VESTMARK ADVISORY SOLUTIONS, INC.

Vestmark Advisory Solutions, Inc. (VAS) provides sub-advisory services to independent financial advisors, including financial institutions, broker-dealers, registered investment advisors, and others who manage their own clients' accounts or portfolios. VAS performs these services under the guidance of the Financial Advisor and occasionally engages directly with the client under specific circumstances. VAS also offers Financial Advisors various advisory tools, including technology services and business process outsourcing services, which are selected at the discretion of the client's Financial Advisor. VAS's services include communicating and meeting with clients, designating custodians and broker-dealers, ensuring compliance with applicable rules, delivering brochures of participating managers, and providing tax-aware transition services. VAS receives a portion of the investment advisory fee from Financial Advisor clients for allocated assets in exchange for its services. As of December 31, 2023, VAS had $5,637,000,000 in total regulatory assets under management, including $3,684,000,000 in discretionary assets.

Vestmark Advisory Solutions, Inc. (VAS) offers two primary investment strategies: Direct Index strategies and strategies managed by external Managers. Direct Index strategies are managed through automation with a rules-based quantitative approach, focusing on active risk management and minimizing tracking error to the custom model. These portfolios are monitored daily to ensure adherence to client objectives, restrictions, and guidelines. For strategies managed by external Managers, VAS performs limited monitoring and approval of these Managers. Each Manager determines their own investment markets and securities within a strategy, resulting in unique risks. The decision to allocate client assets to a Manager's strategy is made by the Financial Advisor based on their own analysis and risk assessment.

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