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client experience, quality and efficiency of client Interactions, and adherence to corporate policies and regulatory <br />standards. Compensation paid to Agents or EAG representatives does not increase the fees paid by the plan, plan <br />sponsor or Members. <br />Item ISβ€” Cust Custody <br />EAG does not maintain actual custody of Its clients' cash, bank accounts, or securities. Pursuant to Rule 206(4)-2 of <br />the Advisers Act as amended, EAG Is deemed to have constructive custody with respect to certain client funds and <br />securities. This Is because an affiliated party is the custodian and directed or discretionary trustee of certain <br />retirement plan accounts. In addition to annual audits, these accounts, are subject to surprise custody verifications <br />by an Independent public accountant each year, as required by Rule 206(4)-2, If applicable, EAG's clients receive <br />periodic account statements (at least quarterly) from their custodian and should carefully review these statements. <br />Certain clients.may have assets held by unaffiliated custodians. _ <br />Item 16β€” Investment Discretion <br />EAG provides discretionary investment management services for those plan participants who enroll and participate <br />In the MA service; EAG does not offer or engage in discretionary investment services for either OIG or CIA, <br />The MA service is a professional, Flexible asset management program that utilizes data from the methodologies and <br />proprietary software program developed and employed by its IFE, Morningstar Investment Management. To <br />provide the MA service to plan participants, EAG retains discretionary authority over the allocation of available <br />Investment options without requiring prior approval of each transaction. All ongoing investment transfers and <br />Investment direction changes are implemented for plan participants enrolled in the Managed Account service. <br />Item 17β€” Voting Client Securities <br />EAG does not assume the responsibility to provide assistance or vote proxies or other issuer communications <br />regard Ing your Account, or to exercise voting or other decision -making authority regarding proxies or other Issuer <br />communications. Correspondence regarding the matters described in this section will be handled in connection <br />with the Plan's policies and service provider arrangements. <br />EAG, as a registered investment adviser', and as a matter of practice, does not accept authority to vote client <br />securities in connection with any of the services described in this Brochure. Correspondence regarding the matters <br />described in this section will be handled in connection with the Plan's policies and service provider arrangements. <br />Item 18 <br />Financial Information <br />As previously discussed, under certain circumstances EAG has discretionary authority over certain client funds and <br />securities. Accordingly, EAG is required to disclose information about its financial condition that is reasonably likely to impair its ability to meet contractual commitments to its clients. EAG has no financial commitment that impairs <br />its ability to meet contractual commitments to its clients, nor has EAG been the subject of a bankruptcy proceeding. <br />Further, EAG does not require or. solicit prepayment of fees in excess of $1,200 per client more than six months in <br />.advance. _ <br />19 <br />City Council 19 β€” 97 9/19/2023 <br />