Members Capital Advisors Inc

Fees and Compensation
We receive negotiable fees for (a) most unaffiliated clients based on a flat amount or an
amount that ranges from .10% to 1.00% annually of the market value of assets managed and
(b) for affiliated clients based on an internal cost allocation. For unaffiliated clients, among the

March 31, 2026, SEC File No. 801-18140

MEMBERS Capital Advisors, Inc.
d/b/a TruStage Investment Management

factors that could affect the level of fees is the nature of our engagement, account size, the
composition of assets and the complexity of the preferences and objectives of the client. Fees
or investment advisory services are generally billed monthly or quarterly in arrears depending
on the nature of the engagement and are typically non-refundable.

Clients could be responsible for other expenses for operating their investment portfolio,
including custodial fees, unitization fees, brokerage expenses and investment-related costs
(e.g., mutual fund expenses). All brokerage transactions are affected through broker/dealers
that are not affiliated with us; and we receive no compensation in connection with the
brokerage transactions we effect for client accounts. See the Brokerage Practices section of
this brochure for additional information on brokerage.

Performance-Based Fees and Side-by-Side Management
Neither we nor any of our supervised people accept any performance-based fees (e.g., fees
based on a share of capital gains on our capital appreciation of the assets of a client).

Types of Clients
Our principal business is to provide investment management and advisory services to our
affiliated companies, other financial institutions, pension plans, and profit-sharing plans.

Methods of Analysis, Investment Strategies and Risk of Loss
Qualified Plan Investment Consulting
Under the marketing name TruStage Fiduciary Consultants, investment advisory services are
provided to ERISA-qualified retirement plans as follows:

Defined Contribution Programs
Initial work involves advice to clients regarding, creation and adoption of an Investment Policy
Statement (“IPS”). The IPS will contain details regarding the asset classes that may be offered
by the plan, the structure of the investment menu, and the general criteria that will be utilized
during selection and periodic monitoring of each investment. Criteria could include general
characteristics such as manager tenure, fund history, and fees; risk characteristics such as
beta, standard deviation, and semi deviation; risk-adjusted return measures such as Sharpe,

March 31, 2026, SEC File No. 801-18140

MEMBERS Capital Advisors, Inc.
d/b/a TruStage Investment Management

Treynor and Information ratios; investment strategy; duration; style consistency; and
performance history versus the investment’s benchmark and, when relevant, peer averages.

After an IPS has been adopted by the plan’s trustees or investment committee, suitable
investments for each asset class will be assembled as a subset of the universe of investments
available on the recordkeeper’s platform and monitored by the TruStage Fiduciary Consultants
investment committee. When serving as an ERISA Section 3(21) investment advisor, MCA will
present investment alternatives to the plan’s trustees or investment committee for review and
final selection.

Mean/variance optimization is utilized when developing or recommending age- or risk-based
asset allocation models. For age-based models, the plan’s trustees or investment committee
will be asked to specify whether models are to run “to” or “through” the participants’ retirement
date. Custom age-based solutions that consider participant-level financial and demographic
factors could be recommended.

When we serve as an ERISA 3(38) investment manager, we will at our discretion select,
replace, or remove investments based on the criteria described in a standardized IPS. The
terms of the IPS are developed in advance and must be adopted by the plan’s trustees or
investment committee.

Defined Benefit Plans:
Initial work involves advice to clients regarding the creation and adoption of an Investment
Policy Statement (IPS) that articulates the plan’s investment strategy and investment selection
and monitoring criteria. Investment advice given to clients will be based on the plan sponsor’s
investment strategy, objectives, financial condition, risk tolerance, asset class preferences,
time horizon, liquidity needs, and risk/return expectations. Actuarial considerations such as the
plan’s funding ratio, structure of emerging and longer-term liabilities, and return assumptions
serve as important inputs. Current and forecast economic conditions can also influence the
investment advice provided or an investment strategy’s implementation timeline.
Recommended investment strategies can include emerging liability reserving, total returns,
liability-driven investing, and other strategies that are expected to meet the plan’s objectives.
Mean/variance optimization is often used to guide the plan’s trustees, or investment committee
regarding its asset allocation decisions when a total return strategy is adopted. A policy
portfolio allocation that is expected to meet the plan’s long-term objectives and
minimum/maximum allocation constraints for each major asset class can be determined and

March 31, 2026, SEC File No. 801-18140

MEMBERS Capital Advisors, Inc.
d/b/a TruStage Investment Management

enshrined in the plan’s IPS. Tactical adjustments away from the policy portfolio allocation may
be recommended from time to time as conditions warrant, but no adjustment may result in an
allocation to any single asset class outside of the minimum/ maximum constraint range for
longer than a reasonable period.

Analysis of the structure of a plan’s liabilities will be referenced when a liability- driven
investment strategy is adopted by the plan’s sponsor or investment committee. Plan assets are
allocated to hedging and return-seeking investments in weights determined by analysis of the
structure of the plan’s expected cash flows and liabilities.

The IPS can also contain details regarding the asset classes that may be used by the plan and
the specific criteria that will be utilized during selection and periodic monitoring of each
investment. Criteria could include general characteristics such as manager, tenure, fund
history, and fees; risk characteristics such as beta, standard deviation, and semi-deviation;
risk- adjusted return measures such as Sharpe and Treynor ratios; investment strategy;
duration; style consistency; and performance history versus the investment’s benchmark and,
when relevant, peer averages.

When serving as an ERISA Section 3(21) investment advisor, MCA provides advice to plan
trustees on an ongoing basis via periodic investment reviews provided by MCA. As
circumstances change, recommendations for adjustments to a plan’s investments or
investment strategy can be made based solely on the needs of the plan’s beneficiaries.

When serving as an ERISA 3(38) investment manager, we will, at our discretion, select,
replace, remove, or reallocate plan assets among investments based on the criteria described
in a standardized IPS. The terms of the IPS are developed in advance and must be adopted by
the plan’s trustees or investment committee.