Mutual of America Capital Management LLC

Item 5       Fees and Compensation

The following describes how Capital Management is compensated for the investment advisory services
it provides. For a detailed description of those services, please refer to Item 4 of this brochure, titled
“Advisory Business.”

I.   MoA Funds

     For providing investment advisory services to MoA Funds, Capital Management receives a daily fee
     at an annual rate of:
          0.05% of the value of the net assets of each of the twelve Target Date Funds;
          0.075% of the value of the net assets of the Equity Index Fund, the Mid Cap Equity Index
             Fund, the Small Cap Equity Index Fund, the Large Cap Value Index Fund and the Large
             Cap Growth Index Fund;
          0.15% of the value of the net assets of the US Government Money Market Fund and the
             Catholic Values Index Fund;
          0.75% of the value of the net assets of the Small Cap Growth Fund and the Small Cap
             Value Fund;
          0.55% of the value of the net assets of the Mid Cap Value Fund and the Mid Cap Growth
             Fund;
          0.40% of the value of the net assets of the All America Fund, the Balanced Fund,
             International Fund and the Intermediate Bond Fund;
          0.39% of the value of the net assets of the Core Bond Fund; and
          0.25% of the value of the net assets of the Inflation Focused Bond Fund.

     The three Allocation Funds can invest in any equity fund or fixed income fund of MoA Funds. The
     individual Allocation Funds are not charged a direct management fee; however, each does incur a
     proportionately weighted average of the management fees charged by the underlying funds in which
     they invest.

     The Target Date Funds invest in other funds of MoA Funds, except for the other Target Date Funds

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    and the Allocation Funds. The Target Date Funds can invest in any equity fund or fixed income fund
    of MoA Funds. The daily management fee incurred by each Target Date Fund is the proportionately
    weighted average of the management fees of the underlying funds in which it invests plus a 0.05%
    management fee charged by Capital Management for rebalancing, reallocation and administrative
    services.

II. Institutional Clients

    A. Separately Managed Account Clients

        Capital Management’s fees are set forth in the client’s investment advisory agreement.
        Generally, the investment advisory fees (assuming at the initiation of the advisory agreement a
        minimum portfolio of $10 million for fixed income portfolios and a minimum portfolio of $5 million
        for equity portfolios) are as follows:

        Fixed Income
                 Assets under Management
                 First $50 million                           30 bp
                 Thereafter                                  25 bp

        Equities – Active Small Cap
                  Assets under Management
                  First $10 million                          90 bp
                  Next $30 million                           85 bp
                  Thereafter                                 75 bp

        Equities – Active Mid Cap
                  Assets under Management
                  First $10 million                          60 bp
                  Next $40 million                           50 bp
                  Thereafter                                 40 bp

        Equities – Active Large Cap
                 Assets under Management
                 First $10 million                           45 bp
                 Next $15 million                            40 bp
                 Next $25 million                            35 bp
                 Thereafter                                  30 bp

        Equities – Indexed
                  Assets under Management
                  First $10 million                          10 bp
                  Next $40 million                            8 bp
                  Thereafter                                  5 bp

        In certain circumstances, fees may be subject to negotiation. Fees referred to above for
        Institutional Clients do not include custodial charges and may differ from the above schedules
        depending upon a particular client’s investment objectives, policies and restrictions. Clients will
        incur brokerage and other transaction costs and incidental costs. Clients will also incur custodial
        charges, depending on the particular arrangement with their custodian. Item 12 of this brochure,
        titled “Brokerage Practices,” discusses our brokerage practices further.

    B. Asset Allocation Clients

        Capital Management’s fees for its asset allocation services are set forth in the client’s asset

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       allocation advisory agreement. Effective January 2024, new clients who are not subject to
       ERISA, are charged a minimum advisory fee of 15 bp for Capital Management’s asset allocation
       services. Fees may be negotiated or modified in our discretion. Capital Management does not
       charge an advisory fee for its asset allocation services to clients that had an asset allocation
       advisory agreement in place for asset allocation services prior to January 2024.

       Capital Management is the investment adviser to each of the MoA Funds and receives
       investment management, administration, and other fees for services provided to the MoA
       Funds, as described in the Prospectus and SAI available on the MoA Funds website
       (https://moafunds.com/). Capital Management does not waive these fees for any asset
       allocation clients. Capital Management is subject to conflicts of interest in providing the
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Item 7       Types of Clients

We provide investment advisory services to registered investment companies (mutual funds); to
Institutional Clients (including pension and profit-sharing plans, state and local government retirement
plans, endowments and foundations, charitable organizations, tribal organizations, pooled investment
vehicles and other institutional investors); and to Mutual of America’s general account. We also provide,
to certain Institutional Clients, asset allocation services among the MoA Funds.