Transamerica Retirement Advisors LLC

Item 5 - Fees and Compensation
TRA offers its defined benefit retirement plan asset allocation advice as part of a standard package of services from TRS,
which may include recordkeeping, administrative, communications, and technical services for defined benefit retirement
plans. Fees for discretionary and non-discretionary asset allocation advice are negotiable by the plan sponsor, and depend
on the amount of assets and other factors. In general, TRA’s fee for asset allocation advisory services typically ranges from
0.05% to 0.25% of assets and will be structured as a percentage of assets or a fixed dollar amount. In some cases, the TRA
advisory fee may be bundled with other services as part of a total bundled fee. In those cases, TRA will be compensated
for its services from that overall bundled fee. This means that TRA’s fee for advisory services will be included in a bundled
fee that also covers recordkeeping, administration, and other services provided by TRS and/or AUIM to the defined benefit
plan. For all services provided, TRA and/or its affiliates receive a fee, often referred to as the “minimum required revenue,”
which is agreed to by the client.

TRA’s fees are typically accrued daily and payable monthly in arrears, although clients may from time to time negotiate
alternative payment schedules. TRA will either send an invoice for the advisory fee or be authorized by the client to deduct
the fee directly from the client’s account through the plan trustee, which holds client funds as a qualified custodian. TRA will
deduct advisory fees only when the client has provided written authorization permitting automatic payment of the fees from
the plan’s account. Defined benefit clients will receive quarterly trustee account statements. All statements received from
the plan trustee should be reviewed for accuracy.

Defined benefit clients bear the costs of the plan trustee acting as custodian of assets. Because TRA’s clients invest in
mutual funds and CITs, client accounts will also bear the fees and expenses of these underlying investment vehicles.
Investment options underlying our asset allocation advice may include funds that are sponsored and/or managed by TRA
affiliates (“affiliated funds”) and funds sponsored or managed by unaffiliated third parties (“third party funds”).

With respect to third-party funds, TRA’s affiliates typically receive administrative, shareholder servicing, sub-transfer
agency, and/or distribution fees from such funds held in a client’s account. These fees received are credited back to the
client’s account by TRA’s affiliates and, for clients using a “percent of assets” pricing structure, the minimum required
revenue (as discussed above) will be automatically netted against those credits to ensure a “levelized” fee structure across
all plan assets. TRA and its affiliate recordkeeper will bill the client’s account for their fees who elect a flat fee pricing
structure.

For affiliated funds, TRA affiliates will receive advisory, service, and/or distribution fees. If the affiliated funds are selected
within a client’s plan and the plan is subject to the minimum revenue calculation described above, the client’s account
receives a credit based on a fund margin calculation, which is TRA’s “retained revenue” as described below. TRA has an
incentive to recommend a higher investment allocation to affiliated funds because affiliates receive additional revenue.
However, we believe this potential conflict of interest is mitigated because TRA credits the “retained revenues” against its
advisory fee. With respect to affiliated funds, retained revenues are revenues received by TRA’s affiliates from an affiliated
fund minus (i) any amount contributed to the fund in accordance with a fee waiver or expense reimbursement arrangement,
and (ii) any fees paid to third-party sub-advisers for services provided to the fund. TRA believes this fee credit mitigates the
incentive to allocate assets to affiliated funds. In addition, TRA, through its affiliates, provides clients with a disclosure
statement of all fees that TRA or its affiliates expect to receive from the funds held in the client’s account.

Clients may be able to purchase investment products available on TRS’s retirement plan platform through brokers or agents
who are not affiliated with TRA. However, clients should consider the bundle of asset allocation advice, recordkeeping,
administration, communications, and technical services provided in connection with the purchase of investment products
through TRS’s retirement plan platform.

Advisory agreements with defined benefit plan clients to provide asset allocation services may be terminated by the client
at any time and by TRA after a reasonable notice period, which is negotiated with each client. Any fees will be accrued and
paid only through the date of termination of the agreement.

Transamerica Retirement Advisors, LLC                                                          March 31, 2026

Advisor Compensation. TRA Portfolio Strategists earn a salary and can also earn a bonus. In addition, TRA conducts
programs under which its Portfolio Strategists may be eligible to receive non-cash awards and other non-cash benefits.
Such programs are not based on sales activities. The payment of a bonus does not change the fees that plan sponsors of
defined benefit plans pay for advisory services. TRA Portfolio Strategists may also be eligible to receive non-cash awards
through gifts and entertainment. They are required to disclose any non-cash awards received through gifts and
entertainment within the firm. This information is reviewed by sales supervision and compliance as needed.

Set forth below is a description of conflicts related to compensation paid to TRA and its Portfolio Strategists.

        TRA earns an advisory fee for the advisory services it provides. When a plan sponsor engages TRA to provide
...

Item 7 - Types of Clients
TRA provides investment advisory services solely to defined benefit plan clients through its Defined Benefit Services. These
advisory services may also be offered as part of an affiliate’s bundled retirement plan product, which includes recordkeeping,
administrative, communications, and/or technical services to retirement plans. The minimum dollar amount of assets
generally required to provide TRA investment advisory services to defined benefit plan clients is $2 million. The minimum
dollar amount generally required for defined benefit plan clients receiving advisory services through the Solution is $25
million, with at least $50 million of total retirement plan assets held at Transamerica.

Transamerica Retirement Advisors, LLC                                                           March 31, 2026