Wilmington Trust Investment Management

Wilmington Trust Investment Management, LLC (WTIM) is a registered investment adviser established in 2005 and is a wholly-owned subsidiary of M&T Bank Corporation. WTIM specializes in offering investment advisory services through its Separately Managed Account Program, providing discretionary investment services to clients. Clients appoint WTIM to manage their assets on a discretionary basis, investing in various securities such as exchange-traded products, mutual funds, individual securities, and model portfolios. WTIM exercises full investment discretion over the selection of securities in each account. Clients can impose reasonable restrictions on their accounts, but WTIM reserves the right to decline unreasonable restrictions. WTIM charges an asset-based fee, with the standard fee schedule ranging from 1.10% for the first $3,000,000 of principal value to 0.45% for amounts over $20,000,000. Clients may also bear additional expenses related to mutual funds or ETFs held in their accounts. WTIM does not currently charge performance-based fees and does not engage in side-by-side management involving such fees. The firm's investment strategies involve asset allocation across various asset classes, utilizing fundamental, technical, and quantitative analysis methods. WTIM has recently settled an administrative proceeding with the Securities and Exchange Commission related to share class selection in its former Portfolio Architect Wrap Fee Program. The firm has agreed to cease and desist from committing violations, pay disgorgement, prejudgment interest, and a civil penalty, and comply with undertakings to notify affected investors. WTIM also discloses its affiliations with other financial entities within the M&T Bank Corporation structure, potential conflicts of interest, and its policies regarding client referrals, custody, investment discretion, and proxy voting.