 2010. Between November 2012 and October 2015, the two representatives recommended that many of their customers invest a substantial portion of their assets in four high-risk energy securities, which generated multiple red flags regarding over concentration and suitability in their customers' accounts that the firm failed to reasonably investigate. The Firm has previously compensated 67 clients over $9.7 million for losses in these investments. Without admitting or denying the findings, the Firm agreed to a settlement that included a censure, a fine of $350,000 and restitution in the amount of $201,498 plus interest to additional specified clients. On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, following the Firms' offers of settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds ("ETFs") without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The Commission found that the Firms willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 203(e)(6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained in the Order, to: cease and desist from committing or causing any violations and any future violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; be censured; and jointly and severally pay a civil monetary penalty in the amount of $35,000,000. In 2018, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC elected to participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative ("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling $17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms self-reported. In December 2017, Wells Fargo Advisors agreed to a settlement with the State of Illinois Securities Department regarding allegations that it received, reviewed and/or analyzed documents and information from a financial advisory firm concerning certain money manager strategies that contained information that was later found to be false and misleading. The findings stated that we included the financial advisory firm’s money manager strategies in certain of our externally managed Separately Managed Account Programs, but that we did not utilize inaccurate historical performance data in connection with our decision to onboard the money manager strategies and we did not incorporate inaccurate performance data in our advertisements or Program marketing materials. Without admitting or denying the findings, the Firm agreed to a total monetary payment of $270,000. On December 21, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also found that the Firms failed to implement an audit system for those records, failed to provide its third party vendors full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce written procedures. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,500,000. The Firms also consented to a review of its policies and procedures. On December 5, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through available applications. The findings stated that these applications allowed the Firms’ representatives to manually enter information regarding customers’ external accounts, assets and liabilities into a centralized table which the Firms maintained. This information would then be used to populate reports, including those that would be sent to the Firms’ customers. FINRA found that the Firms did not have systems in place to review the contents of the reports, including information about customer holdings away from the Firms. In addition, the Firms’ supervisory systems and procedures were inadequate because there was no mechanism allowing representatives to designate which reports were actually provided to customers and the system could not distinguish between draft reports and completed reports that were sent to customers, which should have been subject to the Firms’ supervisory systems designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,000,000. Other Financial Industry Activities and Affiliations We are a national securities firm providing qualified custodial, investment, and other financial services to individual, corporate and institutional Clients. We are a registered broker-dealer and investment adviser. Page 13 of 17 583598 (Rev 30 - 03/26)  WFCS is a member of all principal stock exchanges in the United States, including the New York Stock Exchange and NASDAQ. WFCS is also a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). We may also route transactions through our affiliate, Wells Fargo Securities, LLC. Unless otherwise stated as the case, the investment advisory services offered and the underlying stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not insured or otherwise protected by the Federal Deposit Insurance Corporation (“FDIC”) or another government agency. They are not obligations of any bank or any affiliate of us; are not endorsed or guaranteed by Wells Fargo, WFA, or any bank or any affiliate of WFA; and involve investment risk including possible loss of principal. Cash balances in Client Accounts may be held in a depository product sponsored by Wells Fargo Bank, N.A. Wells Fargo Clearing Services, LLC is not an FDIC-insured depository institution; FDIC deposit insurance only protects against the failure of an insured depository institution. Banking products and services provided by Wells Fargo Bank, N.A. Member FDIC. Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible for securities we sell or purchase. As a general matter, unless otherwise stated, we may be a principal or engaged in underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to issuers whose securities may be sold to you. From time to time, a bank or thrift affiliated with us may lend money to an issuer of securities underwritten or privately placed by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will disclose to the extent required by applicable securities laws: the existence of any material lending relationship by any affiliate of ours with such an issuer; and whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding indebtedness to any of our affiliates. We have a number of related persons who may provide investment management and related financial services to our Clients. The advisory services these investment advisers offer are described more fully in their Disclosure Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services follows. • Wells Fargo also provides retail brokerage and investment advisory services through Wells Fargo Advisors Financial Network, LLC ("WFAFN"). • Wells Fargo Investment Institute, Inc. ("WFII") (known prior to November 1, 2014 as Alternative Strategies Group, Inc. and before that as Wachovia Alternatives Strategies, Inc.) is a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA. We and our affiliates may give advice and take action in the performance of our duties to you that differ from advice given, or the timing and nature of action taken, with respect to other Institutional Consulting Services Program Clients and/or Clients in other advisory Programs. Additionally, we and our affiliates, from time to time, may not be free to divulge or act upon certain information in our possession on behalf of investment banking or other Clients. Material Relationships with Allspring Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners renamed the business Allspring Global Investments. The Wells Fargo Asset Management business was wholly owned by Wells Fargo prior to the transaction and included the following companies: Wells Capital Management Incorporated; Wells Fargo Funds Management, LLC; Wells Fargo Asset Management (International), LLC; Wells Fargo Funds Distributor, LLC; and, Galliard Capital Management, Inc. These companies, which are no longer related persons of WFCS, served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the companies managed separately managed account strategies offered through WFCS. Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings, LLC. This group of companies includes Allspring Funds Management, investment adviser to mutual funds within the Allspring family of funds, Allspring Funds Distributor, LLC, the principal underwriter of Allspring mutual funds, and Allspring Global Investments, LLC, a model portfolio strategy provider and an investment adviser to pooled investment vehicles and separately managed accounts. Wells Fargo has no role in the management of Allspring. However, Wells Fargo retains less than a 10% equity ownership interest in Allspring and has continued to provide certain non-advisory transition services to Allspring for a fee since the close of the sale. WFCS also receives compensation from Allspring for the distribution, administrative and operational services that we provide to the Allspring mutual funds. Although Allspring is not a related person of WFCS, WFCS and its related persons continue to benefit from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a similar financial interest. Wells Fargo’s equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services to Allspring for a fee provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account or model portfolio strategies. WFII charges Allspring research access fees for investment research services that WFII provides to Allspring. Allspring manages the Managed DSIP, Managed DSIP II, ESG Managed DSIP, Current Equity Income, and Income Multi Asset Portfolio strategies offered through WFA’s Personalized Unified Managed Account advisory program (collectively, the “Equity Income Strategies”) utilizing information derived, in part, from certain of the research services. The research access fees are calculated based on the Page 14 of 17 583598 (Rev 30 - 03/26)  assets invested in the strategies, meaning that WFII earns more money when more assets are invested in the strategies. The research access fees are assessed at rates that result in WFII receiving fees that are equivalent to substantially all of the Manager fees assessed in conjunction with the Income Multi Asset Portfolio, the Current Equity Income Strategy, and the Managed DSIP strategy, and approximately half or greater of the Manager fees assessed for the Managed DSIP II strategy and the ESG Managed DSIP strategy. The fee paid to WFII is for research services WFII provides to Allspring, including: investment research that WFII provides to Allspring; and access to certain WFII research analyst teams, strategists, and associates to discuss the research and/ or obtain additional research commentary on covered names, insights into sectors, etc. (collectively “Research Services”). While WFII does not provide the Research Services to other third-party Managers for utilization in managing strategies, WFII does provide the Research Services to its affiliates, WFCS and WFAFN, who in turn, may utilize the Research Services to manage strategies and who provide the investment research at no cost to WFCS and WFAFN advisory clients, WFCS and WFAFN brokerage customers, and prospective clients and customers for their individual use. As such, investors in the Equity Income Strategies are indirectly paying for investment research that others receive at no cost, and that those same investors could receive from WFCS or WFAFN for their individual use outside of the Equity Income Strategies at no cost under other circumstances. Similar investment research may be available in the marketplace at no cost or for materially lower fees than are being charged to Allspring in conjunction with the Equity Income Strategies. WFII’s receipt of a research access fee in conjunction with the Equity Income Strategies creates a material conflict of interest since it results in WFII, an affiliate of WFCS, earning more revenue when investors follow a WFCS recommendation to invest in the Equity Income Strategies than WFCS, WFII or their affiliates would earn if investors followed a recommendation from WFCS to invest in any of the other Model Manager strategies available through the Personalized UMA Program as WFCS and its affiliates earn no comparable additional revenue for investments in other Model Manager strategies. WFCS seeks to mitigate this conflict and its associated implications through disclosure, management of the financial incentive for financial advisors to recommend the Equity Income Strategies, and evaluation of the total costs of investing in the Equity Income Strategies relative to other Model Manager strategies. You should carefully consider the research access fee that is retained by WFII and our related conflict of interest when evaluating whether to invest in the Equity Income Strategies. The Equity Income Strategies are available through Wells Fargo Bank, N.A., including through Wealth & Investment Management Trust Services, and no research access fee is applied to assets invested in the Equity Income Strategies when the assets are custodied at Wells Fargo Bank, N.A. The research access fee is also not applied to assets invested in ERISA accounts. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our Associates are subject to a Code of Ethics that is designed to ensure our business activities are performed with the highest possible standards of ethics and business conduct, and to comply with all applicable laws, rules, and regulations that govern our businesses. Key requirements of our Code of Ethics are summarized below; you may obtain a complete copy through your Financial Advisor. • Conduct all aspects of Wells Fargo’s business activities in an honest, ethical, and legal manner, and in accordance with all applicable laws, rules, and regulations and our policies and procedures. • Provide accurate and complete information in dealings with Clients and others, including disclosure of conflicts of interest when they exist. • Prepare and maintain accurate business records. • Refrain from improper disclosure or misuse of confidential Client information and material, non-public information. Wells Fargo protects the private, personal, and proprietary information of Clients and others. • Avoid conflicts of interest in personal and business activities. • Rules specific to personal trading. Participation or Interest in Client Transactions Under our advisory programs, we are generally appointed as sole and exclusive broker by you with respect to the referenced Account for the execution of transactions. Our Wrap Fee Program Fee covers transaction costs when transactions are executed through us. On occasion, you may designate, or the law may require, the use of other brokers. Investment advisers may also elect to execute transactions with other firms as they deem appropriate, taking into account a number of factors such as best execution, research services and other qualitative factors. When transactions are executed with other firms, including transactions executed through our affiliates, the cost of execution is imbedded in the price of the security. Any imbedded execution costs on trades done away from us are in addition to our Program Fee. In connection with these transactions, we may act as agent or, where permitted by law, principal (including instances wherein we are acting as underwriter or selling group members). You authorize that we may effect and execute brokerage transactions, including on a national exchange, as permitted by current provisions of Section 11(a) of the Securities Exchange Act of 1934, as amended (the “Exchange Act”) and rules promulgated thereunder including any future amendments or changes to such statutes and rules. Page 15 of 17 583598 (Rev 30 - 03/26)  With respect to cash sweep vehicles investments, you receive disclosures about our affiliates and the advisory and other fees paid to affiliates by the Funds in the Fund’s prospectuses and our Disclosure Documents, and Client Agreements, as applicable. We or our affiliates may have investment banking or other relationships with certain publicly traded companies. These relationships may from time to time require us to restrict trading in the securities of these companies. As a result of these investment banking or other activities, our affiliates may acquire confidential or material non-public information that may prevent us or our affiliates, for a period of time, from purchasing, selling or recommending particular securities for your Account. We and our affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. Additionally, we may be restricted or limited in our ability to purchase or sell particular securities or make investment recommendations as a result of these affiliated activities. We have certain restrictions, internal procedures and Client disclosures regarding conflicts of interest that we may have with respect to our participation or interest in Client transactions. We communicate our policies and procedures related to participation in Client transactions to our Associates through our compliance policies and procedure manuals and Program-specific policy guidelines. Personal Trading We maintain policies and procedures to mitigate conflicts of interest between transactions in our Associates’ personal investment Accounts, including Accounts of their immediate family members, and transactions in our Clients’ Accounts. To ensure associate trading requirements are observed, certain Associate trading activity is subject to pre-approval. All Associates are subject to regular review by their supervisors, independent oversight by our Compliance Department, and systemic controls that automatically restrict entry of certain orders and generate related surveillance reporting. Brokerage Practices We do not provide any brokerage services as part of this Program. Review of Accounts The FA provides the services agreed to in the contract. Client Referrals and Other Compensation From time to time, we initiate incentive programs for our Associates, including FAs. Incentive programs compensate our Associates and FAs for attracting new assets and Clients, referring business to our affiliates (such as referrals for banking services and accounts, mortgages, lending, trusts, or insurance services) or other FAs, promoting investment advisory services and promoting green initiatives (such as raising Client awareness of paperless options). We may also initiate programs that reward Financial Advisors who meet total production criteria, length of service requirements, participate in advanced training and improve Client service. Financial Advisors who participate in these incentive programs may be rewarded with cash and/or non-cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. Portions of these programs may be subsidized by external vendors and/or our affiliates, such as mutual fund companies, insurance carriers, or investment advisers. Therefore, Financial Advisors and other Associates have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services we offer. We may also enter into arrangements with other persons to whom we pay compensation for referrals to our advisory Programs. This compensation is generally in the form of a percentage of the fees described in the Program contracts. The details of such arrangements and the amount of compensation will be described in a separate disclosure provided at the time of such referrals. Additionally, we also compensate employees of Wells Fargo Bank, N.A. for referrals to WFA. From time to time, we compensate Associates other than Financial Advisors for referrals of possible Clients to the Programs. Our Financial Advisors, not the referring Associate will make the actual presentation and solicitation of these services. The referral compensation takes the form of a payment to the Associate of a percentage of the fees described in the Programs contracts and results in no additional fees to you or other Clients. Wells Fargo & Company is a full-service financial services firm with many affiliates. Wells Fargo & Company encourages its subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual business planning, business with our affiliates is included in establishing our sales goals. As a result, we may have an incentive to hire affiliate service providers for our advisory programs. We may recommend affiliated mutual funds to our Clients, and may hire other affiliates to provide trade execution, clearing, and platform administration services for our programs. We intend, however, to make all recommendations independent of any such goals and based solely on our obligations to consider your objectives and needs. Page 16 of 17 583598 (Rev 30 - 03/26)  Custody You are allowed to choose your qualified custodian. While this Program generally expects Client assets to be held-away, in certain circumstances, you may choose Wells Fargo Clearing Services, LLC to act as the qualified custodian for your assets. You will receive quarterly, or more frequent, Account statements directly from whichever qualified custodian that you choose. You should carefully review these statements for accuracy. Investment Discretion We do not have discretion for any of the services described in this brochure. Voting Client Securities We do not accept authority to vote Client securities as part of our Institutional Consulting Services Program. Financial Information We have no financial condition that is likely to impair our ability to meet our contractual commitments to you. Page 17 of 17 583598 (Rev 30 - 03/26) 

Part 2A of Form ADV Firm Brochure for: Retirement Plan Consulting 801-37967 Investment Advisory Services of Wells Fargo Advisors Revised March 2026 One North Jefferson, St. Louis, MO 63103 Phone (314) 875-3000 www.wellsfargoadvisors.com This brochure provides information about the qualifications and business practices of Wells Fargo Advisors and our Retirement Plan Consulting Program. This information should be considered before becoming a Client. If you have any questions about these services or the contents of this brochure, please contact us at the telephone number above. This information has not been approved or verified by United States Securities and Exchange Commission or by any state securities authority. Additional information about Wells Fargo Advisors is also available on the SEC's website at www.adviserinfo.sec.gov. Please note that registration as an investment adviser does not imply a certain level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involve risk, including the possible loss of principal. Investment and Insurance Products are: • Not Insured by the FDIC or Any Federal Government Agency • Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate • Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, Members SIPC, separate registered broker-dealers and non-bank affiliates of Wells Fargo & Company. 589132 (Rev 30 - 03/26) Page 1 of 15  Summary of Material Changes This section describes the material changes to Wells Fargo Clearing Services, LLC’s (“WFCS”) Part 2A of Form ADV (“Brochure”) for the Retirement Plan Consulting Program since the annual version of this Brochure dated March 2025. WFCS conducts business under the trade name Wells Fargo Advisors (“WFA”). The summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. Clients are encouraged to read this Brochure in detail and contact their Financial Advisor with any questions. Disciplinary Events sub-section of Additional Information has been updated to include: In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. Discretionary Services—Investment Search and Selection has been updated to include the following: You also agree that we will not determine for you or recommend to you what type of investment option to use as a Qualified Default Investment Alternative (“QDIA”) as this term is defined under ERISA, or what types of investment options qualify as a QDIA under ERISA. Notwithstanding the foregoing, when we provide Plan Level Investment Selection 3(38) services, we will have discretion to remove and replace any investment option, including the QDIA, if applicable. Fees and Compensation section has added information related to compensation for the financial professionals that service WFA clients. Compensation Related to Our Financial Advisors and Branch Management Financial Advisors. Financial Advisors providing service to Clients from either a WFA branch or an office located in a Wells Fargo Bank, N.A. branch receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Financial Advisors discount certain client fees and commissions, or client relationship asset levels are below minimums established by us. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFA advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor’s expense budget and bonus increase, and the Financial Advisor may qualify for recognition trips. Also, as mentioned above the payout schedule is reduced when certain fees are discounted, thus Financial Advisors are discouraged from providing discounts below certain thresholds when negotiating discounts to commissions for brokerage accounts and Program Fees for Advisor Program Accounts. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial Advisor has an incentive to recommend that you invest account assets in an advisory account which have ongoing Program Fees (discussed above) versus a brokerage account which have transaction-based fees. Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities-Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Solutions Team. Financial Advisors receive compensation for each client referred to the Solutions Team, described in the Personalized Unified Managed Account section above. However the Financial Advisor could provide these same services directly to the Client. As a result of the compensation details provided above, Financial Advisors have a financial incentive to not refer otherwise eligible clients to WFA Solutions due to the greater compensation if the Financial Advisor serves the client directly, as these assets will be attributed to those of the Financial Advisor for compensation pay-out, bonus and recognition purposes. Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Financial Advisors are also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include overall company performance, reaching certain production levels, tenure with the Firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices. These incentives—particular ones based on production levels (i.e. revenue and profit generated for the Firm), product mix, asset gathering and referrals to affiliates—result in Financial Advisors being encouraged to recommend courses of action that increase your usage of products and services offered by us and our affiliated companies such as Wells Fargo Bank, N.A. and Wells Fargo Securities, LLC. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. 589132 (Rev 30 - 03/26) Page 2 of 15  Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following three components: an up-front payment; a deferred compensation component; and a back-end bonus arrangement based on new client assets transitioned/gathered over a three- year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFCS. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFCS. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFCS and WFCS's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of certain titles and/or education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Supervisor Compensation. Branch Managers and Area Managers (who are responsible for supervising Financial Advisors operating from a Wells Fargo Bank, N.A. branch) are compensated based on the total revenue generated by the Financial Advisors subject to their supervision. A portion of the Branch Manager’s and Area Manager’s compensation is also based on the branch meeting business growth targets—such as net asset flows from clients, client usage of lending products, financial advisor recruitment and retention, and client usage of affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.—and branch profitability. Therefore, Branch Managers and Area Managers have an incentive to encourage Financial Advisors to recommend products and services that increase or maximize revenue and profit received for the Firm. When Branch Managers and Area Managers serve as Financial Advisors to brokerage and advisory account clients, the Branch Manager (or Area Manager) is compensated as described above for Financial Advisors. Market Growth Strategy Consultants. Market Growth Strategy Consultants support branch-based Financial Advisors and Branch Managers in the growth of WFA advisory accounts. Market Growth Strategy Consultants are compensated by salary and a bonus based on gross asset flows in Advisory Program Accounts at the branches that they are responsible for supporting and on gross assets referred to the Wells Fargo Bank, N.A. trust services platform. Therefore, the Market Growth Strategy Consultant has a conflict of interest, and is incentivized to emphasize the potential benefits of WFA Advisory Program Accounts and trust and investment management services provided by Wells Fargo Bank, N.A. when providing support to Branch Managers, Financial Advisors, or when joining Financial Advisors in discussions with Clients considering an Advisory Program Account or contributing additional funds to an existing Advisory Program Account. 589132 (Rev 30 - 03/26) Page 3 of 15  Table of Contents Page 2 Summary of Material Changes ..................................................................................................................... 5 Advisory Business ................................................................................................................................................ Firm Description and Ownership .......................................................................................................................... 5 Types of Advisory Services ................................................................................................................................... 5 Retirement Plan Consulting .................................................................................................................................. 5 Non-Discretionary Services .................................................................................................................................... 5 Discretionary Services ............................................................................................................................................ 6 Services Tailored to Individual Client Needs ......................................................................................................... 7 No Portfolio Management Services ...................................................................................................................... 7 Assets Under Management .................................................................................................................................. 7 7 Fees and Compensation ....................................................................................................................................... Performance-Based Fees and Side-By-Side Management ................................................................................. 9 Types of Clients ..................................................................................................................................................... 9 9 Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... Disciplinary Information ........................................................................................................................................ 10 Other Financial Industry Activities and Affiliations ............................................................................................ 12 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................. 13 Brokerage Practices .............................................................................................................................................. 14 Review of Accounts ............................................................................................................................................... 14 Client Referrals and Other Compensation ........................................................................................................... 14 Custody ................................................................................................................................................................... 14 Investment Discretion ............................................................................................................................................ 14 Voting Client Securities ......................................................................................................................................... 15 Financial Information ............................................................................................................................................ 15 589132 (Rev 30 - 03/26) Page 4 of 15  Advisory Business Firm Description and Ownership Wells Fargo Advisors ("WFA") is a trade name used by Wells Fargo Clearing Services, LLC ("WFCS") and Wells Fargo Advisors Financial Network ("WFAFN"). WFA, whose predecessors span more than 150 years, is a leading national securities firm providing investment and other financial services to individual, corporate, and institutional Clients. It is a non-bank affiliate of Wells Fargo & Company ("Wells Fargo"), a publicly held company (NYSE: WFC), and financial holding company and bank holding company founded in 1852. Wells Fargo and its Affiliates are engaged in a number of financial businesses, including retail brokerage and investment advisory services. WFCS is affiliated with WFAFN, a broker-dealer also providing advisory and brokerage services. Information about the advisory and brokerage services offered by WFAFN is available by contacting them directly. WFA is also affiliated with Wells Fargo Investment Institute, Inc. ("WFII"), a registered investment adviser that provides advisory services and research to WFA. The terms "Client," "you," and "your" are used throughout this document to refer to the person(s) or organization(s) who contract with us for the services described here. "WFA," "WFCS," "we," "our," and "us" refer to WFA together with our Affiliates, including but not limited to, Wells Fargo & Company and its agents with respect to any services provided by those agents. "Affiliate" means any entity that is controlled by, controls or is under common control with WFA. Each Affiliate is a separate legal entity, none of which is responsible for the obligations of the other. Types of Advisory Services We sponsor a number of wrap fee advisory programs ("Wrap Fee Programs") that are designed to help Clients meet their investment objectives and goals. They include Unified and Separately Managed Account Programs, Mutual Fund Advisory Programs, Financial Advisor-Directed Programs and Non-Discretionary Advisory Programs ("Programs"). We also offer Consulting and Financial Planning advisory services. This Disclosure Document is being provided pursuant to Section 204 of the Investment Advisers Act of 1940 and deals solely with our Retirement Plan Consulting Program. Descriptions of the services and fees for the other programs and services we offer can be found in separate disclosure documents, copies of which are available upon request. Retirement Plan Consulting The Retirement Plan Consulting Program is a service in which Financial Advisors ("FAs") provide consulting services to retirement plans for a fee. We offer both non-discretionary and discretionary services. For non-discretionary services, your FA cannot choose and will not take any actions without your direction. The final decisions are yours. You may choose to act upon any or all of the information provided to you. FAs are required to meet additional Firm established criteria to be eligible to offer discretionary services. For discretionary service, your FA has the authority to create and maintain the plan's investment menu on your behalf and without your approval. We are fiduciaries within the meaning of ERISA and/or the Internal Revenue Code, as applicable, when we provide "investment advice," as defined under Title I ERISA, to you regarding your plan. The services to the plan for which we are a fiduciary are intended to be limited to those investment-related services that constitute investment advice under Section 3(21) of ERISA. The way we make money creates some conflicts with your interests, so when we operate as a fiduciary for your plan we operate under a special rule, Prohibited Transaction Exemption 2020-02, that requires us to act in your best interest and not put our interest ahead of yours. To the extent that particular communications to you or services are considered "investment education" or otherwise nonfiduciary under ERISA, we expressly disclaim that we have any fiduciary duties or obligations in connection with such communications or Services. The Retirement Plan Consulting Program offers one or more of the following services: Non-Discretionary Services Investment Policy Statement: Upon your request, we will assist you in preparing an Investment Policy Statement ("IPS") that identifies the objectives, risk tolerance and constraints for the management of the investments. The development of the IPS will be based on information provided by you and is designed to outline the investment philosophy, and establish the management procedures for use by you and the investment manager(s) for the effective management of the investments. Periodically, in the future, we will review the IPS with you on an agreed upon basis. Our IPS services do not include any recommendations as to the management of the plan's investments or specific recommendations regarding specific securities or other investment vehicles, unless you specifically and separately select investment search and recommendation. You shall be responsible for review, final approval and adoption of the IPS. No assurance has been or can be given that the investment objectives reflected in your IPS will be achieved. Investment Search and Recommendation: Upon your request, we will provide an Investment Search Report (options may include money market, collective investment trusts, mutual funds or group annuity contracts) to you. In this report, we will provide you with investments or investment managers for consideration whose investment philosophies and policies are, in our judgment, compatible with your plan. While WFA will recommend an investment option or option(s) and investment managers, as appropriate, the decision to invest with or retain any particular manager or investment, or offer any investment to participants as an investment option is made by you. You understand that the investment options that we will consider for recommendation to the plan will be limited to the investment options on the plan's custodian's platform. With respect to our investment manager search and recommendation, we cannot guarantee that the investment manager we recommend will ultimately agree to serve as an investment manager to your plan. You also understand that we make no representations concerning any investment option or manager chosen by you without or contrary to our recommendation, nor shall we assume any liability for any loss, claim, damage or expense attributable to your selection of any manager that has not been profiled, reviewed or recommended by us. 589132 (Rev 30 - 03/26) Page 5 of 15  Further, an investment manager's or an investment's past performance is not necessarily indicative of future performance. If requested by you, we will also provide a diversification review designed to identify particular asset classes that we feel should be included in the plan's list of investments options made available to the participants based on the plan's IPS. Based on our review, we may recommend to you additional asset classes to complement the plan's existing investment options. Performance Reporting: Upon your request, on an agreed upon basis, we will provide periodic Performance Reports to assist you in evaluating your plan's designated investment options (options may include money market, collective investment trusts, mutual funds or group annuity contracts) and the performance of the plan’s portfolio over various time periods, as well as comparing various aspects of such performance to benchmarks identified in the IPS. The investments will be analyzed based on their investment philosophies, policies, risk level, and performance as they relate to the investment and diversification objectives, policies, constraints, and risk tolerance, as specified in the IPS and/or you. These reports may include a combination of market commentary; plan asset allocation summary; risk and return analysis; investment cost analysis; investment research; and overall review for comparison to the IPS. Account data will be derived from trust or custodial statements for each period. We will not be responsible for verification of the information supplied by the custodian or trustee. While we are not responsible for and will not separately monitor the investments in your plan, we will provide you with Performance Reports on an agreed upon periodic basis so that you can monitor such investments. We also do not assume responsibility for your decision to invest with or make available any particular manager or for the manager's investment decisions, performance, or compliance with applicable laws or regulations, or for other matters within the control of the manager. Service Provider Search: Upon your request, we will request retirement plan proposals from a group of record keeping platforms based on stated goals, objectives and demographics of the plan, and subsequently prepare a report to summarize the results. The summary report is designed to provide comparison of the features, benefits, available investment options and fees of a specific recordkeeper product that can be analyzed in comparison to the stated criteria. This search process may be performed on an as- needed basis for your fiduciary due diligence or upon request to provide you information to support your decisions on product solution decisions. Plan Benchmarking: Upon your request, we will provide plan benchmarking reports that identify and compare specific plan-design elements such as: plan features; investment-related information; participant behaviors, plan oversight as well as plan-related fees with other plans in similar industries, or with similar plan size and/or demographics. The benchmarking report may be comprehensive and include all elements or a summary of specific items and fees. These reports will be prepared on an as-needed basis or as part of the overall annual review. Employee Education: Upon your request, we will provide investment education to and for the benefit of employees of your company. The parties agree that the education services are not intended to include personal investment advice and are limited to providing Investment Education or general information as described in Department of Labor ("DOL") Interpretive Bulletin 96-1, 29 C.F.R. Section 2510.3-21 or any successor DOL regulations describing the scope of non-fiduciary participant education. Plan Fiduciary Meeting Support: Upon your request, we will attend plan fiduciary meetings to deliver various non-discretionary services. We will provide general summary reports and statistical updates to the plan committee(s) or other fiduciaries. These may include: participation and demographic reports; a review of goals and results of the education policy statement; updates on participant meetings, regulatory updates and market updates. Unless you specifically and separately select investment services, our plan meeting support will not include investment search and recommendation. Discretionary Services Plan Level Investment Selection 3(38): When we perform discretionary plan level Investment Search and Selection and/or Performance Reporting services hereunder, we are an "investment manager" as such terms are defined in Section 3(38) of the Employee Retirement Income Security Act of 1974 ("Investment Manager"), as amended and the regulations promulgated thereunder ("ERISA") and acknowledge our fiduciary status as such. Investment Search and Selection: We will review the investment options available to you and provide you with advice regarding Designated Investment Alternatives (“DIAs”) based on your Investment Policy Statement. Plans with existing assets will be mapped and moved into the DIAs, which will include both the asset movement of current balances and the future investment elections of each participant in the plan. Once our initial investment advice has been implemented, we will monitor the DIAs and will instruct your recordkeeper directly to remove and replace investments that no longer meet the IPS criteria. We will communicate any changes to you reasonably in advance of a proposed change. You understand that the investment options that we will consider for selection for the plan will be limited to the investment options on the plan's custodian's platform. You understand and agree that declining our investment advice or investment decisions may cause the termination of our services to you. DIAs may include money market mutual funds, collective investment trusts, mutual funds or group annuity contracts. We will not be responsible for selection or monitoring, and will not make any advice or make decisions to retain or remove, employer stock, guaranteed investment contracts, participant loans, or investment options beyond the DIAs (i.e., investments in self-directed brokerage windows, managed accounts, and other investments that we may restrict from time to time). You also agree that we will not determine for you or recommend to you what type of investment option to use as a Qualified Default Investment Alternative ("QDIA") as this term is defined under ERISA, or what types of investment options qualify as a QDIA under ERISA. Notwithstanding the foregoing, when we provide Plan Level Investment Selection 3(38) services, we will have discretion to remove and replace any investment option, including the QDIA, if applicable. Although we will not have discretion over the following, if mutually agreed upon, we may provide investment advice recommendations on the following: stable value funds, and guaranteed investment contracts. 589132 (Rev 30 - 03/26) Page 6 of 15  Performance Reporting: On an agreed upon basis, but no less frequently than annually, we will provide periodic Performance Reports to assist you in evaluating your plan’s DIAs and the performance of the plan’s portfolio over various time periods, as well as comparing various aspects of such performance to benchmarks identified in the IPS. The investments will be analyzed based on their investment philosophies, policies, risk level, and performance as they relate to the investment and diversification objectives, policies, constraints, and risk tolerance, as specified in the investment policy statement and/or you. These Performance Reports may include a combination of: market commentary; plan asset allocation summary; risk and return analysis; investment cost analysis; investment research; and overall review for comparison to the IPS. Account data will be derived from trust or custodial statements for each period. We will not be responsible for verification of the information supplied by the custodian or trustee. Additional Plan Services: In addition to investment-related Services, periodically in the future and as mutually agreed upon, we will provide additional non-discretionary services, as defined above. Services Tailored to Individual Client Needs Each of the advisory services we offer is tailored to you and designed to meet the plan's investment objectives, financial needs and tolerance of risk. They are drawn from research and analysis we believe to be reliable and appropriate to your financial circumstances. No Portfolio Management Services We do not act as a portfolio manager for any Retirement Plan Consulting Program services. We act as portfolio manager for certain Wrap Fee Programs that we offer to Clients and collect a fee for performing that service. Assets Under Management As of December 31, 2025, we manage $478,834,872,430 of Client assets on a discretionary basis and $192,586,970,269 of Client assets on a non-discretionary basis. Fees and Compensation Fees for services are described below and are guidelines which may vary due to the complexity and size of the plan, and are therefore subject to negotiation. You can choose to pay for services either as a flat annual fee, a percentage of assets, or, for some services, as a one-time service. Generally, ongoing fees are paid on a quarterly basis unless otherwise agreed upon. Plan Size AUM Ongoing % (bps) Min Fee Ongoing % (bps) Max Fee Ongoing Dollar Min $ Fee Ongoing Dollar Max $ Fee $0 - $1M 0.1 1 $500 $10,000 $1M - $5M 0.1 0.7 $1,000 $30,000 0.1 0.5 $3,500 $40,000 $5M - $10M $10M - $25M 0.01 0.25 $5,000 $100,000 The fee for the Plan Level Investment Selection 3(38) service is as follows: Fee Range 5 to 10 bps per year in addition to the fee range shown in the chart above. Plan Level Investment Selection 3(38) Costs for travel, incidental expenses and materials incurred during the provision of Employee Education services will be charged separately. We reserve the right to negotiate fee rates published above on a case-by-case basis. Frequency and Method of Payment Fees for one-time services are payable immediately after services are provided. Fees for ongoing services are assessed quarterly in arrears. Clients may choose to pay fees by invoice to the plan or plan sponsor, or to instruct us to send the invoice to the plan's provider/recordkeeper. Compensation Related to Our Financial Advisors and Branch Management Financial Advisors. Financial Advisors providing service to Clients from either a WFA branch or an office located in a Wells Fargo Bank, N.A. branch receive a percentage of the revenue that the Firm collects from brokerage transactions and from ongoing fees collected from investment advisory accounts. Typically, a Financial Advisor’s product or service-based payout schedule (periodically adjusted by us at our discretion) increases with production and asset levels. The same payout schedule is reduced when Financial Advisors discount certain client fees and commissions, or client relationship asset levels are below minimums established by us. Therefore, Financial Advisors have an incentive to make recommendations that result in their Clients adding funds to WFA advisory and brokerage accounts, and in selecting products and services that generate the most revenue and profit for themselves and the Firm. As a Financial Advisor’s production and asset levels increase, in addition to the Financial Advisor’s payout schedule increasing, the Financial Advisor’s expense budget and bonus increase, and the Financial Advisor may qualify for recognition trips. Also, as mentioned above the payout schedule is reduced when certain fees are discounted, thus Financial Advisors are discouraged from providing discounts below certain thresholds when negotiating discounts to commissions for brokerage accounts and Program Fees for Advisor Program Accounts. In cases where your Financial Advisor anticipates that you will have low trading activity in your account, the Financial Advisor has an incentive to recommend that you invest account assets in an advisory account which have ongoing Program Fees (discussed above) versus a brokerage account which have transaction- based fees. 589132 (Rev 30 - 03/26) Page 7 of 15  Financial Advisors also receive compensation based on the outstanding loan balances of PCL and Securities-Based Loan Programs from Wells Fargo Bank, N.A. Please refer to the “Margin Loans and Securities-Based Loan Programs” section for additional information on compensation related to PCL and Securities-Based Loan Programs. Client Referrals to Solutions Team. Financial Advisors receive compensation for each client referred to the Solutions Team, described in the Personalized Unified Managed Account section above. However the Financial Advisor could provide these same services directly to the Client. As a result of the compensation details provided above, Financial Advisors have a financial incentive to not refer otherwise eligible clients to WFA Solutions due to the greater compensation if the Financial Advisor serves the client directly, as these assets will be attributed to those of the Financial Advisor for compensation pay-out, bonus and recognition purposes. Client Referrals to Wells Fargo Bank, N.A. Financial Advisors receive referral compensation for client referrals to Wells Fargo Bank, N.A. for trustee or investment management services. The amount of compensation earned by the Financial Advisor for the referral depends on the value of account referred and the role the Financial Advisor will have in the client relationship after the referral. Ongoing involvement in the client relationship post referral typically results in recurring payments to the Financial Advisor based on a percentage of the client fees earned by Wells Fargo Bank, N.A. Financial Advisors are also eligible for annual or ongoing bonuses and deferred compensation awards based upon a variety of factors that include overall company performance, reaching certain production levels, tenure with the Firm, client product mix, asset gathering, referrals to affiliates or other targets, as well as compliance with our policies and procedures and meeting best business practices. These incentives—particular ones based on production levels (i.e. revenue and profit generated for the Firm), product mix, asset gathering and referrals to affiliates—result in Financial Advisors being encouraged to recommend courses of action that increase your usage of products and services offered by us and our affiliated companies such as Wells Fargo Bank, N.A. and Wells Fargo Securities, LLC. Moreover, Financial Advisors receive higher compensation for transactions involving client households that maintain greater amount of assets with us. Recruitment compensation is provided to Financial Advisors who join our Firm from another financial firm. This compensation, which varies by Financial Advisor, typically has the following three components: an up-front payment; a deferred compensation component; and a back-end bonus arrangement based on new client assets transitioned/gathered over a three-year period. This creates an incentive for the Financial Advisor to recommend the transfer of assets to the Firm to earn this compensation despite the fact that you may not have access to the same suite of products and/or services that you had at a predecessor firm. We offer certain Financial Advisors an optional loan when joining WFCS. If the recruited Financial Advisor voluntarily chooses the loan option, the Financial Advisor must repay the loan to WFCS. Financial Advisors who choose a loan option are offered the choice to voluntarily have the loan repaid via an automatic deduction from pay, or they may repay the loan via check. The amount of some incentive compensation paid to the Financial Advisor in these situations is impacted by the Financial Advisor meeting certain revenue or asset levels. This arrangement provides an incentive for the financial advisor to recommend that you deposit assets or establish accounts with WFCS and WFCS's interests will conflict with yours. We provide noncash compensation to Financial Advisors in the form of certain titles and/or education meetings and recognition trips. Portions of these programs are subsidized by external vendors and affiliates, such as mutual fund companies, insurance carriers, or money managers. Consequently, product providers that sponsor and/or participate in educational meetings and recognition trips gain opportunities to build relations with our Financial Advisors, which could lead to sales of such product provider’s products. This creates a conflict of interest as the Financial Advisors could be influenced to recommend such provider's products in order to participate in these educational meetings and recognition trips. Financial advisors also receive promotional items, meals, entertainment, and other noncash compensation from product providers up to $100 per year for gifts per vendor and $1,000 per year for meals per vendor. Supervisor Compensation. Branch Managers and Area Managers (who are responsible for supervising Financial Advisors operating from a Wells Fargo Bank, N.A. branch) are compensated based on the total revenue generated by the Financial Advisors subject to their supervision. A portion of the Branch Manager’s and Area Manager’s compensation is also based on the branch meeting business growth targets—such as net asset flows from clients, client usage of lending products, financial advisor recruitment and retention, and client usage of affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.—and branch profitability. Therefore, Branch Managers and Area Managers have an incentive to encourage Financial Advisors to recommend products and services that increase or maximize revenue and profit received for the Firm. When Branch Managers and Area Managers serve as Financial Advisors to brokerage and advisory account clients, the Branch Manager (or Area Manager) is compensated as described above for Financial Advisors. Market Growth Strategy Consultants. Market Growth Strategy Consultants support branch-based Financial Advisors and Branch Managers in the growth of WFA advisory accounts. Market Growth Strategy Consultants are compensated by salary and a bonus based on gross asset flows in Advisory Program Accounts at the branches that they are responsible for supporting and on gross assets referred to the Wells Fargo Bank, N.A. trust services platform. Therefore, the Market Growth Strategy Consultant has a conflict of interest, and is incentivized to emphasize the potential benefits of WFA Advisory Program Accounts and trust and investment management services provided by Wells Fargo Bank, N.A. when providing support to Branch Managers, Financial Advisors, or when joining Financial Advisors in discussions with Clients considering an Advisory Program Account or contributing additional funds to an existing Advisory Program Account. 589132 (Rev 30 - 03/26) Page 8 of 15  Termination In the event the Client Agreement is terminated, you shall have no obligation to make additional payments that would otherwise be required to be made, but we may submit to you an accounting of the services theretofore provided to you (which may include an accounting of our preparations to provide services that would have been provided by us but for such termination) and you shall be liable to us for the amount set forth thereon (which amount will not exceed the total amount of our compensation as agreed to by you and us in the Client Agreement) (the "Termination Obligation"). In the event you have paid any payments prior to such termination: if the amount of such payments exceeds the Termination Obligation, you shall be entitled to a refund of such excess, and we shall be entitled to retain the remainder in full satisfaction of the Termination Obligation; and if the Termination Obligation exceeds the amount of such payments, and you shall promptly pay the amount of such excess in order to satisfy the Termination Obligation. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees in any of our investment advisory programs. We do not have any side-by-side management situations. Types of Clients We offer the Retirement Plan Consulting Program to both qualified plans subject to ERISA and non-qualified deferred compensation plans not subject to ERISA. We also provide these services to qualified plans and non-qualified deferred compensation plans who are Clients of our affiliate, Wells Fargo Advisors Financial Network. Methods of Analysis, Investment Strategies and Risk of Loss Under our Retirement Plan Consulting Program, we render services to both retirement plans subject to ERISA and retirement plans not subject to ERISA. Our specific recommendations may vary based on the scope of the services for which we are engaged to advise upon. At all times, our investment philosophy will reflect our duty to act with respect to the plan solely in the interests of participants and beneficiaries as well as within the principles of prudence and diversification of plan assets. For plans subject to ERISA, we will carry out our duties and responsibilities in accordance with ERISA as it applies to the services we are rendering. To the extent not contrary to ERISA, we will take into consideration the goals and objectives as provided and/or communicated by the plan. If in our view, any investment instruction, guideline or requirement received from a plan fiduciary is inconsistent with or contrary to ERISA, we will disregard such provision or instruction when carrying out our duties and will act in accordance with our responsibilities under ERISA and the regulations promulgated thereunder. For the purposes of our non-discretionary service of providing Investment Search and Recommendation services to plans subject to ERISA, if the plan does not provide written investment instructions or objectives such as an IPS, we will focus on identifying a menu of diversified investment options, each with differing risk and return characteristics appropriate for a plan participant or beneficiary. The investment options we recommend could include active and passive investment vehicles, as well as target-date investment options. When we are engaged to provide discretionary services to plans subject to ERISA, we will use the IPS and the investment philosophy outlined therein in providing investment advice. If the plan is not subject to ERISA and we are hired to provide Investment Search and Recommendation—we will recommend a menu of investment options for the plan that provides plan participants a diversified set of investment options—ranging from conservative to aggressive growth investment choices. We could include active and passive investment vehicles in our recommendations, as well as target-date investment options. When we are hired to provide Investment Search and Recommendation Service for plans not subject to ERISA, we seek to identify and recommend one (or more when appropriate) investment managers to manage a plan’s assets—either in their entirety or a portion thereof. In doing so, we will recommend investment manager(s) that we believe are capable of adding value on a risk-adjusted basis. When reviewing potential investment managers, we take into consideration the overall stated objectives of the assets which will vary based on: plan type; and whether the investment manager’s mandate will be limited to a specific asset class or investment category within a broader pool of assets. We do not provide investment advice in a discretionary manner to plans not subject to ERISA. Methods of Analysis In performing the investment advisory services, our analyses and recommendations are based on modern portfolio theory and other general diversification philosophies. WFA makes available to its financial advisers: reports and analyses on investment products and asset managers from WFA’s affiliate investment adviser Wells Fargo Investment Institute, Inc. (Wells Fargo Investment Institute, Inc. is an investment adviser registered with the Securities and Exchange Commission. It is a subsidiary of Wells Fargo Bank, N.A. Registration as an investment adviser does not imply a certain level of skill or training. Wells Fargo Investment Institute, Inc. and Wells Fargo Bank, N.A. are subject to the control of Wells Fargo & Company (NYSE: WFC), a financial holding company.); and third-party databases, analytics tools and presentation tools. These resources are used individually or in combination in both initial investment product and investment manager selection. They are also used in the periodic review or, in the case of our 3(38) services, the monitoring of recommended investment products and investment managers. When evaluating and recommending investment options or investment managers to manage the plan’s assets, WFA generally considers the following (List includes common relevant considerations but is not intended to be exhaustive; nor will all be necessarily relevant to a particular plan’s needs.): • General principles of diversification of assets and modern portfolio theory • Legal and regulatory considerations • Plan imposed restrictions 589132 (Rev 30 - 03/26) Page 9 of 15  • Time horizons • Need for current income • Investment objectives • Management fees • Shareholder fees • Asset class • Performance Investing carries risk of loss. Separately managed accounts managed by investment managers, mutual funds and exchange-traded funds, and individual securities are all subject to risk of loss. With respect to an investment manager that we may recommend to a plan, each manager will have investor materials addressing the risks associated with the particular manager’s strategies. Investment Strategies When we provide Plan Level Investment Selection services, we do not provide personalized investment advice to plan participants. When we provide Investment Manager Search and Recommendation Services, information regarding the investment strategies (generally investment risks, investment methods of analysis, and types of securities used) offered by the investment manager that we recommend to the plan will be contained in each manager’s Form ADV Part 2A or similar document, or other informational materials of the manager. Risk of Loss All investments shall be at your risk exclusively, and you must understand that we do not guarantee any return on the investments recommended or advised upon and may not be responsible for losses resulting from such trading or for any transactions that we have not recommended to you. Disciplinary Information We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of the broker-dealer, investment advisor or predecessor firms. For more information on broker/dealer related disciplinary events you may visit: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/. Our investment advisory disciplinary history is available by going to: http://www.adviserinfo.sec.gov/. In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. In January 2025, WFCS and WFAFN agreed to a settlement with the SEC regarding allegations that they failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to their cash sweep program, specifically, their use of a bank deposit sweep program. The order found that WFCS and WFAFN did not adopt and implement reasonably designed policies and procedures that considered the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; or addressed the duties of WFCS and WFAFN financial advisors in managing client cash in advisory accounts, in willful violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. WFCS and WFAFN, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28 million by WFCS and $7 million by WFAFN. In August 2023, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC (collectively, the "Firm") agreed to a settlement with the SEC regarding allegations that from at least 2002 through December 2022, the Firm and its predecessor firms overcharged approximately 10,945 accounts of advisory clients, for accounts opened through 2014, for more than $26.8 million in advisory fees and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the overbilling in willful violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells Fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells Fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the Firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected accountholders. Without admitting or denying the findings, the Firm consented to a settlement that included a cease and desist order, censure and civil money penalty of $35,000,000. In December 2021, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti-money laundering Customer Identification Program (CIP) in the required non-erasable and non-writable “Write Once, Read Many” (WORM) format in violation of Exchange Act Rule 17A-4(F)(2)(II) (A) and failed to notify FINRA prior to using the non-WORM compliant storage platform in violation of Exchange Act rules 17A-4(F) 589132 (Rev 30 - 03/26) Page 10 of 15  (3)(V) and 17A-4(F)(2)(I). Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine, jointly and severally, of $2,250,000. On August 27, 2020, Wells Fargo Clearing Services, LLC agreed to a settlement with FINRA regarding allegations that the Firm failed to reasonably supervise the activities of two former registered representatives, thus violating its own written supervisory procedures along with NASD Rule 3010(a) and FINRA Rules 3110(a) and 2010. Between November 2012 and October 2015, the two representatives recommended that many of their customers invest a substantial portion of their assets in four high-risk energy securities, which generated multiple red flags regarding overconcentration and suitability in their customers' accounts that the firm failed to reasonably investigate. The Firm has previously compensated 67 clients over $9.7 million for losses in these investments. Without admitting or denying the findings, the Firm agreed to a settlement that included a censure, a fine of $350,000 and restitution in the amount of $201,498 plus interest to additional specified clients. On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, following the Firms' offers of settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds ("ETFs") without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The Commission found that the Firms willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 203(e)(6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained in the Order, to: cease and desist from committing or causing any violations and any future violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; be censured; and jointly and severally pay a civil monetary penalty in the amount of $35,000,000. In 2018, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC elected to participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative ("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling $17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms self-reported. In December 2017, Wells Fargo Advisors agreed to a settlement with the State of Illinois Securities Department regarding allegations that it received, reviewed and/or analyzed documents and information from a financial advisory firm concerning certain money manager strategies that contained information that was later found to be false and misleading. The findings stated that we included the financial advisory firm's money manager strategies in certain of our externally managed Separately Managed Account Programs, but that we did not utilize inaccurate historical performance data in connection with our decision to onboard the money manager strategies and we did not incorporate inaccurate performance data in our advertisements or Program marketing materials. Without admitting or denying the findings, the Firm agreed to a total monetary payment of $270,000. On December 21, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also found that the Firms failed to implement an audit system for those records, failed to provide its third party vendors full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce written procedures. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,500,000. The Firms also consented to a review of its policies and procedures. On December 5, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through available applications. The findings stated that these applications allowed the Firms' representatives to manually enter information regarding customers' external accounts, assets and liabilities into a centralized table which the Firms maintained. This information would then be used to populate reports, including those that would be sent to the Firms' customers. FINRA found that the Firms did not have systems in place to review the contents of the reports, including information about customer holdings away from the Firms. In addition, the Firms' supervisory systems and procedures were inadequate because there was no mechanism allowing representatives to designate which reports were actually provided to customers and the system could not distinguish between draft reports and completed reports that were sent to customers, which should have been subject to the Firms' supervisory systems designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,000,000. 589132 (Rev 30 - 03/26) Page 11 of 15  Other Financial Industry Activities and Affiliations We are a national securities firm providing qualified custodial, investment and other financial services to individual, corporate and institutional Clients. We are a registered broker-dealer and investment adviser. WFCS is a member of all principal stock exchanges in the United States, including the New York Stock Exchange and NASDAQ. WFCS is also a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). We may also route transactions through our affiliate, Wells Fargo Securities, LLC. Unless otherwise stated as the case, the investment advisory services offered and the underlying stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not insured or otherwise protected by the Federal Deposit Insurance Corporation ("FDIC") or another government agency. They are not obligations of any bank or any affiliate of us; are not endorsed or guaranteed by Wells Fargo, WFA, or any bank or any affiliate of us; and involve investment risk including possible loss of principal. Cash balances in Client Accounts may be held in a depository product sponsored by Wells Fargo Bank, N.A. Wells Fargo Clearing Services, LLC is not an FDIC-insured depository institution; FDIC deposit insurance only protects against the failure of an insured depository institution. Banking products and services provided by Wells Fargo Bank, N.A. Member FDIC. Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible for securities we sell or purchase. As a general matter, unless otherwise stated, we may be a principal or engaged in underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to issuers whose securities may be sold to you. From time to time, a bank or thrift affiliated with us may lend money to an issuer of securities underwritten or privately placed by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will disclose to the extent required by applicable securities laws: the existence of any material lending relationship by any affiliate of ours with such an issuer; and whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding indebtedness to any of our affiliates. We have a number of related persons who may provide investment management and related financial services to our Clients. The advisory services these investment advisers offer are described more fully in their Disclosure Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services follows. • Wells Fargo also provides retail brokerage and investment advisory services through Wells Fargo Advisors Financial Network, LLC ("WFAFN"). • Wells Fargo Investment Institute, Inc. ("WFII") (known prior to November 1, 2014 as Alternative Strategies Group, Inc. and before that as Wachovia Alternatives Strategies, Inc.) is a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA. We and our affiliates may give advice and take action in the performance of our duties to you that differ from advice given, or the timing and nature of action taken, with respect to other advisory Clients and/or Clients in other advisory programs. Additionally, we and our affiliates, from time to time, may not be free to divulge or act upon certain information in our possession on behalf of investment banking or other Clients. Material Relationships with Allspring Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners renamed the business Allspring Global Investments. The Wells Fargo Asset Management business was wholly owned by Wells Fargo prior to the transaction and included the following companies: Wells Capital Management Incorporated; Wells Fargo Funds Management, LLC; Wells Fargo Asset Management (International), LLC; Wells Fargo Funds Distributor, LLC; and, Galliard Capital Management, Inc. These companies, which are no longer related persons of WFCS, served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the companies managed separately managed account strategies offered through WFCS. Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings, LLC. This group of companies includes Allspring Funds Management, investment adviser to mutual funds within the Allspring family of funds, Allspring Funds Distributor, LLC, the principal underwriter of Allspring mutual funds, and Allspring Global Investments, LLC, a model portfolio strategy provider and an investment adviser to pooled investment vehicles and separately managed accounts. Wells Fargo has no role in the management of Allspring. However, Wells Fargo retains less than a 10% equity ownership interest in Allspring and has continued to provide certain non-advisory transition services to Allspring for a fee since the close of the sale. WFCS also receives compensation from Allspring for the distribution, administrative and operational services that we provide to the Allspring mutual funds. Although Allspring is not a related person of WFCS, WFCS and its related persons continue to benefit from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a similar financial interest. Wells Fargo’s equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services to Allspring for a fee provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account or model portfolio strategies. 589132 (Rev 30 - 03/26) Page 12 of 15  WFII charges Allspring research access fees for investment research services that WFII provides to Allspring. Allspring manages the Managed DSIP, Managed DSIP II, ESG Managed DSIP, Current Equity Income, and Income Multi Asset Portfolio strategies offered through WFA’s Personalized Unified Managed Account advisory program (collectively, the “Equity Income Strategies”) utilizing information derived, in part, from certain of the research services. The research access fees are calculated based on the assets invested in the strategies, meaning that WFII earns more money when more assets are invested in the strategies. The research access fees are assessed at rates that result in WFII receiving fees that are equivalent to substantially all of the Manager fees assessed in conjunction with the Income Multi Asset Portfolio, the Current Equity Income Strategy, and the Managed DSIP strategy, and approximately half or greater of the Manager fees assessed for the Managed DSIP II strategy and the ESG Managed DSIP strategy. The fee paid to WFII is for research services WFII provides to Allspring, including: investment research that WFII provides to Allspring; and access to certain WFII research analyst teams, strategists, and associates to discuss the research and/ or obtain additional research commentary on covered names, insights into sectors, etc. (collectively “Research Services”). While WFII does not provide the Research Services to other third-party Managers for utilization in managing strategies, WFII does provide the Research Services to its affiliates, WFCS and WFAFN, who in turn, may utilize the Research Services to manage strategies and who provide the investment research at no cost to WFCS and WFAFN advisory clients, WFCS and WFAFN brokerage customers, and prospective clients and customers for their individual use. As such, investors in the Equity Income Strategies are indirectly paying for investment research that others receive at no cost, and that those same investors could receive from WFCS or WFAFN for their individual use outside of the Equity Income Strategies at no cost under other circumstances. Similar investment research may be available in the marketplace at no cost or for materially lower fees than are being charged to Allspring in conjunction with the Equity Income Strategies. WFII’s receipt of a research access fee in conjunction with the Equity Income Strategies creates a material conflict of interest since it results in WFII, an affiliate of WFCS, earning more revenue when investors follow a WFCS recommendation to invest in the Equity Income Strategies than WFCS, WFII or their affiliates would earn if investors followed a recommendation from WFCS to invest in any of the other Model Manager strategies available through the Personalized UMA Program as WFCS and its affiliates earn no comparable additional revenue for investments in other Model Manager strategies. WFCS seeks to mitigate this conflict and its associated implications through disclosure, management of the financial incentive for financial advisors to recommend the Equity Income Strategies, and evaluation of the total costs of investing in the Equity Income Strategies relative to other Model Manager strategies. You should carefully consider the research access fee that is retained by WFII and our related conflict of interest when evaluating whether to invest in the Equity Income Strategies. The Equity Income Strategies are available through Wells Fargo Bank, N.A., including through Wealth & Investment Management Trust Services, and no research access fee is applied to assets invested in the Equity Income Strategies when the assets are custodied at Wells Fargo Bank, N.A. The research access fee is also not applied to assets invested in ERISA accounts. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our Associates are subject to a Code of Ethics that is designed to ensure our business activities are performed with the highest possible standards of ethics and business conduct, and to comply with all applicable laws, rules, and regulations that govern our businesses. Key requirements of our Code of Ethics are summarized below, and you may obtain a complete copy through your Financial Advisor. • Conduct all aspects of Wells Fargo's business activities in an honest, ethical, and legal manner, and in accordance with all applicable laws, rules, and regulations and our policies and procedures. • Provide accurate and complete information in dealings with Clients and others, including disclosure of conflicts of interest when they exist. • Prepare and maintain accurate business records. • Refrain from improper disclosure or misuse of confidential Client information and material, non-public information. Wells Fargo protects the private, personal, and proprietary information of Clients and others. • Avoid conflicts of interest in personal and business activities. • Rules specific to personal trading. Participation or Interest in Client Transactions Under the Wrap Fee Programs, we are generally appointed as sole and exclusive broker by you with respect to the referenced Account for the execution of transactions. Our Wrap Fee Program fee covers transaction costs when transactions are executed through us. On occasion, you may designate, or the law may require, the use of other brokers. Investment advisers may also elect to execute transactions with other firms as they deem appropriate, taking into account a number of factors such as best execution, research services and other qualitative factors. When transactions are executed with other firms, including transactions executed through our affiliates, the cost of execution is imbedded in the price of the security. Any imbedded execution costs on trades done away from us are in addition to our Program Fee. In connection with these transactions, we may act as agent or, where permitted by law, principal (including instances wherein we are acting as underwriter or selling group members). You authorize that we may effect and execute brokerage transactions, including on a national exchange, as permitted by current provisions of Section 11(a) of the Securities Exchange Act of 1934, as amended (the "Exchange Act") and rules promulgated thereunder including any future amendments or changes to such statutes and rules. With respect to money market sweep vehicles investments, you receive disclosures about our affiliates and the advisory and other fees paid to affiliates by the Funds in the Fund's prospectuses and our Disclosure Documents, and Client Agreements, as applicable. 589132 (Rev 30 - 03/26) Page 13 of 15  We or our affiliates may have investment banking or other relationships with certain publicly traded companies. These relationships may from time to time require us to restrict trading in the securities of these companies. As a result of these investment banking or other activities, our affiliates may acquire confidential or material non-public information that may prevent us or our affiliates, for a period of time, from purchasing, selling or recommending particular securities for your account. We and our affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. Additionally, we may be restricted or limited in our ability to purchase or sell particular securities or make investment recommendations as a result of these affiliated activities. We have certain restrictions, internal procedures and Client disclosures regarding conflicts of interest that we may have with respect to our participation or interest in Client transactions. We communicate our policies and procedures related to participation in Client transactions to our Associates through our compliance policies and procedure manuals and program-specific policy guidelines. Personal Trading We maintain policies and procedures to mitigate conflicts of interest between transactions in our Associates' personal investment accounts, including accounts of their immediate family members and transactions in our Clients' accounts. To ensure Associate trading requirements are observed, certain Associate trading activity is subject to pre-approval. All Associates are subject to regular review by their supervisors, independent oversight by our Compliance Department, and systemic controls that automatically restrict entry of certain orders and generate related surveillance reporting. Brokerage Practices We do not provide any brokerage services as part of our Retirement Plan Consulting Program. Assets are all held away from us with a third-party custodian. Review of Accounts The FA provides the services agreed to in the contract. Client Referrals and Other Compensation From time to time, we initiate incentive programs for our Associates, including FAs. Incentive programs compensate our Associates and FAs for attracting new assets and Clients, referring business to our affiliates (such as referrals for banking services and accounts, mortgages, lending, trusts, or insurance services) or other FAs, promoting investment advisory services and promoting green initiatives (such as raising Client awareness of paperless options). We may also initiate programs that reward Financial Advisors who meet total production criteria, length of service requirements, participate in advanced training and improve Client service. Financial Advisors who participate in these incentive programs may be rewarded with cash and/or non-cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. Portions of these programs may be subsidized by external vendors and/or our affiliates, such as mutual fund companies, insurance carriers, or investment advisers. Therefore, Financial Advisors and other Associates have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services we offer. We may also enter into arrangements with other persons to whom we pay compensation for referrals to our advisory Programs. This compensation is generally in the form of a percentage of the fees described in the Program contracts. The details of such arrangements and the amount of compensation will be described in a separate disclosure provided at the time of such referrals. Additionally, we also compensate employees of Wells Fargo Bank, N.A. for referrals to WFA. From time to time, we compensate Associates other than Financial Advisors for referrals of possible Clients to the Programs. Our Financial Advisors, not the referring Associate, will make the actual presentation and solicitation of these services. The referral compensation takes the form of a payment to the Associate of a percentage of the fees described in the Programs contracts and results in no additional fees to you or other Clients. Wells Fargo & Company is a full-service financial services firm with many affiliates. Wells Fargo & Company encourages its subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual business planning, business with our affiliates is included in establishing our sales goals. As a result, we may have an incentive to hire affiliate service providers for our advisory programs. We may recommend affiliated mutual funds to our Clients, and may hire other affiliates to provide trade execution, clearing, and platform administration services for our programs. We intend, however, to make all recommendations independent of any such goals and based solely on our obligations to consider your objectives and needs. Custody In the Retirement Plan Consulting Program, we do not have custody of your funds or securities. Once the vendor is chosen for the retirement plan, you will receive quarterly, or more frequent, account statements directly from the vendor and/or the custodian, which may or may not include WFCS or an affiliate. You should carefully review these statements for accuracy. Investment Discretion Except when providing the Plan Level Investment Selection 3(38) service, we do not have investment discretion when providing services to Retirement Plan Consulting Program Clients. 589132 (Rev 30 - 03/26) Page 14 of 15  Voting Client Securities We do not accept authority to vote Client securities subject to our Retirement Plan Consulting Program services. Financial Information We have no financial condition that is likely to impair our ability to meet our contractual commitments to you. 589132 (Rev 30 - 03/26) Page 15 of 15 

Wrap Fee Brochure for Intuitive Investor® Program 801 - 37967 Investment Advisory Services of Wells Fargo Advisors Revised March 2026 One North Jefferson, St. Louis, MO 63103 Phone (314) 875-3000 wellsfargoadvisors.com This wrap fee brochure provides information about the qualifications and business practices of Wells Fargo Advisors and our Intuitive Investor Program (the "Program"). This information should be considered before becoming a Client of this Program. If you have any questions about the Program or the contents of this brochure, please contact us at (855) 283-5567. This information has not been approved or verified by United States Securities and Exchange Commission or by any state securities authority. Additional information about Wells Fargo Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov. Please note that registration as an investment adviser does not imply a certain level of skill or training. The advisory services described in this brochure are not insured or otherwise protected by the U.S. Government, the Federal Deposit Insurance Corporation, the Federal Reserve Board, or any other government agency and involve risk, including the possible loss of principal. Investment and Insurance Products are: • Not Insured by the FDIC or Any Federal Government Agency • Not a Deposit or Other Obligation of, or Guaranteed by, the Bank or Any Bank Affiliate • Subject to Investment Risks, Including Possible Loss of the Principal Amount Invested Wells Fargo Advisors is a trade name used by Wells Fargo Clearing Services, LLC (WFCS), Member SIPC, a registered broker-dealer and non- bank affiliate of Wells Fargo & Company. WellsTrade brokerage accounts are offered through WFCS. Page 1 of 21 593718 (Rev 25 - 03/26)  Summary of Material Changes This section describes the material changes to Wells Fargo Clearing Services, LLC’s (“WFCS”) Part 2A of Form ADV Appendix 1 (“Wrap Fee Program Brochure” or this “Brochure”) for the Intuitive Investor Program since the annual version of this Brochure dated March 2025. WFCS conducts business under the trade name Wells Fargo Advisors (“WFA”). The summary of material changes is designed to make clients aware of information that has changed since the Brochure’s last annual update or that may be important to them. Clients are encouraged to read this Brochure in detail. Cash Sweep Program sub-section of Additional Information was updated to indicate that the Expanded Bank Deposit Sweep program would be discontinued effective August 15, 2025. The Expanded Bank Deposit Sweep Program has now been discontinued, as a result, the Cash Sweep Program section of the Brochure has again been updated to remove language specific to the Expanded Bank Deposit Sweep Program from this section. Since all Program Banks are affiliated banks of WFA, all benefits that Program Banks receive from participating in the Bank Deposit Sweep Program accrue solely to banks affiliated with WFA. More information on how Program Banks benefit from participating in the Bank Deposit Sweep Program, as well as WFA’s economic incentives and conflicts of interest related to the program, can be found in the Bank Deposit Sweep Program section generally and the Spread Earned by Banks subsection of this disclosure Brochure. Disciplinary Events sub-section of Additional Information has been updated to include: In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. Voting Client Securities and Corporate Actions section has replaced the Proxy and Reorganization section and details that proxies are now voted under proxy voting policies and guidelines established by Wells Fargo and administered by a third-party service provider. You are encouraged to review the new sections in full. On March 6, 2026, WFCS discontinued Sustainability Focused Portfolios. These portfolios are no longer available to accounts enrolled in the Intuitive Investor program. This document has been updated to remove references to the Sustainability Focused Portfolios as an investment approach. Program Fees section, “Differing Compensation” subsection has been amended, adding that the additional compensation from exchange-traded funds poses a conflict of interest as it offers us a financial incentive to select one fund or a fund from one fund sponsor over a similar fund due to the compensation we retain from one fund or fund sponsor versus another. Program Fees section has been amended to include sub-section Financial Advisor Compensation. This sub-section includes the following: “Financial Advisors serving Program Accounts are compensated by salary and discretionary performance bonus. For these Financial Advisors, their discretionary bonus is based on a number of factors including company performance and individual performance which takes into consideration a variety of factors including telephony metrics and production metrics such as funded accounts and net asset flows, client referrals to Wells Fargo Bank, N.A. for trustee or investment management services, and client usage of lending products and affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A.” Proxy Voting Practices and Voluntary Corporate Actions section has been updated, removing portions related to Institutional Shareholder Services, LLC and references to the ability to appoint a party other than the clients to vote proxies for securities held in an Intuitive Investor Account. Brokerage Practices section has been updated to include the following: “For this Program, the terms of the Client Agreement instruct that WFA will be used for execution of purchases and sales of securities for your Account. Directing brokerage through WFA may result in transactions in your Account receiving less favorable execution than could be obtained using a broker-dealer other than WFA. Not all investment advisers require their clients to direct brokerage.” Page 2 of 21 593718 (Rev 25 - 03/26)  Table of Contents Page Summary of Material Changes 2 Services, Fees and Compensation 4 The Intuitive Investor Program Services 4 Program Fees 6 Compensation 8 Account Termination 9 Account Requirements and Types of Clients 10 Portfolio Manager Selection and Evaluation 10 Services Tailored to Individual Client Needs 11 Client Restrictions and Instructions 11 Performance-Based Fees and Side-By-Side Management 11 Methods of Analysis, Investment Strategies and Risk of Loss 11 Program Website Tool Methodology 12 Voting Client Securities and Corporate Actions 12 Proxy Voting Practices 12 Client Information Provided to Portfolio Managers 13 Client Contact with Portfolio Managers 13 Additional Information 13 Disciplinary Information 13 Other Financial Industry Activities and Affiliations 15 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 17 Review of Accounts 17 Prospectus Delivery 17 Client Referrals and Other Compensation 18 Brokerage Practices 18 Financial Information 21 Page 3 of 21 593718 (Rev 25 - 03/26)  The Intuitive Investor Program Overview and Definitions Wells Fargo Advisors ("WFA") is a trade name used by Wells Fargo Clearing Services, LLC ("WFCS"). WFA is a non-bank affiliate of Wells Fargo & Company ("Wells Fargo"), a publicly held company (NYSE: WFC) and financial holding company and bank holding company founded in 1852. Wells Fargo and its affiliates are engaged in a number of financial businesses, including retail brokerage and investment advisory services. WFA is affiliated with Wells Fargo Investment Institute, Inc. ("WFII"), a registered investment adviser that provides advisory services and research to WFA. Helpful Terms. You, Yours, I, Client and the Account Owner is any person who has entered into an Agreement with WFA. We, Our, Ours and Us includes Wells Fargo Clearing Services, LLC d/b/a Wells Fargo Advisors including their affiliates and agents (collectively referred to as "Wells Fargo Advisors" or "WFA"). Account is collectively or individually any brokerage Account and/or any Advisory Program Account you have with us, including any and all funds, money, securities and/or other property you have deposited with us. Affiliate is any entity that is controlled by, controls or is under common control with us. Each Affiliate is a separate legal entity, none of which are responsible for the obligations of the other. Securities and Other Property is money, securities, financial instruments and commodities of all types and related contracts, options, distributions, proceeds, products and accessions. Agreement is the Agreement between you and us regarding your Account, and any other documents included by reference. Types of Advisory services We Offer. We offer a number of advisory programs ("Programs") and services that are designed to help you meet your investment objectives and goals, including various wrap fee Programs, consulting services and financial planning services. Wrap fee Programs generally, subject to certain limitations, include advisory, execution, custodial and reporting services for a single fee, rather than separate costs and commissions for each transaction. WFA's advisory Programs and services include: Financial Advisor Directed Wrap Fee Programs Institutional and Retirement Plan Consulting Services Financial Planning Services • Unified and Separately Managed Account Wrap Fee Programs • Mutual Fund Advisory Wrap Fee Programs • • Non-Discretionary, Client Directed Advisory Wrap Fee Programs • • About This Wrap Fee Brochure. This disclosure document specifically describes the Intuitive Investor Program. Descriptions of the services and fees for the other advisory Programs and services we offer can be found in separate disclosure documents, copies of which are available upon request or from www.sec.gov. Services, Fees, and Compensation Intuitive Investor Program Services Description. The Intuitive Investor Program ("Program") is a digital investment advisory Program in which investment advice is given through the Program website. Through your Account ("Program Account"), you will be able to invest in one of several discretionary asset allocation portfolios that are diversified across multiple asset classes. Under this Program, you will provide to us through the Program website, mobile applications or other digital interfaces (the "Website"), information about your risk tolerance and investment goals from which we will recommend a Portfolio. After you have enrolled in the Program, you may be able to select or change certain services with instructions to us; however, in certain circumstances we may ask you to sign a separate Agreement or complete additional documentation. Electronic Relationship. In this Program, services are provided to you electronically through the use of the Program Website and the majority of communication will be done electronically. You will need to complete the Program Agreement and any other agreements as necessary to participate in the Program. These agreements and any required disclosures will be delivered to you electronically. In order to access the Program Website, you will be required to establish online credentials and provide us with a valid email address. You must notify us immediately of any changes to your email address. For any issues with the Program Website, you may call us at (855) 283-5565. You may also contact us via phone at (855) 283-5567 for assistance and support related to Your Account including the risk tolerance questionnaire, portfolio recommendations, Account opening, and/or Account performance. Management of your Account. The Portfolios that we recommend are developed by WFII, adopted by WFA and implemented by an unaffiliated Manager. The current Manager is SigFig Wealth Management, LLC. We may change the Manager from time to time in our sole discretion without your prior consent. The Manager will exercise discretion with respect to the day-to-day management of your Account, and provide instruction to us for execution of transactions in your Account. Program Assets. Program Accounts will be invested in portfolios comprised of exchange traded funds ("ETFs"). Accounts will also maintain a cash position held in the Cash Sweep Program. For more information, please see the "Cash Sweep Program" section, later in the Brochure. Page 4 of 21 593718 (Rev 25 - 03/26)  ETFs are typically passively managed portfolios designed to track the performance of a basket of securities or a certain index. ETFs trade on an exchange the way individual stocks do. In simplest terms, traditional ETFs are passively-managed "baskets" of securities that are designed to closely track the performance of specific indices, market sectors, or industries. ETFs are priced and can be bought and sold throughout the trading day. Traditional ETFs that seek to track the performance of a specified benchmark/index are not actively managed. As a result, the investment advisers of those ETFs do not attempt to take defensive positions in declining markets. Therefore, ETFs may be subject to greater losses in a declining market than an actively managed fund. ETFs may not have a high degree of correlation to its underlying index as a result of the ETFs expenses, imperfect correlation between the ETF's investments and the components of the underlying index, rounding of shares prices, changes to the underlying index, turnover rate, and regulatory policies. The Program Portfolios may consist of a blend of traditional low-cost ETFs and complementary "Smart Beta ETFs." Smart Beta ETFs seek to enhance portfolio construction by weighting underlying securities by means other than just the size of the companies. These alternative ways to weight portfolio constituents can employ some of the same screening processes and optimization techniques used by active managers, but with systematic approaches to track referenced benchmarks helping to substantially reduce fund expenses in relation to fully active management. Establishing a Program Account. In order to establish a Program Account you must complete the risk tolerance questionnaire ("RTQ"). We will rely on the information contained in the RTQ when making investment recommendations for your Program Account. The services provided in this Program, including any advisory recommendations we provide, are highly reliant on the accuracy of the information you provide in the RTQ. If you provide us with inaccurate information, this could materially impact the quality and applicability of our recommendations. We reserve the right to refuse for any reason to open any Program Account. No Program Account shall become active until you have provided us with the information and funds necessary to commence activity within your Program Account. Your request to begin services under the Program Agreement is not considered a market order, since both WFA and/or the Manager require time to process your request. We will, however, make every effort to process your request promptly. Factors to Consider. When determining whether to open a Program Account, you should consider various factors, including but not limited to the following: The features and benefits of one service or Program versus another. • Your preference for advisory services or brokerage services; • Your preference for asset-based pricing or commission-based pricing; • Your preference for an online/digital relationship rather than a traditional relationship with a Financial Advisor; • Your expected trade activity; • Your preference for a discretionary rather than non-discretionary relationship; • Your desire for investment advice and/or our management of your money; • Your investment preferences and the types of investments available to you within one Program versus another; • Expected levels of cash to remain uninvested; and • Rebalancing Services. The Manager is responsible for rebalancing the assets in your Program Account. Rebalancing will occur when your Program Account holdings deviate from the Target Allocation of your selected portfolio, subject to certain drift tolerance parameters. In most cases, ETF holdings may drift 25%-35% from the target allocation before rebalancing, and cash may drift 50% from the target allocation before rebalancing. For example, if an ETF position has a target allocation of 10% of your account value and a drift tolerance of 25%, shares would be sold if the allocation of the ETF drifted to 12.5% of your account value or more; and, shares would be purchased if the allocation drifted to 7.5% of your account value or less. We may alter the drift tolerance parameters in your selected Portfolio at any time, and the manager may modify at any time the manner or frequency with which Manager calculates, generates, and places with WFA the orders to rebalance your Program Account. The use of drift tolerance parameters results in slight differences between Accounts invested in the same portfolio. Various factors, such as market fluctuations and the timing of withdrawals and deposits may affect how closely the assets in your Program Account reflect the Target Allocation of your selected Portfolio. Rebalancing your Account may create tax consequences. Tax-Loss Harvesting. Through the Website, you may instruct us to initiate tax-loss harvesting trades in your taxable Account. Tax-loss harvesting is not offered in trust or custodial Accounts. If such instructions are received, understand that: The Manager may limit the amount of gains or losses that can be realized in your Account. • All such requests will be made on a best-efforts basis. • • Performance may be adversely impacted. • When normal trading activity resumes in your Account, the same or similar securities may be repurchased, which may generate new taxable gains or losses. • Securities sold for a loss may not be able to be repurchased for a period of 31 days due to the Internal Revenue Service Wash Sale Rules. This may result in a higher than normal cash position for that period or the Manager may invest in substitute securities. Please note: wash sale rules apply to the Client and the household. Therefore, if you sell a stock in your taxable Account and repurchase the security in your IRA within 30 days (for example), the loss is disallowed, though the retirement Account basis is not increased. The Manager monitors your Account for tax-loss harvesting opportunities; the Manager is not responsible for considering transactions in other accounts held by you or a member of your household — including other accounts held at Wells Fargo — that may result in a wash sale. Page 5 of 21 593718 (Rev 25 - 03/26)  • The replacement Program funds that the Manager recommends may not align with the investment approach that you have selected for your account. Please note: we do not render legal, accounting, or tax advice. Please consult your tax or legal advisors before taking any action that may have tax consequences. Program Fees The standard Program Fee is as follows: Account Value Annual Fee Your Account Value 0.35% The annual fee is billed quarterly in advance. The fee schedule is generally not negotiable, however we may from time to time use special promotional rates and/or give a discounted rate based on Wells Fargo relationship or employment status with Wells Fargo. A promotional rate or discounted rate is subject to end due to the end of the promotion or a change in relationship or employment status. Advisory Programs typically assume a normal amount of trading activity and, therefore, under particular circumstances, prolonged periods of inactivity may result in higher fees than if commissions were paid separately for each transaction. You should be aware that Program fees charged may be higher or lower than those otherwise available if you were to select a separate brokerage service and negotiate commissions in the absence of the extra advisory service provided. Calculating Account Values and Fees. Unless agreed to otherwise, we will deduct fees at the rate shown in the Fee Schedule quarterly in advance. For the purposes of calculating the Program fees, "Account Value" means the sum of the absolute market value of all Program Assets. The Program Fee will be applied to cash and cash alternatives (i.e., money market funds) included in the Account Value. Clients will, in certain interest rate environments, pay Wells Fargo Advisors more in fees with respect to sweep holdings than the interest they earn on the sweep deposits. In valuing Accounts, we will utilize information provided by quotation services believed to be reliable. If any prices are unavailable or believed to be unreliable, we will determine prices in good faith so as to reflect our understanding of fair market value. The Account Value for the calculation of fees may differ from that shown on your monthly Account statement and/or online reports depending on several factors, including trade date or settlement date accounting and other factors. Quarterly Fee. The initial fee is calculated as of the date that the Account is accepted into the Program and covers the remainder of the calendar quarter. There may be a short delay between inception and initial transactions. Subsequent fees will be determined for calendar quarter periods and shall be calculated on the basis of the market value of the Program Assets held for your Account on the last business day of the prior calendar quarter. If your Account does not have a sufficient cash balance to make a payment on the due date, we may sell Program Assets in your Account, without prior notice to you, to generate proceeds sufficient to pay the Program Fee and any other fees and charges payable. The Program Fee is separate and distinct from the fees and expenses charged by the ETFs to their shareholders. Consequently, the ETFs held in your Account are subject to internal fees and/or expenses, which may include advisory and/or brokerage fees. WFA and its affiliates may earn or receive a portion of such fees and expenses in connection with the advisory or brokerage services they provide as sponsor or distributor of an affiliated Program Fund. Additions and Withdrawals. Your Account will be charged (or refunded) a prorated quarterly fee on any net additions (or net withdrawals) in the Account during a month. • Fees will be charged (or refunded) if the net addition or (net withdrawal) would generate a fee (or refund) of at least $40 for that quarter. Fees will be assessed in the month following the net addition (or net withdrawal). • • Fees are based on the value of the assets in your Account as determined by the fee schedule. We are not compensated on the basis of a share of capital gains upon or capital appreciation of the funds or any portion of your funds. Other Account Fees The Program fee does not include certain charges that may be applicable, including: • Dealer markups or markdowns • Odd lot differentials • Transfer taxes • Exchange fees or similar fees charged by third parties, including issuers, and fees required by the SEC • Execution fees (foreign and/or domestic) when applicable • Other fees required by law Page 6 of 21 593718 (Rev 25 - 03/26)  Cash Holdings. You should understand that, depending on interest rates and other market factors, the yield that you earn on cash and cash alternatives, including cash sweep deposits, CDs and money market funds in an Account, has been, and may continue in the future to be, lower than the aggregate advisory fees you pay on cash assets held in an Account. As a result, depending on the interest rate environment, you may experience a negative overall investment return with respect to cash held in an Account. Furthermore, in some instances, the effective return on a cash sweep may be negative. Non-Brokerage-Related Fees. Non-brokerage related fees, such as IRA fees and wire transfer fees, are not included in the Program fee and will be charged to your Account separately. Please consult the Annual and Operational Fee Schedule for a list of these non-Program related fees and charges identified as applicable to advisory Accounts. Prior Commissions or Charges. To the extent that cash used for investment in the Program comes from redemption proceeds of or deposits of your existing mutual funds or other securities investments, you should consider the cost of any prior sales charges or commissions you paid, which are in addition to the Program fee. Selling Securities. If you sell securities prior to initiating (or after terminating) the Program, you will pay the separate brokerage charges for those transactions, in addition to applicable Program fees during the period. If you fund your Program Account with securities, they will be liquidated at no additional cost under the Program Fee. However, if these securities include a mutual fund with a back-end sales charge, that charge will still be applicable. Costs of Investing in Program Assets ETFs. In addition to the Program Fee, as a shareholder of an ETF, you will bear a proportionate share of the fund's expenses, including investment management fees that are paid to the fund's investment adviser, who may be an affiliate of ours. For more information about these funds, see their prospectus. You should be aware that you can invest in ETFs directly without incurring the fee charged for participation in the Program. Cash Sweep Program Clients provide consent through the general account opening agreement to use our Cash Sweep Program. Through our Cash Sweep Program, you may earn a rate of return on the uninvested cash balances in your Account by automatically placing ("sweeping") cash balances into a sweep program account until such balances are invested in securities or otherwise needed to satisfy obligations arising in connection with your Account. Available cash sweep options, eligibility for which depends on the specific advisory program and account type, currently consist of interest-bearing deposit accounts at affiliated banks (“Affiliated Banks”) in our Bank Deposit Sweep Program, and one or more affiliated and unaffiliated Money Market Mutual Funds ("Money Market Sweep Funds"). The Bank Deposit Sweep Program offers FDIC insurance; money market funds do not. Please refer to the Cash Sweep Program Disclosure Statement for details about the terms and conditions of the Program. Once you sign the general account opening agreement, you will opt into the “default” Cash Sweep option for your respective advisory program and account type. You may elect not to participate in the Cash Sweep Program. If you choose not to participate in the Cash Sweep Program, you will not, except in the case of retirement accounts, earn a rate of return on cash balances prior to direct investment. You may also periodically invest cash balances directly in available money market mutual funds or other products offered as direct investments outside of the Cash Sweep Program, options which will likely generate a higher rate of interest or yield than the Cash Sweep Program. You may invest your cash in other products by providing instructions to your investment professional. Available cash will not be automatically swept into any money market mutual fund or other investment that you purchase outside of the Cash Sweep Program; each such purchase must be requested by you or your financial advisor or manager. As returns in the Cash Sweep Program, your personal financial circumstances, and other factors change, it may be in your financial interest to change your Cash Sweep option (if another option is available for your account type), or to invest cash balances in products offered outside of the Cash Sweep Program, options which likely generate a higher rate of interest or yield. Prior to receipt of the general account opening documents, cash deposited in the client's account and not otherwise invested will be held as a free credit balance and not placed in the Cash Sweep Program until written consent is provided to participate in the Cash Sweep Program. While any cash remains in free credit balance, Wells Fargo Advisors will retain any interest earned on assets awaiting investment or disbursement. You understand and agree that this interest (generally referred to as "float") will be retained by us as additional compensation for the provision of services with respect to the account. Except for retirement accounts, while any cash remains in free credit balance, you will not earn any interest on such balance. Bank Deposit Sweep Program The Bank Deposit Sweep Program consists of interest-bearing accounts at up to two Affiliated Banks. Each Affiliated Bank is a depository institution regulated by bank regulatory agencies under various federal banking laws and regulations. Wells Fargo Advisors will establish and periodically update the interest rate paid on deposits held at the Affiliated Banks, coordinating with the Affiliated Banks to implement any change. Note that these rates of interest are typically lower than money market fund yields. Wells Fargo Advisors benefits financially from cash balances held in the Bank Deposit Sweep Program through payments Wells Fargo Advisors receives from the Affiliated Banks. The Affiliated Banks benefit financially from cash balances held in the Bank Deposit Sweep Programs through the “spread” the Affiliated Banks earn on deposits, as described in more detail below. In addition, the management personnel and certain other employees of Wells Fargo Advisors and its affiliates receive incentive compensation based on a number of factors, including the amount of Wells Fargo Advisors Client Bank Deposit Sweep assets held in Affiliated Banks, and the profitability of Affiliated Banks and their joint parent company, Wells Fargo & Company. Wells Fargo Advisors has a conflict of interest as a result of these benefits because it and its affiliates benefit financially from the Bank Deposit Page 7 of 21 593718 (Rev 25 - 03/26)  Sweep Programs and Wells Fargo Advisors chooses to include these options as default Cash Sweep options in advisory programs, instead of selecting other cash investment options that would not generate these financial benefits, and that typically pay you higher rates of interest. Moreover, the Affiliated Banks deduct client interest from the payments they make to Wells Fargo Advisors. The higher the rate paid to clients, the lower the amount paid to Wells Fargo Advisors. Therefore, Wells Fargo Advisors has an incentive to maintain lower rates in the Bank Deposit Sweep Program. Spread Earned by Banks As with other depository institutions, the profitability of the Affiliated Banks in the Bank Deposit Sweep Program is determined in large part by the difference or "spread" between the interest they pay on deposit accounts, such as the Bank Deposit Sweep Program, and the interest or other income they earn on loans, investments, and other assets. The banks in the Bank Deposit Sweep Program pay rates of interest on the Bank Deposit Sweep Program deposits that are typically significantly less than the spread banks earn on deposits. The participation of the Affiliated Banks in the Bank Deposit Sweep Programs increases their respective deposits and, accordingly, overall profits. Wells Fargo & Company’s periodic filings include high-level information on deposit spreads and are available at https://www.wellsfargo.com/about/investor-relations/filings/ . Bank Payments to Wells Fargo Advisors As noted above, Wells Fargo Advisors receives payments from the Affiliated Banks, which are calculated as a percentage of the client assets deposited in the Cash Sweep Program. The interest paid to client accounts in the Bank Deposit Sweep Program is deducted from these payments, and Wells Fargo Advisors receives the remainder. Accordingly, Wells Fargo Advisors has an incentive to pay lower interest rates to participating client accounts. Note that the fee Wells Fargo Advisors receives from the Affiliated Banks usually exceeds the interest paid to participating client accounts by a substantial amount. Moreover, note that the rates paid out to clients will typically be substantially lower than the Federal Funds Effective Rate, and may not increase as quickly as the Federal Funds Effective Rate. In the Bank Deposit Sweep Program, Wells Fargo Advisors receives from the Affiliated Banks payments in an amount not to exceed a percentage (equivalent to Federal Funds Target plus 30 basis points (0.30%)) of the daily total deposit balances at the Affiliated Banks. Money Market Sweep Funds The Cash Sweep Program includes some money market funds that are managed by third parties. Mutual fund companies typically offer multiple share classes with different levels of fees and expenses. When selecting the share class for the Money Market Fund used in the Cash Sweep Program, we do not necessarily select the share class with the lowest fees that is available from the fund company. The use of a more expensive share class of a Money Market Fund in the Cash Sweep Program will negatively impact your overall investment returns. Additional Information For additional information, see the Cash Sweep Program Disclosure Statement, which we provided to you when you opened your Account. For additional information about the Cash Sweep Program, including information about how we and our affiliates benefit from the Cash Sweep Program, see the Cash Sweep Program. Compensation Compensation from Investment Advisors. We receive training and education payments from many of the companies whose ETFs we sell for conducting comprehensive training and education for Associates. Wells Fargo Advisors may receive different training and education payments from ETF product sponsors depending on the training and education activities provided. From time to time, ETF product sponsors will reimburse us for expenses in connection with conducting training and educational meetings, conferences or seminars for Associates and customers. Also, Associates may receive promotional items, meals or entertainment or other "noncash" compensation from product sponsors. Although training and education compensation is not related to individual transactions or assets held in Client Accounts, it is important to understand that, due to the total number of companies whose products are offered by us, it is not possible for all the product sponsors affiliated with each company to participate in a single meeting or event. Consequently, those product sponsors who participate in training, an educational meeting, seminar or other event gain an opportunity to build relationships with Associates that could lead to additional sales of the sponsor's ETF products. ETF sponsor policies can be found in an ETF's prospectus, which is available on request from the ETF product sponsor. While we offer a wide variety of ETFs for our Associates to sell or recommend, we reserve the right in the future to limit branch access to ETF sponsors. We work with certain ETF providers to provide aggregated sales data, and we receive varying payments each year for data agreements. Our affiliates may receive compensation for making a market and keeping an inventory of select ETF offers. They may also have an investment banking relationship with ETF issuers. Differing Compensation. The additional compensation received from ETF sponsors varies. The additional compensation poses a conflict of interest as it offers us a financial incentive to select one fund or a fund from one fund sponsor over a similar fund due to the compensation we retain from one fund or fund sponsor versus another. This could also result in an increase in your cost as a result of us recommending a more expensive ETF. We intend, however to make all recommendations independent of such financial considerations and based solely on our obligations to consider your objectives and needs. Page 8 of 21 593718 (Rev 25 - 03/26)  We do not pre-condition the recommendation of ETFs for inclusion in the Program based on any compensation we may receive. In addition, Wells Fargo is a full-service financial services firm with many affiliates. Wells Fargo encourages its subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual business planning, business with our affiliates is included in establishing our sales goals. As a result, we may have an incentive to hire affiliate service providers for our advisory Programs. We intend, however, to make all recommendations independent of any such goals and based solely on our obligations to consider your objectives and needs. Financial Advisor Compensation. Financial Advisors serving Program Accounts are compensated by salary and discretionary performance bonus. For these Financial Advisors, their discretionary bonus is based on a number of factors including company performance and individual performance which takes into consideration a variety of factors including telephony metrics and production metrics such as funded accounts and net asset flows, client referrals to Wells Fargo Bank, N.A. for trustee or investment management services, and client usage of lending products and affiliated banking products such as deposit and checking accounts with Wells Fargo Bank, N.A. Rollovers. If you are rolling over assets from an employer-sponsored Qualified Retirement Plan ("QRP"), such as a 401(k), to an Individual Retirement Account ("IRA") with us, you should carefully evaluate all choices which are typically available. These four options include: leaving your assets in your former employer's plan (if permitted), rolling over the assets to your new employer's plan (if permitted), rolling your assets to an IRA with us or another firm, or cashing out the Account value. You should consider the following factors, among others, in deciding whether to keep assets in a QRP, roll over to an IRA or cash out: investment options, fees and expenses, ability to make penalty-free withdrawals and differences in creditor protection. We have a conflict of interest in connection with a rollover of your assets into an IRA and the investment of the assets with us as opposed to leaving the assets in your former employer's plan or electing one of the other options. The conflict arises because we will likely earn no compensation if you were to leave the assets in your former employer's plan or transfer to your new employer's plan. In addition, the costs of maintaining and investing assets in an IRA with us will generally involve higher costs than the other options available to you. While we typically offer a broader range of investment options and services than an employer-sponsored QRP, there are no guarantees that the additional investment options will outperform your employer-sponsored QRP. The online process for opening an Intuitive Investor Account does not provide any recommendations or advice with respect to the rollover or transfer of any retirement Account or IRA to Intuitive Investor. Account Termination You or we may terminate a Program Account by notifying the other party in writing of the Program Account to be terminated and termination will become effective upon the receipt of the notice. If a Program Account is terminated, we will make a pro-rata refund to you of fees paid to us pursuant to the Agreement for the period after the date of effectiveness of such termination through the end of the then current fee period. Termination of the Account will not affect either your or our responsibilities under this agreement for previously initiated transactions or for balances due in the Program Account upon termination. If for any reason you are not satisfied with the Program, you are entitled within 90 days of Account opening to terminate your Program Account and be credited for any portion of the Program Fee that you have paid. Please note: this will not refund market losses. Upon termination, you may, but are not required to, request that we liquidate your Account. You should also keep in mind that the decision to liquidate Program Assets may result in tax consequences that should be discussed with your tax advisor. We are not responsible for market fluctuations in your Account from time of written notice until complete liquidation. Your request to liquidate securities upon termination of this Agreement is not considered a market order, since both we and/or the Manager require time to process your request. All efforts will be made to process the liquidation in an efficient and timely manner. It may take several business days under normal market conditions to process your request. Should the necessary securities markets be unavailable and trading suspended, efforts to trade will be done as soon as possible following their reopening. Upon Termination, your Program Account will become a brokerage Account. If securities remain in the brokerage Account after termination, neither the Manager nor WFA and our affiliates will provide any investment recommendations or ongoing investment management, nor will we give advice or offer any opinion with respect to the suitability, profitability, or appropriateness for you of any security, investment, financial product, or investment strategy. You will be solely responsible for determining whether a security transaction or strategy is suitable for you. All transactions will be done only on your order or the order of your authorized delegate, except as otherwise provided in the Program Agreement. Further, upon the termination of your Program Account, your assets will be subject to all fees and charges normally assessed by WFA and/or its agents on its standard brokerage Accounts. Class Action Services Beginning January 2025, all WFA accounts will be automatically enrolled in the Class Action Service also described in the Client Agreement. The Class Action Service authorizes WFA to automatically file a claim on your behalf if WFA receives notice of a class action lawsuit that impacts securities purchased in your Account. The terms of the Class Action Service apply to your Account unless you have opted out. You are not obligated to continue to use the Class Action Service and you may opt out at any time by contacting us at 1-800-TRADERS. The Class Action Service is a separate administrative service, is not part of the advisory services included in any Advisory Program and WFA does not act in an advisory capacity when making this service available to you. WFA will not provide legal advice regarding your participation in any class action. Broadridge Investor Communication Solutions, Inc. ("Broadridge") administers the Class Action Service and, in exchange for administering the Class Action Service, Broadridge will retain ten percent (10%) from any class action settlement payment received on your behalf. The remainder of the class action settlement payment will be credited to your Account and will be subject to the Page 9 of 21 593718 (Rev 25 - 03/26)  fees described in your Client Agreement and the Program Features and Fee Schedule incorporated into your Client Agreement. In cases where WFA elects not to submit a claim for any class action for which you are otherwise entitled to submit a claim, WFA will notify you in writing in advance of the submission deadline and provide you with the individual class action notice so you may submit a claim directly to the claims administrator if you so choose. You are encouraged to carefully review the complete terms and conditions of the Class Action Service, which can be found in the Client Agreement, or to contact us should you have questions. Account Requirements and Types of Clients Account Requirements A minimum initial Account value of at least $500 is required. Under certain circumstances the Account minimum may be waived. We may terminate your Account with notice if they fall below minimum Account value guidelines established by us. To participate in the Program, you must establish a Program Account and enroll in the Program electronically through the Program Website. Types of Clients We provide the advisory services described in this brochure generally to individuals, through taxable or retirement Accounts, and trusts. Portfolio Manager Selection and Evaluation Our affiliate, WFII, has created nine Globally Diversified ETF portfolios that are available within the Program. These Portfolios are built based on specified investment objectives, risk/return profiles and/or targeted asset allocations. For all available portfolios, the allocation targets are generally based on longer-term risk/return assumptions for various asset classes or investment strategies and may change from time to time in light of new research and analysis. The asset allocation guidelines and risk/return objectives are selected such that the Conservative Income model would be expected to generally have the lowest long-term investment risk, based on historical average risk levels, but also the lowest expected return. As an investor moves to models with higher allocations in equities or other higher-risk assets, historical averages suggest that expected investment risk and potential return increase. A description of the Portfolios can be found in the "Methods of Analysis, Investment Strategies and Risk of Loss" section. WFII uses both quantitative and qualitative criteria when evaluating the potential inclusion, combinations and weights of ETFs in a Portfolio. WFII will typically arrange meetings with Portfolio Managers or representatives of an ETF sponsor to discuss the underlying investment philosophy of the fund manager and how that philosophy is manifested in security buy, sell and weighting decisions. They also seek to understand the capabilities of the Portfolio Manager, and assess how the investment philosophy will perform in different market environments. Additional factors influencing the inclusion and weight of an ETF within a portfolio may include a statistical analysis of the fund's past risk/return profile; complementary nature; expense ratios; assessed capacity and liquidity levels; tracking error versus specified indexes; the assessed quality of the investment process; changes in investment process or personnel; the number, continuity and experience of the investment professionals; a completed questionnaire, database information on the firm and interviews with members of the management team. This process is a continuing one, and ETFs may be added or removed from the Program based on these ongoing assessments. You are aware that ETF replacements in a Portfolio may cause tax consequences. WFA and WFII use information, financial data, and investment research from a variety of sources to evaluate ETFs. We believe the information we collect on funds is reliable and accurate, but we do not necessarily independently review or verify it on all occasions. The stated investment objectives and/or allocation guidelines for the Portfolios provide the general basis by which they will be managed. We modify the allocations and/or selected ETFs when we believe it is in the interests of our investors to do so. Other than in connection with our consulting responsibilities, we do not assume responsibility for the ETFs that we select, including their performance or compliance with laws or regulations. You are advised and should understand that: An ETF's past performance is no guarantee of future results; • • There is a certain market and/or interest rate risk which may adversely affect any ETF's objectives and strategies, and could cause a loss in your Account; and • Client risk parameters or comparative index selections provided to us are guidelines only; there is no guarantee that they will be met or exceeded. You should also be aware that shares of any particular ETF may fluctuate in value and when sold may be worth less than their original cost. There is no guarantee that your Program Portfolio will protect against such loss of investment. Our reasons for removing an ETF may include its failure to adhere to expected investment objectives or a given management approach, a material change in the professional staff managing the fund, unexplained poor performance, a change of the investment management process, or the identification of a better alternative. We will, at our sole discretion, determine whether any or all of these factors are material when deciding to make a replacement. WFII meets as necessary to make appropriate changes to the current asset allocation recommendations. We will review these recommendations and apply them to the Portfolios, as appropriate. We may give advice and take action in the performance of our duties to you that differ from advice given, or the timing and nature of action taken, with respect to other Program Clients and/or Clients in other advisory Programs. Additionally, we, from time to time, Page 10 of 21 593718 (Rev 25 - 03/26)  may not be free to divulge or act upon certain information in our possession on behalf of investment banking or other confidential sources. Services Tailored to Individual Client Needs All of our investment recommendations for Program Accounts are based on an analysis of your individual financial needs. They are drawn from research and analysis we believe to be reliable and appropriate to your financial circumstances. Each of the advisory services we offer is tailored to a specific type of investor and designed to meet their individual investment objectives, financial needs and tolerance of risk. A detailed description of these Programs is provided in the "Services, Fees and Compensation" section. Client Restrictions and Instructions We will comply with any reasonable instructions and/or restrictions you give us when making recommendations for your Account, including the designation of securities that should not be purchased or held in the Account. • If we believe that the restrictions are unreasonable or inappropriate, we will notify you that, unless they are modified, we may remove your Account from the Program. • You will not be able to provide restrictions that prohibit or restrict the purchase or sale of securities by the investment advisor of an ETF. • If you wish to restrict more than one of the ETFs in a particular asset class, we may remove your Account from the Program. Our policy is generally to liquidate your existing securities portfolio immediately in newly established Program Accounts and reinvest the Account in conformity with your target allocations. If you wish to hold certain positions for tax or investment purposes, you should consider holding these positions in a separate Account. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees in any of our investment advisory Programs. We do not have any side-by-side management situations. Methods of Analysis, Investment Strategies and Risk of Loss The Intuitive Investor Program offers nine investment objective-based Globally Diversified portfolios. Globally Diversified portfolios Globally Diversified portfolios combine traditional market-capitalization-weighted ETFs intended to provide low-cost core portfolio exposures with complementary smart beta or enhanced-index ETFs within select asset classes to increase exposures to factors/ characteristics that can potentially enhance longer-term risk and return outcomes. The factors used by smart beta ETFs for screening and weighting purposes are often related to relative measures of quality, volatility, valuation, momentum, and other metrics focused on enhancing overall diversification. The individual and combined factor-related metrics and screening employed by smart beta ETFs can be similar to select screening employed by active managers in an attempt to add value over a traditional market-cap-weighed passive approach. However, because the screening/weighting approaches employed by smart beta ETFs are systematic in nature and designed to replicate broad market factor-tilted indices, their relative expenses remain low in comparison to actively managed alternatives. In combination, the portfolios selected ETFs and weightings are intended to provide a relatively low-cost approach, but with the potential for enhanced outcomes (compared to employing only a traditional market-weighted passive approach) while maintaining the relative cost efficiencies and other potential benefits of an all-ETF portfolio. Though the intention is to enhance potential longer-term outcomes relative to more traditional size-weighted passive approaches, it should be recognized that the differences in weighting methodologies can result in periods of both significant outperformance and underperformance for particular or combined smart beta ETFs versus corresponding broad market indices. Below are descriptions of the nine investment objective-based portfolios that are available in the Program. Income: Portfolios emphasize current income with minimal consideration for capital appreciation and usually have less exposure to more volatile growth assets. • Conservative Income: Conservative Income investors generally assume lower risk, but may still experience losses or have lower expected income returns. • Moderate Income: Moderate Income investors are willing to accept a modest level of risk that may result in increased • losses in exchange for the potential to receive modest income returns. Aggressive Income: Aggressive Income investors seek a higher level of returns and are willing to accept a higher level of risk that may result in greater losses. Growth & Income: Portfolios emphasize a blend of current income and capital appreciation and usually have some exposure to more volatile growth assets. • Conservative Growth & Income: Conservative Growth and Income investors generally assume a lower amount of risk, but may still experience losses or have lower expected returns. • Moderate Growth & Income: Moderate Growth and Income investors are willing to accept a modest level of risk that may result in increased losses in exchange for the potential to receive modest returns. • Aggressive Growth & Income: Aggressive Growth and Income investors seek a higher level of returns and are willing to accept a higher level of risk that may result in greater losses. Page 11 of 21 593718 (Rev 25 - 03/26)  Growth: Portfolios emphasize capital appreciation with minimal consideration for current income and usually have significant exposure to more volatile growth assets. • Conservative Growth: Conservative Growth investors generally assume a lower amount of risk, but may still experience increased losses or have lower expected growth returns. • Moderate Growth: Moderate Growth investors are willing to accept a modest level of risk that may result in significant • losses in exchange for the potential to receive higher returns. Aggressive Growth: Aggressive Growth investors seek a higher level of returns and are willing to accept a high level of risk that may result in more significant losses. Program Website Tool Methodology The suggested asset allocation strategy generated by the Program Website Tool ("Tool") is based on your answers to the questionnaire, which is comprised of a series of questions regarding, among others, your investment objective, risk tolerance, investment time frame, and liquidity. The Tool selects the suggested asset allocation strategy from one of 9 possible investment objectives. After a recommended investment objective is provided, you will then have the option to move forward with that recommendation or select an investment objective that is one step lower or one step higher on our risk scale. The asset allocation strategies for each of the 9 investment objectives are based on Wells Fargo Investment Institute's (WFII's) Capital Market Assumptions ("CMAs"). The CMAs are estimates of the expected 10- to 15-year risk and return for each asset class within the prescribed allocations. They reflect the trends that WFII believes are most likely to affect investments in the coming years given the assessment of key economic and market drivers, appropriate historical context, and trends that we expect to develop over time. The assumptions are reviewed annually by WFII and are subject to change as conditions vary. Such assumptions are not a prediction or guarantee of returns or performance that may be realized and are subject to inherent limitations. The suggested asset allocation strategies are proprietary to Wells Fargo and intended to be implemented only in conjunction with an Intuitive Investor Account. You are the one to decide whether to act on the suggested asset allocation strategy by opening and funding an Intuitive Investor Account. Tool Updates and Responsibility for Information Provided. We will periodically update the Tool, which could include changes to the questions and modifications to the scoring methodology that generates the recommended asset allocation strategy. Your asset allocation strategy will not update automatically when we update the Tool. Results generated by the Tool after an update may be different, even if your answers are the same or similar to what you provided previously. Your updated results should be considered in place of any previous results. The results provided by the Tool depend upon the accuracy of the information you provide. Wells Fargo is not responsible for the accuracy or appropriateness of the information you provide. Limitations on the Use of the Tool. The Tool's analysis does not consider the effects of taxes, fees, and/or expenses associated with investing. The Tool should not be considered as legal or tax advice. Please consult a tax professional to review the suggested asset allocation strategy, its fees, and tax consequences prior to making an investment decision. Risk Considerations and Disclosures. You are under no obligation to accept the asset allocation strategy suggested by the Tool. You should carefully consider all of your options, as well as your other assets and investments before opening an Intuitive Investor Account and investing in the suggested asset allocation strategy. As your financial circumstances or goals change, consider revisiting the Tool. Wells Fargo is not responsible for reviewing your financial situation, and the Tool's investment advice should not be considered comprehensive in regards to your financial situation. There is no guarantee that any particular asset allocation strategy and its underlying funds, paired with an Intuitive Investor Account, will ensure your ability to meet any of your investment goals or provide you with income. Asset allocation strategies and diversification do not guarantee a profit or protect against loss. All investing involves risk including the possible loss of principal. An investment in a fund will fluctuate, and shares, when sold, may be worth more or less than their original cost. Risk of Loss. All investments shall be at your risk exclusively and we do not guarantee any return on the investments recommended or advised upon. We will not be responsible for losses resulting from the management of your Account. The Program includes investment risks, including possible loss of principal. Voting Client Securities and Corporate Actions Proxy Voting Practices Unless you decide to opt out, by the terms of the Client Agreement, you authorize proxies for securities in your Account to be voted as described in this section. You may rescind authorization to us and retain such authority for yourself. Your request to rescind will be effective upon our receipt and processing of your written request. Wells Fargo's Wealth & Investment Management division ("WIM") has established the WIM Proxy Committee ("Committee"). The Committee's primary objective is to ensure that proxies are voted in a manner that is in the best long-term economic interest of the Client. The Committee is comprised of members representing the advisory and fiduciary services businesses that make up WIM — WFCS, Wells Fargo Advisors Financial Network, LLC, WFII, Wells Fargo Bank, N.A., and the Wells Fargo Delaware Trust Company, N.A. The Committee has retained a third-party proxy voting administration firm ("Proxy Voting Administrator") that is responsible for processing proxy votes and applying the Independent Fund Voting Policies (described below) to the proxy votes in your Account. For regulatory compliance purposes, neither WFA, WIM nor the Committee will provide voting instruction or influence on the proxies of any securities issued by funds registered under the Investment Company Act of 1940 (including mutual funds, closed- Page 12 of 21 593718 (Rev 25 - 03/26)  end funds, UITs and ETFs) (“Funds”). Therefore, proxies for all securities in your Account will be voted under policies developed by an independent third-party proxy voting advisor (“Independent Fund Voting Policies”). The Independent Fund Voting Policies are selected by the Committee. We will not under any circumstances override or seek to influence the development of application of Independent Fund Voting Policies. We reserve the right to instruct the Proxy Administrator to replace the Independent Fund Voting Policies if deemed necessary, and with at least 90-days (calendar days) notice to the Proxy Administrator (described further below) prior to their implementation of the change. You can obtain the current Independent Fund Voting Policies at www.ejproxy.com/methodology and selecting "Wealth-Focused Policy” or by contacting the team of Financial Advisors that are available to service your Account. Conflicts of Interest. The Proxy Administrator applies and process proxy votes for securities in your Account in accordance with the Independent Fund Voting Policies. Conflicts of interest are thus addressed by our removal from the vote processing and proxies in your Account are voted under the voting policies of a third-party rather than those of the Committee. Directing Individual Proxy Votes. We do not permit Clients to instruct us on how to vote their securities for a particular proxy proposal. If you want to ensure that a proxy is voted in a particular manner, you should retain voting authority for yourself in which case you will be responsible for all proxy voting for your Account. Obtaining Information on Voting. You may obtain information about how your securities were voted at by contacting the team of Financial Advisors that are available to service your Account. Rescinding Authority To Vote Securities in Your Account You may rescind authorization to vote proxies at any time by submitting your written request to revoke. Your request will be effective upon our receipt and processing of your written request to rescind. If you rescind such authorization, you will be responsible for voting all proxies for the securities held in your Account. Accounts Subject to ERISA and Internal Revenue Code Section 4975 For Accounts subject to ERISA or Section 4975 of the Internal Revenue Code, the same voting practices described herein will be applied when exercising shareholder rights on securities in such Accounts. You are responsible for reviewing and monitoring the Independent Fund Voting Policy. If you determine that the Independent Fund Voting Policies are not appropriate for your plan based on its investment objectives and investment horizons, you should assume responsibility for exercising shareholder rights. Further, if your plan determines that consideration of factors such as effects of climate change and other environmental or social considerations, are appropriate when voting the securities in your plan, you should review the Independent Fund Voting Policy, which is selected with the intent that proxies will be voted in the best long-term economic interests of the client for whom this service is being performed. Voluntary Corporate Actions Voluntary corporate actions will not be responded to. Client Information Provided to Portfolio Managers When completing the Risk Tolerance Questionnaire, we will ask you to provide information about your investment objectives, financial circumstances and risk tolerance. Based on this information, we will make a recommendation using research and analysis we reasonably deem to be reliable. We may share this information with the Manager. • We will contact you at least annually to update your information and indicate if there have been any changes in your financial situation, investment objectives or restrictions. • It is your responsibility to inform us of any material change in your financial circumstances that might affect the manner in which your assets should be invested. Failure to do so could affect the suitability of the services that we are providing to you. We will act on any changes deemed to be material or appropriate as soon as practical after we become aware of the change. Client Contact with Portfolio Managers We will make our investment advisory and support personnel reasonably available for consultation with you if you request. You can request assistance by phone at (855) 283-5567. Additional Information Disciplinary Information We are both a broker-dealer and investment advisory Firm. The disciplinary events listed below are related to the activities of the broker-dealer, investment advisor, or predecessor firms. For more information on broker-dealer related disciplinary events you may visit: http://www.finra.org/Investors/ToolsCalculators/BrokerCheck/ . Our investment advisory disciplinary history is available by going to: http://www.adviserinfo.sec.gov/. In May 2025, WFCS entered into a settlement with FINRA regarding allegations that WFCS failed to establish and maintain a supervisory system, including written supervisory procedures, reasonably designed to safeguard customer information by failing to notify insurance carriers when certain employees departed WFCS resulting in these former employees having access to WFCS client information through insurance carrier portals, in violation of SEC Regulation S-P and FINRA and NASD rules. Without admitting or denying the findings, WFCS consented to a settlement that included a censure and fine of $150,000. Page 13 of 21 593718 (Rev 25 - 03/26)  In January 2025, WFCS and Wells Fargo Advisors Financial Network ("WFAFN") agreed to a settlement with the SEC regarding allegations that they failed to adopt and implement written policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder relating to their cash sweep program, specifically, their use of a bank deposit sweep program. The order found that WFCS and WFAFN did not adopt and implement reasonably designed policies and procedures that considered the best interests of clients when evaluating and selecting which cash sweep program options to make available to clients, including during periods of rising interest rates; or addressed the duties of WFCS and WFAFN financial advisors in managing client cash in advisory accounts, in willful violation of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder. WFCS and WFAFN, without admitting or denying the findings, consented to a settlement that included a cease and desist order, censure, and civil money penalty of $28 million by WFCS and $7 million by WFAFN. In August 2023, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC (collectively, the "Firm") agreed to a settlement with the SEC regarding allegations that from at least 2002 through December 2022, the Firm and its predecessor firms overcharged approximately 10,945 accounts of advisory clients, for accounts opened through 2014, for more than $26.8 million in advisory fees and failed to adopt and implement written compliance policies and procedures reasonably designed to prevent the overbilling in willful violation of Sections 206(2) and 206(4) of the Investment Advisers Act of 1940 and Rule 206(4)-7 thereunder. Specifically, from at least 2002 through 2014, certain investment adviser representatives from Wells Fargo and its predecessor firms agreed to reduce the firms' standard, pre-set advisory fee rate for certain clients at the time these clients agreed to open accounts. The representatives made handwritten or typed changes on the clients' standard investment advisory agreements that reflected the reduced fee rate. However, in certain instances, the account processing employees at Wells Fargo and its predecessor firms failed to enter the agreed-upon reduced advisory fee rate into the firms' billing systems when setting up the clients' accounts. In 2022 and 2023, the Firm corrected the advisory fees to be charged to the accounts and issued payments for the overcharged advisory fees, plus interest, to the affected account holders. Without admitting or denying the findings, the Firm consented to a settlement that included a cease and desist order, censure and civil money penalty of $35,000,000. In December 2021, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that for more than three years beginning in November 2016, the Firm failed to store 13 million records, pertaining to 8.2 million customers, related to its anti-money laundering Customer Identification Program (CIP) in the required non-erasable and non-writable “Write Once, Read Many” (WORM) format in violation of Exchange Act Rule 17A-4(F)(2)(II) (A) and failed to notify FINRA prior to using the non-WORM compliant storage platform in violation of Exchange Act rules 17A-4(F) (3)(V) and 17A-4(F)(2)(I). Without admitting or denying the findings, the firms consented to a settlement that included a censure and fine, jointly and severally, of $2,250,000. On August 27, 2020, Wells Fargo Clearing Services, LLC agreed to a settlement with FINRA regarding allegations that the Firm failed to reasonably supervise the activities of two former registered representatives, thus violating its own written supervisory procedures along with NASD Rule 3010(a) and FINRA Rules 3110(a) and 2010. Between November 2012 and October 2015, the two representatives recommended that many of their customers invest a substantial portion of their assets in four high-risk energy securities, which generated multiple red flags regarding over concentration and suitability in their customers' accounts that the firm failed to reasonably investigate. The Firm has previously compensated 67 clients over $9.7 million for losses in these investments. Without admitting or denying the findings, the Firm agreed to a settlement that included a censure, a fine of $350,000 and restitution in the amount of $201,498 plus interest to additional specified clients. On February 27, 2020, the Securities and Exchange Commission ("Commission") entered an order against Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC, following the Firms' offers of settlement. The Commission found that, from April 2012 through September 2019, the Firms recommended that many retail investment advisory clients and brokerage customers buy and hold single-inverse exchange-traded funds ("ETFs") without having adequate compliance policies and procedures and without providing financial advisors proper training and supervision of single-inverse ETFs. The Commission found that, as a result, certain investment adviser representatives and registered representatives made unsuitable recommendations to certain clients. The Commission found that the Firms willfully violated Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder, failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 203(e)(6) of the Advisers Act and failed reasonably to fulfill their supervisory responsibilities within the meaning of Section 15(b)(4)(E) of the Exchange Act. The Firms consented, without admitting or denying the findings contained in the Order, to: cease and desist from committing or causing any violations and any future violations of Section 206(4) of the Advisers Act and Rule 206(4)-7 thereunder; be censured; and jointly and severally pay a civil and monetary penalty in the amount of $35,000,000. In 2018, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC elected to participate in the Securities and Exchange Commission's Mutual Fund Share Class Selection Disclosure Initiative ("SCSD Initiative"). The SCSD Initiative provided investment advisers with the opportunity to voluntarily self-report to the SEC's Division of Enforcement possible securities law violations related to the adequacy of their disclosures concerning mutual fund share class selection and fees received pursuant to Rule 12b-1 under the Investment Company Act of 1940. As part of the SCSD Initiative, the Firms reviewed disclosures and activities related to mutual fund share class selection within advisory programs. At the conclusion of the SCSD Initiative, the Firms jointly and severally consented to a settlement agreement alleging violations of Sections 206(2) and Section 207 of the Investment Advisers Act of 1940 and entry of an order under which the Firms were censured, agreed to cease and desist from committing further violations, and agreed to pay disgorgement and prejudgment interest totaling $17,363,847.29. The SEC did not impose a fine or civil monetary penalty in recognition of the fact that the Firms self-reported. In December 2017, Wells Fargo Advisors agreed to a settlement with the State of Illinois Securities Department regarding allegations that it received, reviewed and/or analyzed documents and information from a financial advisory firm concerning certain money manager strategies that contained information that was later found to be false and misleading. The findings stated that we Page 14 of 21 593718 (Rev 25 - 03/26)  included the financial advisory firm's money manager strategies in certain of our externally managed Separately Managed Account Programs, but that we did not utilize inaccurate historical performance data in connection with our decision to on board the money manager strategies and we did not incorporate inaccurate performance data in our advertisements or Program marketing materials. Without admitting or denying the findings, the Firm agreed to a total monetary payment of $270,000. On December 21, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to maintain approximately one million electronic brokerage records in non-erasable and non-rewritable format, which is intended to prevent the alteration or destruction of broker-dealer records stored electronically. The findings also stated that for approximately 1.5 million accounts, the Firm failed to preserve customer account form templates containing the terms and conditions related to the opening and maintenance of accounts, failed to retain certain communications and failed to notify FINRA at least 90 days prior to using new storage media to store electronic broker-dealer records. FINRA also found that the Firms failed to implement an audit system for those records, failed to provide its third party vendors full access to the storage systems, failed to implement an adequate supervisory system and failed to enforce written procedures. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,500,000. The Firms also consented to a review of its policies and procedures. On December 5, 2016, Wells Fargo Clearing Services, LLC and Wells Fargo Advisors Financial Network, LLC agreed to a settlement with FINRA regarding allegations that the Firms failed to establish, maintain and enforce reasonable supervisory systems for the use of consolidated reports generated by their registered representatives through available applications. The findings stated that these applications allowed the Firm's representatives to manually enter information regarding customers' external accounts, assets and liabilities into a centralized table which the Firms maintained. This information would then be used to populate reports, including those that would be sent to the Firms' customers. FINRA found that the Firms did not have systems in place to review the contents of the reports, including information about customer holdings away from the Firms. In addition, the Firms supervisory systems and procedures were inadequate because there was no mechanism allowing representatives to designate which reports were actually provided to customers and the system could not distinguish between draft reports and completed reports that were sent to customers, which should have been subject to the Firms' supervisory systems designed to review customer communications. Without admitting or denying the findings, the Firms agreed to a censure and fine, jointly and severally, of $1,000,000. Other Financial Industry Activities and Affiliations We are a national securities firm providing investment and other financial services to individual, corporate and institutional Clients. We are a registered broker-dealer and investment adviser. WFCS is a member of all principal stock exchanges in the United States, including the New York Stock Exchange and NASDAQ. WFCS is also a member of the Financial Industry Regulatory Authority ("FINRA") and the Securities Investor Protection Corporation ("SIPC"). We may also route Client transactions through its affiliate, Wells Fargo Securities, LLC. Unless otherwise stated as the case, the investment advisory services offered and the underlying stock, bonds, mutual funds and other securities bought or sold through us are not deposits of any bank and are not insured or otherwise protected by the Federal Deposit Insurance Corporation ("FDIC") or another government agency. They are not obligations of any bank or any affiliate of us; are not endorsed or guaranteed by Wells Fargo, WFA, or any bank or any affiliate of us; and involve investment risk including possible loss of principal. Cash balances in Client Accounts may be held in a depository product sponsored by Wells Fargo Bank, N.A. Wells Fargo Clearing Services, LLC is not an FDIC-insured depository institution; FDIC deposit insurance only protects against the failure of an insured depository institution. Banking products and services provided by Wells Fargo Bank, N.A. Member FDIC. Our obligations and commitments do not extend to any affiliated bank or thrift, and any such bank or thrift is not responsible for securities we sell or purchase. As a general matter, unless otherwise stated, we may be a principal or engaged in underwriting securities for which we are providing broker, advisory or other services to our Clients. We may also purchase those securities from an affiliate or sell them to an affiliate. In addition, we or our affiliates may act as an investment adviser to issuers whose securities may be sold to you. From time to time, a bank or thrift affiliated with us may lend money to an issuer of securities underwritten or privately placed by us. The prospectus or other offering documentation provided in connection with such underwriting or private placement will disclose to the extent required by applicable securities laws: The existence of any material lending relationship by any affiliate of ours with such an issuer and • • Whether the proceeds of an issuance of such securities will be used by the issuer to repay any outstanding indebtedness to any of our affiliates. We have a number of related persons who may provide investment management and related financial services to our advisory Clients. The advisory services these investment advisers offer are described more fully in their Disclosure Documents and/or Form ADV, Part 2A. The identity of these related persons and summary of the products and services follows. • Wells Fargo Advisors Financial Network, LLC is an affiliate of WFA that also provides retail brokerage and investment advisory services. • Wells Fargo Investment Institute, Inc. (known prior to November 1, 2014 as Alternative Strategies Group, Inc. and before that as Wachovia Alternatives Strategies, Inc.) is a registered investment adviser and wholly owned subsidiary of Wells Fargo Bank, N.A. that provides advisory services and research to WFA. Page 15 of 21 593718 (Rev 25 - 03/26)  Certain cash sweep vehicles that we offer as part of our Cash Sweep Program may also be used by our affiliates. The rate of return paid when invested in these cash sweep vehicles with our affiliates could be greater than the rate of return paid when invested in these cash sweep vehicles with WFA. Material Relationships with Allspring Wells Fargo sold the Wells Fargo Asset Management business in 2021 and the new owners renamed the business Allspring Global Investments. The Wells Fargo Asset Management business was wholly owned by Wells Fargo prior to the transaction and included the following companies: Wells Capital Management Incorporated; Wells Fargo Funds Management, LLC; Wells Fargo Asset Management (International), LLC; Wells Fargo Funds Distributor, LLC; and, Galliard Capital Management, Inc. These companies, which are no longer related persons of WFCS, served as adviser, sub-adviser, and distributor of the Wells Fargo Funds and certain of the companies managed separately managed account strategies offered through WFCS. Allspring Global Investments (“Allspring”) is the trade name used by the asset management businesses of Allspring Global Investments Holdings, LLC. This group of companies includes Allspring Funds Management, investment adviser to mutual funds within the Allspring family of funds, Allspring Funds Distributor, LLC, the principal underwriter of Allspring mutual funds, and Allspring Global Investments, LLC, a model portfolio strategy provider and an investment adviser to pooled investment vehicles and separately managed accounts. Wells Fargo has no role in the management of Allspring. However, Wells Fargo retains less than a 10% equity ownership interest in Allspring and has continued to provide certain non-advisory transition services to Allspring for a fee since the close of the sale. WFCS also receives compensation from Allspring for the distribution, administrative and operational services that we provide to the Allspring mutual funds. Although Allspring is not a related person of WFCS, WFCS and its related persons continue to benefit from the sales of these products to a greater extent than the sale of other third-party products in which we do not have a similar financial interest. Wells Fargo’s equity ownership in Allspring and the agreements by WFCS and its related persons to provide ongoing services to Allspring for a fee provide us with a financial incentive to continue to recommend to our clients products that are managed and distributed by Allspring, including mutual funds, sweep vehicles, and separately managed account or model portfolio strategies. WFII charges Allspring research access fees for investment research services that WFII provides to Allspring. Allspring manages the Managed DSIP, Managed DSIP II, ESG Managed DSIP, Current Equity Income, and Income Multi Asset Portfolio strategies offered through WFA’s Personalized Unified Managed Account advisory program (collectively, the “Equity Income Strategies”) utilizing information derived, in part, from certain of the research services. The research access fees are calculated based on the assets invested in the strategies, meaning that WFII earns more money when more assets are invested in the strategies. The research access fees are assessed at rates that result in WFII receiving fees that are equivalent to substantially all of the Manager fees assessed in conjunction with the Income Multi Asset Portfolio, the Current Equity Income Strategy, and the Managed DSIP strategy, and approximately half or greater of the Manager fees assessed for the Managed DSIP II strategy and the ESG Managed DSIP strategy. The fee paid to WFII is for research services WFII provides to Allspring, including: investment research that WFII provides to Allspring; and access to certain WFII research analyst teams, strategists, and associates to discuss the research and/ or obtain additional research commentary on covered names, insights into sectors, etc. (collectively “Research Services”). While WFII does not provide the Research Services to other third-party Managers for utilization in managing strategies, WFII does provide the Research Services to its affiliates, WFCS and WFAFN, who in turn, may utilize the Research Services to manage strategies and who provide the investment research at no cost to WFCS and WFAFN advisory clients, WFCS and WFAFN brokerage customers, and prospective clients and customers for their individual use. As such, investors in the Equity Income Strategies are indirectly paying for investment research that others receive at no cost, and that those same investors could receive from WFCS or WFAFN for their individual use outside of the Equity Income Strategies at no cost under other circumstances. Similar investment research may be available in the marketplace at no cost or for materially lower fees than are being charged to Allspring in conjunction with the Equity Income Strategies. WFII’s receipt of a research access fee in conjunction with the Equity Income Strategies creates a material conflict of interest since it results in WFII, an affiliate of WFCS, earning more revenue when investors follow a WFCS recommendation to invest in the Equity Income Strategies than WFCS, WFII or their affiliates would earn if investors followed a recommendation from WFCS to invest in any of the other Model Manager strategies available through the Personalized UMA Program as WFCS and its affiliates earn no comparable additional revenue for investments in other Model Manager strategies. WFCS seeks to mitigate this conflict and its associated implications through disclosure, management of the financial incentive for financial advisors to recommend the Equity Income Strategies, and evaluation of the total costs of investing in the Equity Income Strategies relative to other Model Manager strategies. You should carefully consider the research access fee that is retained by WFII and our related conflict of interest when evaluating whether to invest in the Equity Income Strategies. The Equity Income Strategies are available through Wells Fargo Bank, N.A., including through Wealth & Investment Management Trust Services, and no research access fee is applied to assets invested in the Equity Income Strategies when the assets are custodied at Wells Fargo Bank, N.A. The research access fee is also not applied to assets invested in ERISA accounts. Access to Research. WFII also provides research and strategy recommendations to other affiliates of WFA and within other Programs offered. While all the affiliates have similar access to the research, due to the operation differences, manner and size of the advisory programs, certain affiliates may be able to implement and trade on these recommendations prior to another affiliate. The ability to implement and trade on these recommendations first, may give the clients of one affiliate an advantage over clients of other affiliates. Page 16 of 21 593718 (Rev 25 - 03/26)  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Our Associates are subject to a Code of Ethics that is designed to ensure our business activities are performed with the highest possible standards of ethics and business conduct, and to comply with all applicable laws, rules, and regulations that govern our businesses. Key requirements of our Code of Ethics are summarized below. • Conduct all aspects of Wells Fargo's business activities in an honest, ethical, and legal manner, and in accordance with all applicable laws, rules, and regulations and our policies and procedures. • Provide accurate and complete information in dealings with Clients and others, including disclosure of conflicts of interest when they exist. Prepare and maintain accurate business records. • • Refrain from improper disclosure or misuse of confidential Client information and material, non-public information. Wells Fargo protects the private, personal, and proprietary information of Clients and others. Avoid conflicts of interest in personal and business activities. Rules specific to personal trading. • • Participation or Interest in Client Transactions Under the Program, we are generally appointed as sole and exclusive broker by you for the execution of transactions. The Program fee covers transaction costs when transactions are executed through us. For these transactions, we may act as agent or, where permitted by law, principal (including when we are acting as underwriter or selling group members). We may effect and execute brokerage transactions, including on a national exchange, as permitted by current provisions of Section 11(a) of the Securities Exchange Act of 1934, as amended (the "Exchange Act") and rules promulgated thereunder including any future amendments or changes to such statutes and rules. For more information see the "Brokerage Practices" section. Relationships with Publicly Traded Companies. We or our affiliates may have investment banking or other relationships with certain publicly traded companies. These relationships may from time to time require us to restrict trading in the securities of these companies. As a result of these investment banking or other activities, our affiliates may acquire confidential or material non-public information that may prevent us or our affiliates, for a period of time, from purchasing, selling or recommending particular securities for your Account. We and our affiliates are not permitted to divulge or to act upon this information with respect to our advisory or brokerage activities. Additionally, we may be restricted or limited in our ability to purchase or sell particular securities or make investment recommendations as a result of these affiliated activities. Policies, Restrictions, and Training. We have certain restrictions, internal procedures, and client disclosures regarding conflicts of interest that we may have with respect to our participation or interest in client transactions. We communicate our policies and procedures related to participation in Client transactions to our Associates through compliance policies and procedure manuals and program-specific policy guidelines. Personal Trading We have policies and procedures to mitigate conflicts of interest between your transactions and those in the personal investment Accounts of our associates and their immediate family members. To ensure associate trading requirements are observed: Certain associate trading activity is subject to pre-approval. All associates are subject to regular review by their supervisors and independent oversight by our Compliance Department. Systemic controls are used to automatically restrict entry of certain orders and generate related surveillance reporting. • • • Review of Accounts Program services include review and monitoring of your Account by our personnel and facilities. Through the Website, we will provide you with Account information which will include a calculation of your Account's performance. Confirmations and Statements. We will provide you with the following: Trade confirmations reflecting all transactions in securities A statement of Account activity at least quarterly • • These documents will be delivered to you electronically. Prospectus Delivery The Manager is authorized to accept on your behalf delivery of prospectuses for funds registered under the Investment Company Act of 1940 (including ETFs). If the Manager accepts delivery of prospectuses on your behalf, WFA and the Manager will generally not deliver a prospectus directly to you unless you request one. You may obtain a prospectus at any time by contacting the team of Financial Advisors that are available to service your Account. Notwithstanding the authorization described in this paragraph and apart from any requests you may make for a prospectus, WFA or the Manager may, in its sole discretion, choose to deliver prospectuses directly to you. Page 17 of 21 593718 (Rev 25 - 03/26)  Client Referrals and Other Compensation From time to time, we initiate incentive Programs for our Associates, including FAs. Incentive programs compensate our Associates and FAs for attracting new assets and Clients, referring business to our affiliates (such as referrals for banking services and accounts, mortgages, lending, trusts, or insurance services) or other FAs, promoting investment advisory services and promoting green initiatives (such as raising Client awareness of paperless options). We may also initiate Programs that reward FAs who meet total production criteria, length of service requirements, participate in advanced training and improve client service. FAs who participate in these incentive programs may be rewarded with cash and/or non-cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. Portions of these programs may be subsidized by external vendors and/or our affiliates, such as mutual fund companies, insurance carriers or investment advisers. Therefore, FAs and other Associates have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services we offer. We also enter into arrangements with other persons to whom we pay compensation for referrals to our advisory Programs. This compensation is generally in the form of a percentage of the fees described in the Program contracts. The details of such arrangements and the amount of compensation will be described in a separate disclosure provided at the time of such referrals. Additionally, we also compensate employees of Wells Fargo Bank, N.A. for referrals to WFA. From time to time, we compensate Associates other than FAs for referrals of possible Clients to the Programs. Our FAs, not the referring Associate, will make the actual presentation and solicitation of these services. The referral compensation takes the form of a payment to the Associate of a percentage of the fees described in the Programs' contracts and results in no additional fees to you or other Clients. Wells Fargo & Company is a full-service financial services firm with many affiliates. Wells Fargo & Company encourages its subsidiaries to use the products and services offered by affiliated firms, when appropriate. During the course of annual business planning, business with our affiliates is included in establishing our sales goals. As a result, we have an incentive to hire affiliate service providers for our advisory Programs. We recommend affiliated mutual funds to Program Clients, and hire other affiliates to provide trade execution, clearing and platform administration services for the Programs. We intend, however, to make all recommendations independent of any such goals and based solely on our obligations to consider your objectives and needs. Brokerage Practices As described in the Services, Fees and Compensation section, above, Advisory Accounts will be invested in portfolios comprised of ETFs. Orders will be routed to execution venues, including through our affiliate Wells Fargo Securities, LLC (through which a majority of such trades are routed) with best execution being the highest priority. We consider a number of factors when determining where to send Client orders, including execution speed and price, price improvement opportunities, the availability of efficient and reliable order-handling systems, the level of service provided, and the cost of executing orders. when transacting large aggregated orders of ETFs, we may utilize non-affiliated third-party Authorized Participants ("APs"). APs are typically large institutions like market makers or specialists who can create ETFs by trading the underlying securities. For this Program, the terms of the Client Agreement instruct that WFA will be used for execution of purchases and sales of securities for your Account. Directing brokerage through WFA may result in transactions in your Account receiving less favorable execution than could be obtained using a broker-dealer other than WFA. Not all investment advisers require their clients to direct brokerage. We may aggregate orders involving multiple Program Accounts trading in the same ETF. These transactions are not subject to any markups, markdowns, or dealer spreads. WFA will not favor any one particular client over another, and clients whose accounts participate in such aggregated transactions will participate at the average share price for transactions in the block order. Fractional Shares. In addition to purchasing whole ETF shares for your Advisory Account, we will facilitate purchases and sales of fractional ETF shares on your behalf, where doing so is required to ensure that the Advisory Account is allocated in accordance with the selected Portfolio. WFA will facilitate purchases and sales of fractional shares for Client Accounts on an agency basis by allocating excess fractional shares to a trade along account maintained by WFA. The trade along account will enable WFA to aggregate client orders to purchase or sell fractional shares such that they may be placed in the market as transactions in whole shares. WFA reserves the right to limit or stop facilitating transactions in fractional shares or to change its policies and procedures that pertain to transactions in fractional shares, including but not limited to its allocation and rounding procedures, at any time without prior notice to its clients. Fractional shares are typically unrecognized and illiquid outside of the Advisory Account. As a result, fractional shares are not transferrable to another account. In the event you request a transfer or liquidation of the assets in your Advisory Account, we will convert the fractional shares held in the Account to cash. However, if your Advisory Account is terminated pursuant to the terms of your Agreement, the fractional shares held in your Advisory Account will continue to be held in the standard brokerage account to which it reverts, and will be subject to the terms governing fractional share trading set forth in the brokerage account agreement, including the purchase and sale of fractional shares on a principal basis. Dividends will be allocated pro-rata based on the fractional shares held in your Advisory Account. Principal Trades. We do not execute principal trades or agency-cross transactions in Accounts enrolled in this Program. Trade Corrections. If WFA is responsible for a trade processing error, it is WFA's policy to correct the issue as soon as possible and return the Account to the economic position that it would be in absent the error. If correction processing generates a shortfall to the Account, we make the Account whole by paying the shortfall. If correction processing generates an overage (i.e., an amount in excess of what would be in the Account if the error did not occur), WFA retains the overage. Page 18 of 21 593718 (Rev 25 - 03/26)  Margin Loans and Securities-Based Loan Programs You may be eligible to use margin in your non-retirement Accounts or pledge your non-retirement Account assets as collateral for margin loans ("Margin Loans"). You may also be able to pledge your non-retirement Account assets as collateral for loans obtained through certain affiliated and unaffiliated loan programs ("Securities-Based Loan Programs"). It is important that you fully understand the costs, risks, and conflicts of interest involved in pledging your Account assets for a Margin Loan or Securities- Based Loan. Margin Loans Certain Advisory Programs may permit margin borrowing and trading. We will not extend margin in an advisory account unless authorized by you through a separate Margin Account Agreement. You are responsible for notifying us if you decide that you no longer want to use margin in your Account. You may also discontinue use of margin in your Account according to the terms of the Client Agreement. We are not responsible for any losses resulting from our failure or delay in implementing such instructions. Margin Loans Are Subject to Separate Terms and Conditions. If you take out a Margin Loan, the terms and conditions applicable to the Margin Loan are governed by the Margin Account Agreement, Margin Disclosure Statement and the Client Agreement. You should review carefully the terms, conditions, and risk disclosures for Margin Loans and understand that such risks are heightened in the event you hold a concentrated position in your pledged Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investable assets. Certain eligibility requirements must be met, and documentation in the form of a separate Margin Account Agreement must be completed prior to using margin. Costs Are in Addition to Advisory Fees. As discussed above, if you use margin to purchase additional securities, your Account Value increases and therefore the amount of fees you pay will increase. You will also be charged margin interest on the debit balance in your Account, which is in addition to the Program Fee. This results in additional compensation to us. Interest rates for Margin Loans and Securities-Based Loans have different features and eligibility criteria. The interest charged on a Margin Loan is generally higher than the interest charged on affiliated Securities-Based Loans, including WF Bank PCL and WFA PCL. We Have an Incentive to Recommend the Use of Margin. The increased asset-based fee and interest that you pay on a Margin Loan provides an incentive for your Financial Advisor to recommend the use of margin. Your Financial Advisor also has an incentive to use margin to purchase additional securities and other assets instead of selling existing securities or other assets. We address these conflicts by disclosing them to you. Margin Loans May Not Be Suitable for You. Using margin is not suitable for all investors. As described in the next paragraph, the use of margin increases leverage in your Account and therefore increases risk to a portfolio. We generally believe the use of margin is most appropriate when short in duration. Before deciding to use margin, you should consider the intended duration and total cost of the Margin Loan, as well as other options available to you, such as alternative loan options or liquidating your Account assets. Using Margin Involves Higher Risks. Generally, we believe that the use of margin adds risk to a portfolio that you should not assume unless you are prepared to experience significant losses. Losses in the value of an asset purchased on margin will be magnified because of the use of borrowed money. You can lose more funds than amounts deposited in margin accounts. In addition, you generally will not benefit from using margin unless the performance of your Account exceeds interest expenses on the Margin Loan plus advisory fees incurred. You should also understand that the use of margin can negatively impact our ability to rebalance your account. You should carefully consider whether the additional risks are appropriate prior to using margin due to the increased potential for significantly greater losses associated with using margin. You assume full responsibility for the use of margin in your Account. Please see the Margin Disclosure Statement and the Client Agreement for more details on the risks of margin use. You should read this documentation carefully. Securities-Based Loan Programs You may pledge your Account assets as collateral for Securities-Based Loan Programs with our consent and where you are eligible under the programs. The Securities-Based Loan Programs include, but are not limited to, the WF Bank Priority Credit Line ("WF Bank PCL"), offered by Wells Fargo Bank, N.A. ("Wells Fargo Bank") in partnership with Wells Fargo Advisors, the Priority Credit Line ("WFA PCL") from Wells Fargo Advisors and various Securities-Based Loan Programs from our affiliate Wells Fargo Bank. The Secured PrimeLine program, offered by Wells Fargo Bank is available only in limited circumstances. The availability of these Securities-Based Loan Programs may vary over time. In order for your Account to be eligible to serve as collateral for a Securities-Based Loan, your Account may not also serve as collateral for a Margin Loan. If you wish to use your Account as collateral for a Securities-Based Loan, we will automatically discontinue the availability of margin for your Account. There are risks, costs, and conflicts of interests associated with Securities-Based Loan Programs. You are encouraged to speak with your Financial Advisor to the extent you have questions about how your Account may be used in connection with a Securities- Based Loan Program and how such arrangement should be taken into consideration when discussing the management of your Account. Securities-Based Loan Programs Are Subject to Separate Terms and Conditions. If you have elected to participate in a Securities-Based Loan Program, the terms and conditions applicable to that Securities-Based Loan Program are governed by the applicable Securities-Based Loan documents and other service agreements and are not included or described further in this brochure. You should review carefully the terms, conditions and any related risk disclosures for the Securities-Based Loan Program and understand that risks are heightened in the event you hold a concentrated position in your pledged Account or if your pledged Account makes up all, or substantially all, of your overall net worth or investable assets. You should understand that WF Bank PCL, WFA PCL and other Securities-Based Loans that are "securities contracts" under the Bankruptcy Code provide more favorable protection for the lender (WFA or Wells Fargo Bank) in the event of your bankruptcy Page 19 of 21 593718 (Rev 25 - 03/26)  than other loan programs through us. Certain eligibility requirements must be met and documentation must be completed prior to obtaining Securities-Based Loans. Interest Rates for Securities-Based Loan Programs Differ. Interest Rates for Securities-Based Loan Programs are different and have different features and eligibility criteria. More than one Securities-Based Loan Program may be available to you. The interest rate charged for one offering may be higher than interest rates available through another lender or offering. Costs Are in Addition to Advisory Fees. The costs, including interest, associated with a Securities-Based Loan Program are not included in the Program Fee and will result in compensation to WFA, our affiliate, and our Financial Advisors. The interest charges on your Securities-Based Loan Program, combined with the Program Fee, may exceed the income generated by your pledged Account assets and, as a result, the value of your Account may decrease. You are encouraged to consider carefully the total cost of taking out a Securities-Based Loan, and any additional compensation that WFA and your Financial Advisor will receive, when determining to take out and/or maintain a Securities-Based Loan against your Account assets. Financial Advisors Receive Compensation on Securities-Based Loans. In addition to receiving a portion of the Program Fee, Financial Advisors also receive compensation based on the outstanding loan balances of WF Bank PCL, WFA PCL and other Securities-Based Loan Programs from Wells Fargo Bank. The Financial Advisor's compensation is reduced if the interest rate on WF Bank PCL, WFA PCL or other Securities-Based Loan from Wells Fargo Bank is discounted below a certain level, which creates an incentive for the Financial Advisor to not request for you or to discourage interest rate discounts below a certain level. We Have an Incentive to Recommend the Use of Securities-Based Loan Programs. Since WFA and your Financial Advisor are compensated through asset-based advisory fees paid on your Account, we benefit if you draw down on your Securities-Based Loan, which preserves asset-based advisory fee revenue and generates additional loan-related compensation, rather than sell securities or other investments in your Account, which would reduce the assets in your Account and our asset-based advisory fee revenue. This presents a conflict of interest for your Financial Advisor when addressing your liquidity needs. In addition, where a Securities-Based Loan is secured by both brokerage and advisory assets, a Financial Advisor will benefit if your brokerage assets are liquidated prior to or instead of your advisory assets because the Financial Advisor would be able to maintain advisory Account assets subject to the Program Fee. We address these conflicts by disclosing them to you. Securities-Based Loan Programs May Not Be Suitable for You. There are other lending products that may be suitable for you and for which we and your Financial Advisor would receive different or no compensation. You are responsible for independently evaluating if a Securities-Based Loan is appropriate for your needs, if the lending terms are acceptable, and whether the Securities-Based Loan will have potential adverse tax or other consequences for you. There Are Limitations on the Use of Securities-Based Loan Proceeds. Except for margin accounts, where the loan proceeds can be used to purchase, carry, or trade securities, the proceeds of the other Securities-Based Loans available from Wells Fargo Bank or WFA may not be used to: purchase, carry, or trade securities (or margin stock in the case of loans offered by Wells Fargo Bank); or reduce or retire any indebtedness incurred to purchase, carry, or trade securities (or margin stock in the case of loans offered by Wells Fargo Bank). If your Account is used as collateral for a Securities-Based Loan, the Account is pledged to support the Securities-Based Loan and you are not permitted to withdraw funds or other assets from your Account unless sufficient amounts of collateral remain to continue supporting the Securities-Based Loan (as determined under the applicable Securities-Based Loan Program). Although you are required to satisfy such collateral requirements, you can terminate your advisory relationship with WFA, at which time the funds and assets in your account will be treated as a brokerage account at WFA and the collateral requirements for the Securities-Based Loan will continue to apply. Additional Considerations Associated with Pledging Advisory Account Assets for Margin Loans and Securities-Based Loans In addition to the risks mentioned above, if your Account assets are pledged or otherwise used as collateral for Margin Loans or Securities-Based Loans, the exercise of the lender's (WFA or Wells Fargo Bank) rights and powers over your Account assets, including the disposition and sale of any and all assets pledged as collateral, may be contrary to your interests and the investment objective of your Account. There Are Collateral Maintenance Requirements. When you use margin to purchase securities or draw down on a Securities-Based Loan, your Account assets serve as collateral. For Margin Loans, WF Bank PCL, WFA PCL and some other Securities-Based Loans from Wells Fargo Bank, the lender can increase the maintenance requirements or call the loan at any time and for any reason, and is not required to provide you with advance written notice (although these approaches will be different for other loan programs from Wells Fargo Bank, and may be different for loans from unaffiliated lenders). If your Account assets decline in value, so does the value of the collateral. If the required collateral is not maintained, you may need to deposit additional cash or securities as collateral or repay a partial or the entire amount of the funds borrowed on short notice. You are not entitled to an extension of time on a maintenance call. The lender may refuse to fund any advance request due to insufficient collateral. Where the lender assigns different advance rates to different asset types, you may be able to satisfy collateral maintenance requirements by selling securities with a low advance rate and investing and/or holding the proceeds in assets that have a higher advance rate for the loan. Liquidation of Securities in a Maintenance Call. Failure to promptly meet requests for additional collateral or repayment, or other circumstances including but not limited to a rapidly declining market, will cause the liquidation of some or all of the collateral supporting any Margin Loans or Securities-Based Loans in order to meet the maintenance requirements. The lender can sell your Account assets without contacting you. Neither the lender nor WFA are required to notify you of a maintenance call. The details and timing of how the lender handles a maintenance call will be different for other loan programs from Page 20 of 21 593718 (Rev 25 - 03/26)  Wells Fargo Bank, and may be different for loans from unaffiliated lenders, but with Margin Loans and Securities-Based Loans, you will be responsible for any shortfall if your Account assets are insufficient to cover the maintenance deficiency. Even if the lender has notified you and provided a specific date by which you can meet a maintenance call, the lender can still take necessary steps to protect its financial interests, including immediately selling your Account assets without notice to you. You should understand that because your Account assets are collateral for the Margin Loans or Securities-Based Loans, in selling such assets, the lender will seek to protect or advance its interests over your interests. You should expect that the lender's interests will not be aligned with—and will be adverse to—your interests when the lender sells assets during a maintenance call, and that the lender may sell assets that you desire to keep or sell them at prices that may be less than the value that we or you believe the assets are worth. You are not entitled to choose which Account assets are liquidated or sold to meet a maintenance call. If there are Account assets that you desire to own during the term of your Margin Loan or Securities-Based Loan, you should not pledge them as collateral. Depending on market circumstances, the prices obtained for your Account assets may be less favorable and may be less than the value that we or you believe the assets are worth. If a maintenance call cannot be fully satisfied from your Account assets, you remain liable for the outstanding debt. Impact of Maintenance Calls on Management of Your Account. In a maintenance call, the lender might liquidate Account assets that you, your Financial Advisor, or your Manager otherwise would not sell, and that might not otherwise be in your best interests to sell, and you will not get to choose the assets that are liquidated. We or a third-party Manager will seek to manage your Account as agreed under your advisory Client Agreement and applicable Program Features and Fee Schedule, provided that, if a maintenance call takes place, you should expect that we or your Manager will not be able to manage your Account consistent with our or the Manager's overall strategy. In addition, in order to preserve sufficient collateral value to support the loan and avoid a maintenance call, depending on your leverage, a Financial Advisor may be inclined to invest your Account in more conservative investments, which may result in lower investment performance than more aggressive investments (depending on market conditions). We mitigate this risk by requiring and monitoring to ensure that your Account is managed consistent with your respective investment strategies. No Legal or Tax Advice. WFA, our affiliates and your Financial Advisor do not provide legal or tax advice. You should consult with your own legal counsel and independent tax advisor before using securities as collateral for loans in order to fully understand the tax implications associated with pledging your Account as loan collateral and the potential liquidation of pledged assets. Financial Information We have no financial condition that is likely to impair our ability to meet our contractual commitments to you. Page 21 of 21 593718 (Rev 25 - 03/26)