Wilshire Advisors

Firm Description Founded in 1972, Wilshire Advisors LLC (“Wilshire” or the “Firm”) is a diversified financial services company registered as an investment adviser in the United States with the Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”), providing investment consulting and investment management services in conjunction with and through global operating affiliates. Wilshire is headquartered in Santa Monica, California, with approximately 307 employees in 9 offices. Biographical information on certain key personnel is contained in the supplement to this Brochure.

Principal Owners Wilshire is controlled by Monica Holdco (US), Inc. Monica Holdco (US), Inc. is in turn indirectly controlled by CC Monica Holdings, LLC, and Motive Monica LP (together with their respective affiliates, the “Owners”). CC Monica Holdings, LLC is advised by CC Capital, a private investment firm based in New York City. Motive Monica LP is advised by Motive Partners, a specialist private equity firm with offices in New York City and London.

Types of Advisory Services Wilshire provides diverse discretionary and non-discretionary investment advisory and management services and products to funds, accounts, investors, and intermediaries. Wilshire has assets under advisement1 of approximately $1,673,341,171,859 as of December 31, 2025, including approximately $74,531,924,600 in discretionary assets under management and $859,048,740 in non-discretionary assets under management.2 The amounts disclosed for, and the methodology used to calculate, assets under advisement and assets under management differs from that of our regulatory assets under management disclosed in Part 1A of our Form ADV. Wilshire assists clients (as described below) in developing and implementing an investment plan, primarily through the provision of three distinct, yet interrelated, services: (i) asset allocation, (ii) manager research, and (iii) portfolio construction. Each of the foregoing services may be provided separately or combined into a comprehensive service, which may also include helping clients to define their investment objectives, guidelines and/or risk parameters. In general, Wilshire does not provide investment management services in the context of managing a portfolio of individual securities or instruments, but instead provides customized allocations and portfolios focused on recommending specific third-party investment managers or investments in pooled investment vehicles advised by such third-party managers. Wilshire may, as part of implementing a discretionary investment management program as described herein, manage excess cash in a client’s portfolio through investments in cash equivalents and money market funds. Wilshire provides discretionary or non-discretionary investment management services to funds, accounts, investors, institutions, and financial intermediaries as follows:

Wilshire-sponsored funds for which either (i) Wilshire engages third-party investment managers (any third-party investment manager, an “External Manager”) to serve as sub-adviser to manage the investment portfolios, (ii) Wilshire directs fund investments into funds sponsored by third parties (“External Funds”), or (iii) Wilshire offers investors an opportunity to invest in specific investment opportunities in External Funds. Such sponsored funds include Wilshire’s private funds, Wilshire Private Assets Fund, the Wilshire Mutual Funds and Variable Insurance Trusts (VITs), the Wilshire Solutions Funds Trust, the Wilshire Institutional Master Funds, and Wilshire’s Collective Investment Trusts (“CITs”)

Separately managed accounts comprising direct fund investments into External Funds, allocation to External Managers, or other investment advice with respect to a client’s portfolio of External Funds

1 “Assets under advisement” refer to various consulting and advisory relationships for which Wilshire provides investment advisory services without

engaging, on either a discretionary or non-discretionary basis, in the direct management of a client’s portfolio, as well as assets under management (as defined below). 2 “Assets under management” refers to the amount of assets attributable to securities portfolios for which Wilshire provides discretionary and non-

discretionary asset management services and is calculated differently than “regulatory assets under management.”

Registered investment companies and External Funds for which Wilshire serves as sub-adviser with discretion over security selection, asset allocation and/or manager selection

External Funds for which Wilshire serves as non-discretionary sub-adviser, providing manager research and investment recommendations

Outsourced Chief Investment Officer (“OCIO”) services where Wilshire has the discretion to hire and terminate investment managers and rebalance portfolio assets

Model portfolios where Wilshire has discretion over the model

Wrap programs sponsored by third parties where Wilshire has discretion over security selection, asset allocation and/or manager selection (“Wrap Accounts”)

Retirement and pension plans where Wilshire has discretion over security selection, asset allocation and/or manager selection

Delegated consulting where Wilshire has the discretion to adjust the asset allocation of a portfolio to maintain a prescribed risk profile

Non-discretionary consulting where Wilshire provides advice and information concerning security selection, asset allocation and/or manager selection

As noted above, Wilshire-sponsored funds may also be sub-advised by one or more unaffiliated third-party investment managers to whom Wilshire delegates discretionary trading authority and who sub-advises the fund subject to a trading advisory agreement (“Trading Advisor”). The Trading Advisor will often have broad investment authority over the fund, subject to overall oversight and setting of the investment strategy and guidelines by, and certain rights of, Wilshire. Typically, a Trading Advisor is tasked with implementing an alternative investment strategy for Wilshire which is similar to strategies implemented by such Trading Advisor for one or more other accounts or funds already managed by such Trading Advisor. Despite this delegation of trading authority to the Trading Advisor, the trading strategy of the Wilshiresponsored fund will typically be modified by investment or risk guidelines or restrictions imposed by Wilshire. Such guidelines or restrictions may be developed in-house or customized on a case-by-case basis in consultation with the particular client for whom the Wilshire-sponsored fund was established or as determined by Wilshire. The strategies implemented, and the instruments used, by a Trading Advisor for a particular Wilshire-sponsored fund are more robustly described in such fund’s offering materials and/or the trading advisory agreement entered into with such Trading Advisor. References to “clients” throughout this Brochure refer to the above-mentioned funds, accounts, investors, institutions and financial intermediaries. Absent a separate advisory relationship with Wilshire, investors in funds, External Funds, and third-party feeder vehicles are not deemed to be Wilshire “clients” under the Advisers Act but are entitled to the rights and benefits described in the applicable disclosure documents, management agreements, limited liability company agreements, subscription agreements, and other applicable constituent documents. In providing each of its services, Wilshire takes into account each client’s risk tolerances and goals, which may include any legal or regulatory restrictions. Clients are provided with regular reports detailing Wilshire’s assessments or services to the extent applicable. Clients may be given access to Wilshire’s qualitative and quantitative software tools to assist in developing and implementing investment objectives. Services may cover public and/or private markets, depending on client needs. Wilshire is a diversified financial services firm and therefore Wilshire’s products, services, investment approach and advice differ between clients (including discretionary accounts and even where similarly situated) and not all of Wilshire’s products and services are available to all clients. Clients may utilize different classes of the same issuer that have different rights, including, without limitation, with respect to liquidity and fees. Wilshire receives a share of the fees charged to clients of Wrap Accounts, and may benefit from the marketing, computer reporting and client screening services of the Wrap Account sponsors.

Client Agreements Prior to the start of any client relationship, Wilshire enters into an agreement with the client. The agreement outlines the terms and conditions of the relationship including a description of the services to be provided by Wilshire, responsibilities of the client, fees and other standard contractual terms. Investment goals, objectives and/or guidelines for each advisory client are documented in each client agreement. Clients may impose restrictions on investing in certain securities or types of securities, or whether Wilshire’s services are provided on an open architecture model (in which Wilshire uses exclusively third-party products to implement the client’s investment plan) or a proprietary

products service model (in which, for the strategies and asset classes covered by Wilshire products, Wilshire products will be the only available options). Advisory agreements may not be amended or assigned without client consent, which consent may be provided through negative consent in certain circumstances.

Non-Investment Advisory Services Types of Services Wilshire has over fifty years of expertise providing solutions for investment manager peer analysis. Clients served include central and custodial banks, asset management firms, insurance companies, plan sponsors, mutual fund companies and hedge funds. Wilshire’s analytics solutions, including Wilshire Compass and Wilshire Trust Universe Comparison Services, are intended to help clients in their investment evaluation and decision-making. Wilshire provides data and analytics specializing in seeking to improve profitability and performance for investment managers, institutional investors and funds. These services cover all aspects of investment management, including custody and administration, foreign exchange, cash, trading, compliance and additional potential cost saving areas, and may be provided directly by Wilshire or by Wilshire’s affiliates. Wilshire acts as an index provider for a limited number of indexes, collectively known as the Wilshire Index Series, that provide institutional investors, asset managers and retail intermediaries flexibility in solving benchmarking, portfolio construction, and risk management challenges. The indexes in the Wilshire Index Series are calculated and administered by an unaffiliated third-party service provider under agreement with Wilshire. Customer Agreements Prior to the start of any customer relationship for non-investment advisory services, Wilshire enters into an agreement with the customer. The agreement outlines the terms and conditions of the relationship including a description of the services to be provided by Wilshire, including licenses to utilize Wilshire’s analytical tools, responsibilities of the customer, fees and other standard contractual terms.

Fees Generally Wilshire’s advisory fees differ depending on the size of the client, services provided, complexity of the solution and the relationship established. Fee structures include i) a fixed fee; ii) a percentage of assets under management or advisement; iii) a performance fee; and iv) a fee based on number of plan participants, and (v) a fee based on individual work-product produced. All fees are negotiable. Wilshire, in its sole discretion, reserves the right to waive any minimum fee requirements and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). Wilshire is also permitted to exempt certain investors in its private funds from payment of all or a portion of management fees or performance-based fees charged by Wilshire, including persons designated by Wilshire as “friends and family,” Wilshire’s personnel, or other investors meeting certain qualification requirements based on commitment size or other strategic or relationship factors. Wilshire reserves the right to make any such exemption from management fees and/or performance-based fees by a direct exemption, a rebate by Wilshire and/or its affiliates, or through a co-investment or other similar vehicle. Fee Billing Depending on the services provided, Wilshire may deduct fees from client assets or bill clients for fees incurred. Where the client is one of Wilshire’s proprietary funds, fees are typically paid out of the client’s investment account by the client’s custodian on a monthly or quarterly basis. For all other clients, Wilshire issues an invoice with payment in full expected within a certain period of receipt. Clients that pay fees out of their investment account must consent in advance to direct debiting of its investment account. When we collect fees in this manner, at the same time we bill the custodian, we will send the client an invoice showing the amount of the fees, the value of the assets on which they are based, and the fee computation. Upon termination, fees are either billed or refunded, as appropriate, pro rata based on the number of days for which Wilshire provided advisory services during the relevant billing period prior to termination. Clients may, but are not required to, prepay their fees to Wilshire on a periodic basis. Where a client has prepaid fees, if the advisory contract is terminated before the end of a billing period, Wilshire will calculate a credit and return the unused portion of the prepaid fees to the client. The amount of the refund will be pro rata based on the number of days remaining in the billing period. Other Fees and Expenses Clients typically are expected to incur other fees not associated with Wilshire (e.g., administrative, custodian and/or transaction fees). Clients also incur brokerage commissions, which are discussed in the “Brokerage Practices” section of this Brochure. Expenses other than advisory and performance fees and brokerage commissions, such as custody fees, are generally paid directly by a client to the service provider. Funds are subject to operating expenses, including, without limitation, advisory fees paid to the investment managers, sub-advisers, and Trading Advisors of the funds, as well as transaction, administration, custody, transfer agency, auditing, legal, line of credit fees, and fees payable to other external service providers. If Wilshire invests a client’s assets into a fund (proprietary or non-proprietary), the client will bear a proportionate share of the fees and expenses of the fund in addition to the fees and expenses it pays Wilshire. If Wilshire invests a discretionary client’s assets in a fund managed by Wilshire, Wilshire generally will waive a portion of, or all, fees at either the client account or fund level to ensure that the discretionary client is being appropriately charged with respect to the management of those assets. Performance Based Fees Wilshire charges a performance fee for certain services to its clients qualified to participate in performance fee arrangements under the Advisers Act. These fees are generally charged as a percentage of the profits earned from investments, at times only after a minimum return has been achieved. The pertinent fee agreement provides details about how these fees are charged. Please see Item 6 for more information about performance-based fees.

Fee Schedule Solutions for Institutional Investors Non-discretionary advisory services Wilshire typically charges an annual fixed retainer fee between $35,000 and $4 million for general non-discretionary advisory services. Discretionary advisory services Wilshire typically charges from 5 to 65 basis points on assets under management for general discretionary advisory services. Life-cycle or targeted retirement date investment programs Wilshire typically charges from 3 to 25 basis points on assets under management for life-cycle or targeted retirement date investment programs. Risk Management Wilshire typically charges an annual fixed fee between $250,000 and $3 million for full-service risk management consulting that delivers the risk measurement and monitoring tools required to implement a risk management program. Investment Management Wilshire serves as the investment manager to the Wilshire Solutions Funds Trust (“WST”), a pooled investment vehicle consisting of a series of funds. WST is a commingled investment platform offered to clients who seek a pre-packaged solution to access Wilshire’s discretionary services. A complete description can be found in WST’s offering documents. For serving as investment manager to the WST, Wilshire charges a fee on assets under management as agreed to between Wilshire and the investor, subject to a minimum annual fee of $100,000 per investor. The minimum fee may be waived at Wilshire’s sole discretion. Wilshire Compass Wilshire charges a fixed retainer fee annually for Wilshire Compass. Additional costs may be incurred, depending on the number of users to be supported at each client site and/or on other factors. Wilshire Trust Universe Comparison Services (WTUCS) Wilshire charges a fixed retainer fee annually for WTUCS. Additional costs may be incurred, depending on the number of users to be supported at each client site and/or on other factors. Private Asset Solutions Separate account management Wilshire generally charges a management fee of between 50 and 100 basis points on committed or invested capital for separate accounts. Certain additional services may also be contracted and charged on a fee-for-service basis. The minimum capital commitment under management for a separate account is $25 million, which may be reduced at Wilshire’s sole discretion. Commingled funds (including funds of funds) Wilshire serves as the investment manager or sub-adviser to pooled investment vehicles, including funds registered under the Investment Company Act of 1940 (the “40 Act”). Limited partners and investors of the commingled funds pay a management fee based on the value of committed capital or invested capital and typically pay a performance fee. Fees vary and are disclosed in the offering documents for each investment vehicle. Commingled private vehicles typically require a minimum investment of between $100,000 and $5 million. Funds registered under the 40 Act may have lower or higher investment minimums. Funds of one Wilshire serves as the investment manager or sub-adviser to investment vehicles that have one limited partner or investor. The limited partner or investor of the funds of one pays a management fee based on the value of committed capital or invested capital and typically pays a performance fee. Fees vary and are disclosed in the offering documents for each investment vehicle.

Non-discretionary advisory services Wilshire may charge a project-based fee, an annual fixed retainer fee or a fee based on a percentage of assets under management or assets under advisement for non-discretionary advisory services. Trading Advisors Funds or accounts that are sub-advised by a Trading Advisor are charged advisory fees (calculated as a percentage of assets) and, if applicable, performance fees (generally calculated as a percentage of any new capital appreciation on assets) that are payable in full to the respective Trading Advisor. With certain funds that are sub-advised by a Trading Advisor, instead of advisory fees and performance fees being paid in full to such fund’s Trading Advisor, such fees may be shared among the Trading Advisor and Wilshire, or Wilshire may also receive a management and/or performance fee in addition to the fees payable to the Trading Advisor. Such fee arrangements are disclosed in the offering documents and/or subscription agreements relating to such investment vehicles. Expenses Expenses, to the extent allocable, are allocated consistently with the fiduciary obligations of Wilshire and in a way that is fair and equitable to each client over time per Wilshire’s expense allocation policy. Generally, Wilshire seeks to allocate expenses in accordance with the applicable investment management agreement, disclosure document, governing document, or similar agreement with a client. Certain expenses are allocable to a single client (or, in the case of a fund with multiple share classes, one or more share classes within such fund), allocable to multiple clients or allocable between Wilshire and one or more clients. Fee and expense terms will vary among clients. Expenses incurred in establishing and managing private funds (i.e., commingled funds, funds of funds and funds with one or more Trading Advisors) will typically be borne by the fund, in accordance with its limited partnership agreement or other similar agreement, and disclosure and subscription documentation. Funds are typically subject to, and charged, expenses related to the organization and operation of the fund. As further described in a fund’s governing documents, organizational expenses generally include, without limitation, printing, legal, capital raising, accounting, travel (including all air travel, car services, other modes of transportation, meals and lodging), registration, compliance and any administrative or other filings and other organizational expenses of the fund (including the preparation of any documents related to any of the foregoing and out-of-pocket costs and expenses incurred by placement agents, finders or other persons performing similar services in connection with the foregoing) and its general partner, managing member or similar controlling entity. In addition to the management fee, performance fee and organizational expenses, a fund also will generally pay, or reimburse Wilshire (or an affiliate thereof) for, all other fees, costs, expenses, liabilities and obligations (referred to collectively in this section as “costs”) relating to the fund’s and/or its general partner or managing member and/or its subsidiaries’ and/or intermediate entities’ (as applicable) operations, investment activities (including the investigation, proposed acquisition, acquisition, management, proposed disposition and disposition of its investments and proposed investments, whether or not actually acquired) and its liquidation, including, without limitation, all costs relating or attributable to:

activities with respect to structuring, organizing, acquiring, bidding on, negotiating, diligencing, consummating, evaluating, bidding-on, financing, refinancing, managing, operating, hedging, monitoring, valuing, winding up, liquidating, dissolving, restructuring, recapitalizing, trading, selling, or otherwise disposing of the fund’s actual and potential investments (including follow-on investments and other transactions involving the deployment of fund capital) or seeking to do any of the foregoing (including any associated legal, financing, banking, commitment, transaction or other costs payable to attorneys, accountants, tax professionals, investment bankers, lenders, financing sources, third-party due diligence providers, software and service providers (including certain subscriptions to databases and/or research services), advisors, consultants, data providers and similar professionals in connection therewith and any costs related to transactions that may have been offered to co-investors), whether or not any contemplated transaction or project is consummated and whether or not such activities are successful;

indebtedness of, or guarantees made by, a fund, Wilshire (or any affiliate thereof) or any “affiliated partner” on behalf of the fund and any fund entity and involving any investment, including interest with respect thereto, or evaluating, negotiating or seeking to put in place any such indebtedness or guarantee;

all legal (including the fees and charges of outside counsel), regulatory, compliance (including ongoing filing and registration fees charged by regulators and any fees, costs and expenses incurred in complying with disclosure, third-party reporting and other similar obligations, including legal and regulatory filings of Wilshire and/ or its

affiliates relating to a fund and its activities, such as Form PF and other reports, disclosure and filings made to regulatory authorities and compliance obligations arising from the AIFMD) and administrative costs;

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of Loss Methods of Analysis Since 1972, Wilshire has pioneered analytical-driven investment consulting and asset management solutions to manage risk. Wilshire was an early innovator of integrated asset/liability modeling, as well as risk management and portfolio optimization models to help plan sponsors and institutional investors arrive at optimal portfolios based on their specific needs. Industry research and our experience lead us to believe that the asset allocation decision has the greatest impact on a portfolio's long-term return and risk profile. Wilshire embraced this important concept over 40 years ago when the Firm introduced its integrated asset/liability modeling technique to the industry. The investment strategy for a specific client is based upon the objectives stated by the client during consultations and as mutually agreed through an investment policy statement. Wilshire has over 40 years of experience in assisting clients to develop investment policies, procedures, and guidelines. Investment policy and guidelines are integral to all aspects of Wilshire’s investment advisory services. For those clients for which Wilshire has investment discretion, Wilshire primarily (i) selects asset managers as subadvisers or Trading Advisors to whom Wilshire delegates day-to-day portfolio management, (ii) invests in External Funds, and (iii) invests directly, or through third-party co-investment opportunities, in securities or derivatives. These investment managers, Trading Advisors, or funds execute diverse types of investment strategies. Wilshire’s selection and monitoring of investment managers, Trading Advisors, and External Funds is based on various criteria, including, without limitation, investment performance, risk management, investment philosophy, organizational structure, experience and education of key personnel, legal and compliance infrastructure, information technology, operational capabilities, portfolio composition, information obtained through personal interviews and literature, and political, market, and economic factors. In addition, Wilshire may identify External Funds, External Managers, and Trading Advisors through our staff’s professional networks, various industry channels, including, without limitation, vendor databases, attendance at capital introduction conferences, Bloomberg lists, hedge fund alerts, and discussions with industry participants. Trading Advisors, to whom we delegate discretionary trading for certain funds or accounts, typically utilize one or more alternative investment strategies. These strategies include, without limitation, long/short equities, long/short credit, distressed securities, market neutral, commodities trading, managed futures, event driven and global macro (including emerging market equities, rates, fixed income and currencies). The Trading Advisors implement their investment strategies through a variety of methods, including, without limitation, by investing in securities, commodities, derivatives, and other instruments. Wilshire also engages in quantitative, rules-based investment analytics, which are used in a variety of applications including monitoring broker-dealers’ investment platforms and selecting securities for investment portfolios.

Use of Artificial Intelligence (“AI”) Wilshire utilizes certain artificial intelligence (“AI”) tools and technologies to support its business operations, including in its manager research process for both traditional and alternative strategies. AI may be used as part of the Firm’s information gathering, data analysis, due diligence, and screening of investment managers. All AI-generated insights or data are subject to review and oversight by Wilshire investment professionals as part of the Firm’s standard research and diligence processes. In addition to its application within manager research, AI is also utilized across various non-investment functions of the Firm, such as operational efficiency, sales processes, legal workflow, regulatory compliance, and other internal business activities. Wilshire has implemented governance procedures and controls around the responsible use of AI, including measures to promote confidentiality, data security, data integrity, oversight, and compliance with legal and regulatory requirements. As with any technology, the use of AI tools may involve certain risks, including, but not limited to, the potential for errors or biases in analysis, cybersecurity considerations, and evolving regulatory expectations.

Risk of Loss All investment programs have certain risks that are borne by the investor. Wilshire’s investment approach seeks to mitigate risk and ensure clients are compensated for the risk they take. The risk for each client varies in accordance with their policies, procedures, goals, guidelines and stated risk tolerance. Investing in securities involves risk of loss and other risks that clients should be prepared to bear. Past performance is not necessarily indicative of future results. Clients should be aware that investing entails risks that may be applicable to a particular investment product. All investors are urged to review, if applicable, the investment product’s offering materials and the risk disclosures found therein in addition to the risks noted below. All of Wilshire’s clients will encounter risks, including, but not limited to: Investment Objective Risk: No assurance can be given that a client will achieve its overall investment objectives. There can be no assurance that Wilshire will be able to recommend investments to a client in a manner that is profitable, and there is no guarantee against loss of client assets. Any client may lose some or all of its investments. Reliance on Third Parties: The success of a client’s account is dependent on the judgment and abilities of Wilshire managing investments for the client’s account and, where applicable, in selecting and monitoring the performance of External Managers, External Funds, Trading Advisors, and co-investment opportunities, and on the ability of these managers to generate positive performance. Clients usually do not have the opportunity to evaluate fully the relevant economic, financial, and other information regarding their account’s investments. Clients are dependent on the judgment and abilities of Wilshire and other External Managers. There is no assurance that Wilshire or External Managers, or the investments or funds recommended or advised by such parties, will be successful. Although our officers, key employees, consultants, and principals will devote as much of their time to clients as is necessary or appropriate, they will not devote substantially all of their time to any one client as they must devote a portion of their time to other clients and investments. The loss of the services of one or more of these employees, principals, or consultants may have a material adverse effect on our ability to provide certain services to the clients. Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying value or the company’s circumstances. For example, political, economic, and social conditions may trigger market events. Events that once had only local impact are now more likely to have regional or even global effects. Events that occur in one country, region, or financial market will, more frequently, adversely cause impacts in other countries, regions, or markets. These impacts can be exacerbated by failures of governments and societies to adequately respond to an emerging event or threat. Clients will be negatively impacted if the value of their investments decreases as a result of such events. These events may adversely impact the operations and effectiveness of Wilshire or an External Manager, or a key service provider of the foregoing, or disrupt systems and processes necessary or beneficial to the management of a client’s account. Furthermore, Trading Advisors, and External Managers, and the service providers on which they and Wilshire rely upon, are located throughout the globe and may be impacted by certain events isolated to their location, in which case such events can nevertheless materially and adversely affect a client’s financial condition and investments. Lack of Diversification: A Client’s account might not be diversified, and, in particular, may have periods where it is invested in none, one, or only a few investments or investment strategies. In addition, the investments in which a client’s account is invested might not be diversified and, instead, may be concentrated in one or a small number of markets, sectors, strategies, currencies, instruments, jurisdictions or issuers. Concentration of risk generally makes an account more susceptible to fluctuations in value resulting from adverse economic or business conditions affecting that particular market, sector, currency, instrument, jurisdiction or issuer, and could expose the account to losses disproportionate to those that it might have incurred if the account maintained a greater level of diversification. Trading Advisors and External Managers will not coordinate their investment strategies with each other and at times may take positions which are the same as, or opposite from, positions taken by the other, or other advisers and managers to which a client may have exposure. Doing so may cause concentration of investments for a client, cancelling out of positions between funds in which such client is invested, and/or additional fees and expenses to be borne by such client without any marginal benefit. Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. As interest rates rise, the market value of fixed income instruments tends to decrease. Conversely, as interest rates fall, the market value of fixed income instruments tends to increase. This risk will be greater for long- term securities than for short-term securities. We may (depending on the investment objectives and restrictions applicable to a client) attempt to minimize the exposure of the client to interest rate changes through the use of interest rate swaps, interest rate futures and/or interest rate

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Wilshire provides investment advisory and management services to a wide range of institutional investors and financial intermediaries. We provide advisory services primarily to institutional investors such as pension and profit-sharing plans, trusts, endowments, charitable organizations and corporations. We also provide services to retirement plans, individual retirement investors and retail investors through financial intermediaries such as recordkeepers, broker-dealers, investment advisers and insurance companies. Wilshire provides investment services to U.S. or foreign government entities and agencies, state or municipal government entities and agencies, public international organizations, investment limited partnerships, and other types of investment vehicles. Wilshire also provides non-advisory services to institutional investors and asset managers. Client relationships vary in scope and length of service. Minimum account size varies across solution, product and client type.

Management As discussed above, Wilshire charges performance-based fees to certain “qualified clients” (as defined in Rule 205-3 under the Advisers Act) depending upon the terms and conditions of the advisory agreement with the client. In the event that Wilshire receives performance-based fees, the fact that we are compensated based on trading profits creates an incentive for us to recommend private funds or other investment opportunities that are riskier or more speculative than would be the case in the absence of such compensation. In addition, as further described in the governing documents of a private fund or other applicable client account, some performance-based fees are based both on realized and unrealized gains. As a result, certain performance-based fees received are in certain cases based on unrealized gains that a client never realizes. In addition, Wilshire has an incentive to recommend private funds or other investment opportunities, as applicable, to clients that are subject to performance-based fees payable to Wilshire over other clients who are not subject to performance-based fees payable to Wilshire. Wilshire maintains policies and procedures regarding investment allocations and seeks to allocate investment opportunities in accordance with such policies and in a manner that does not result in preferential allocations for clients subject to performance-based fees.

Financial Industry Activities Wilshire acts in the capacity of investment adviser to the Wilshire Mutual Funds, Inc., the Wilshire Variable Insurance Trust, Wilshire Private Assets Fund, and Wilshire Private Assets Master Fund, as well as acting as sub-adviser to various other registered investment companies. In addition, certain personnel of Wilshire serve as officers and/or directors of Wilshire Mutual Funds, Inc., and the Wilshire Variable Insurance Trust. Wilshire or its affiliates act as general partner and/or investment adviser to various private funds, the Wilshire Solutions Funds Trust, and the Wilshire Institutional Master Funds. Wilshire is registered as a Commodity Pool Operator and Commodity Trading Advisor with the National Futures Association and certain Wilshire employees have been registered as Associated Persons. Certain Wilshire employees are also registered representatives of Foreside Financial Group, LLC, a registered broker-dealer.

Affiliations Wilshire Associates Europe B.V. (“WAEBV”) distributes Wilshire products and services and provides research and advisory support for Wilshire’s business in Europe. Members of Wilshire who are employees of WAEBV are involved in the due diligence and ongoing monitoring of Wilshire’s private markets investments. Wilshire Advisors UK Limited is a UK affiliate of Wilshire which employs UK personnel on behalf of Wilshire. Wilshire Hong Kong Limited (“WHKL”) provides research support for Wilshire’s private markets business. Employees of WHKL are involved in the due diligence and ongoing monitoring of Wilshire’s private markets investments. Wilshire’s participation as general partner in various U.S. and offshore limited partnership investment vehicles is conducted through entities controlled by its affiliates, Wilshire Global Advisors LLC or Monica Holdco (UK) Limited. ParkLexington Advisors LLC (“PLA”) is a subsidiary of Wilshire that provides non-advisory services focused on analyzing the investment costs (e.g., transaction costs and ongoing expenses) of their clients and seeks to optimize such costs. PLA services are provided by employees of Wilshire. Wilshire and PLA may refer clients to each other, but neither receives any compensation for doing so. Wilshire clients are not required to use the services of PLA and may obtain similar services from unaffiliated providers. XTP, which includes XTP Implementation Services LLC, XTP Gmbh, XTP Ltd., and XTP Institutional Gmbh, provides nonadvisory services focused on analyzing the investment costs (e.g., transaction costs and ongoing expenses) of their clients and seeks to optimize such costs. Wilshire clients are not required to use the services of XTP and may obtain similar services from unaffiliated providers. CC Capital and Motive Partners, indirect owners of Wilshire, and the companies they control, are affiliates of Wilshire as a result of their ownership interest. This relationship creates certain conflicts of interest as discussed in more detail in “Conflicts of Interest” below.

Conflicts of Interest Conflicts of interest may exist where the benefits to or obligations of two parties are not aligned. In the asset management context, conflicts of interest most frequently arise where an adviser, its owners, subsidiaries, or affiliates may receive a benefit with respect to decisions made on behalf of client accounts (e.g., allocating funds to an affiliated manager or third-party manager to which the adviser sells other services). Conflicts will arise from the regular provision of Wilshire’s services to its clients and represent risks that need to be managed. Conflicts of interest may arise when Wilshire, or its affiliates, subsidiaries or employees, engage in the following activities:3

provide advice or recommendations to clients with regard to Wilshire’s own products or services (e.g., recommending Wilshire-sponsored products where Wilshire will receive additional fees),

provide advice or recommendations to clients with regard to products or services offered by Wilshire affiliates (e.g., recommending products where Wilshire’s parent companies may receive economic benefits),

provide advice or recommendations with regard to a product or service with which Wilshire competes where Wilshire may have incentives to not select such product or service in favor of Wilshire’s proprietary products or services,

develop and/or markets products or services using its own or an affiliate’s underlying tools and products where such affiliate and/or Wilshire’s owners may receive fees or other benefits,

evaluate, review, or recommend an investment manager, Trading Advisor or other financial services provider with which Wilshire has a business relationship or to which it or an affiliate provides services and receives fees (e.g., recommending managers from which Wilshire receives fees for providing analytics services),

act as general partner for certain funds in which Wilshire solicits client investments or invests client assets on a discretionary basis,

serve on (i) the advisory boards of underlying investments in which a Wilshire-sponsored or managed fund invests, (ii) the boards of entities that serve as the managers or advisers of a Wilshire-sponsored or managed fund, or (iii) the boards of operating companies,

charge different amounts and types of fees across accounts, which could create incentives to favor certain accounts over others (as more fully discussed in Items 5 and 6),

allocation of fees and expenses, whether to Wilshire, to Wilshire and clients and/or among clients, or

recommend the services of a third party from which Wilshire obtains a benefit (economic or otherwise).

In addition to the foregoing conflicts, Wilshire may be subject to conflicts related to its employees or employees of Wilshire’s affiliates. Wilshire reserves the right to employ personnel with pre-existing ownership interests in portfolio companies owned directly or indirectly by a client advised by Wilshire and/or its affiliates. Current or former personnel or executives of Wilshire and/or its affiliates are expected from time to time to serve in significant management roles at portfolio companies or service providers recommended by Wilshire. Similarly, Wilshire, its affiliates and/or personnel maintain relationships with (or invest in) financial institutions, service providers and other market participants, including, but not limited to, managers of registered and private funds, banks, brokers, advisors, consultants, finders (including executive finders and portfolio company finders), executives, attorneys, accountants, institutional investors, family offices, lenders, current and former employees, and current and former portfolio company executives, as well as certain family members or close contacts of these persons. Certain of these persons or entities will invest (or will be affiliated with an investor) in, engage in transactions with, or provide services (including services at reduced rates) to, Wilshire or its affiliates or one or more clients. Wilshire expects to be subject to a potential conflict of interest with a fund in recommending the retention or continuation of a third-party service provider to such fund if such recommendation, for example, is motivated by a belief that the service provider or its affiliate(s) will continue to invest in one or more funds, will provide Wilshire information about markets and industries in which Wilshire operates (or is contemplating operations), or will provide other services that are beneficial to Wilshire or one or more other funds. Controls and Mitigation

3 This list is not intended to be exhaustive and additional conflicts of interest may exist or arise in the future.

It is Wilshire’s policy to make evaluations, recommendations and decisions based upon the best interests of the client and without regard to any benefit (economic or otherwise) that Wilshire or its affiliates receive or might receive. Wilshire is committed to ensuring that it appropriately manages conflicts of interests in providing its products and services and that it does not prioritize an investment manager’s or financial service provider’s business relationship with Wilshire, its owners, personnel, or affiliates, or lack thereof, in performing evaluations for or making recommendations to its advisory clients. Wilshire has implemented policies and procedures that seek to mitigate conflicts of interest through appropriate oversight, transparency, and controls. Controls include well defined investment procedures and appropriate oversight in the execution of investment and operations functions. Wilshire also seeks to manage the flow of information or limit certain activities, where relevant and appropriate. Wilshire generally does not use information barriers to limit the sharing of information within its advisory business. Investment advisory personnel have multiple roles and often the personnel necessary for an assignment cannot be divided into distinct groups around which to erect barriers. In these instances, Wilshire will seek other means to mitigate any actual or potential conflict that arises, including disclosure or greater supervisory oversight. Wilshire’s policy is to disclose material conflicts of interest to its clients and prospective clients through this Brochure and other relevant documents. Upon request or where otherwise required by relevant rule or regulation, Wilshire will provide existing and prospective clients with a conflicts disclosure report providing a summary of relevant conflicts identified by Wilshire that are applicable to that client relationship. Due to Wilshire’s obligations under non-disclosure and confidentiality agreements with its clients, the information provided in the conflicts disclosure report may be in summary or aggregated form. When deemed necessary, a client will be required to acknowledge and accept certain conflicts. In some instances, conflicts of interest may arise between Clients. Wilshire will seek to resolve these conflicts in ways that are fair, transparent and reasonable for all affected parties, even if the ultimate resolution could nevertheless disadvantage or appear to disadvantage one or more of the parties to some extent. Where appropriate, Wilshire will seek to obtain informed consent to its proposed resolution from the affected parties or their representatives. In all cases, Wilshire will disclose both the conflict and its ultimate resolution to the affected clients. Specific conflicts of interest may arise where Wilshire is required to compare (and subsequently recommend) its proprietary products (or the products or services of an affiliate) directly versus third-party products. In such instances, Wilshire may take a variety of steps to mitigate the risks, including, but not limited to, (i) requiring the client to acknowledge the conflict and presence of Wilshire-sponsored or affiliated products in the allocation, (ii) limiting allocation decisions to either all-or-none with respect to Wilshire-sponsored vehicles, and/or (iii) waiving fees at either the Wilshire or fund level to prevent double-charging. Wilshire oversees management of the aforementioned policies and procedures, as well as identifying and mitigating new conflicts of interest. When appropriate, Wilshire will delegate issues to a Wilshire committee or persons to provide oversight or an independent assessment of issues where a conflict of interest is present. Expense Conflicts Wilshire intends to allocate aggregate costs among applicable clients (and, in certain cases, among Wilshire and applicable clients) in accordance with allocation policies and procedures which are designed to allocate expenses in a fair and equitable manner over time among such clients. However, expense allocation decisions can involve potential conflicts of interest (e.g., an incentive to favor clients that pay higher incentive fees or conflicts relating to different expense arrangements with certain clients). Clients generally will bear costs and expenses to the extent provided in the agreements under which the client was established (such as a limited partnership agreement or private placement memorandum for a private fund or an investment advisory agreement with a client). Typically, the investment advisory agreement and/or fund partnership agreement relating to such client will stipulate what costs and expenses can be borne by the client. Generally, investment-related costs (including broken deal costs where allowed) will be allocated across relevant clients pro rata. However, any expense allocation determination involves inherent matters of discretion, e.g., in determining whether to allocate pro rata based on number of funds, co-invest vehicles or other clients receiving related benefits or proportionately in accordance with asset size, invested capital or capital commitments, or in certain circumstances determining whether a particular expense has greater relative benefit to a particular fund. Not all costs incurred in connection with sourcing, negotiating, structuring, holding, or exiting an investment will benefit participating clients ratably even though such costs will typically be allocated on a ratable basis. Wilshire reserves the right to allocate other types of shared client expenses on another basis (e.g., use per instance) as determined more appropriate by Wilshire under the circumstances, and in accordance with its policies and procedures. Expense allocation decisions by Wilshire could result in a client bearing more or less of certain fees and expenses than other participants or potential

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Transactions and Personal Trading Code of Ethics Wilshire’s Code of Ethics (“Code”) was adopted in compliance with the requirements of the Advisers Act. The Code emphasizes Wilshire’s fiduciary duty to its advisory clients and the obligation of the Firm’s personnel to uphold that fundamental duty. The Code addresses securities-related conduct and focuses principally on personal securities transactions, conflicts of interest, political contributions, and employee reporting requirements. Wilshire has implemented ACA Compliance Alpha to assist in the management, monitoring and reviewing of employee personal securities accounts and transactions. Employees, with limited exceptions, are required to maintain accounts at approved broker-dealers and are required to obtain pre-approval prior to trading securities. Wilshire maintains a Restricted Companies List (“RCL”) which list securities employees are generally prohibited from trading. The RCL may include certain publicly traded companies that include clients of Wilshire’s advisory business units, individual securities being actively held or traded by a portfolio over which Wilshire has discretionary control, or companies of which Wilshire believes it could be in possession of material nonpublic information. Members of Wilshire’s investment group, in consultation with Wilshire’s Legal and Compliance Department, otherwise determine whether to place companies on the RCL. On an annual basis, Wilshire requires employees to certify that they are in compliance with the Code. Wilshire will provide clients and prospective clients with a copy of the Code upon request. As discussed in Item 10 above, Wilshire also provides advice or recommendations to clients with regard to Wilshire’s own products or services. Wilshire also acts as general partner for certain funds in which we solicit client investments or invest client assets on a discretionary basis. Wilshire addresses these conflicts through disclosure to our clients and has implemented policies and procedures that seek to mitigate conflicts of interest through appropriate oversight, transparency, and controls.

Selecting Brokerage Firms Wilshire may be considered affiliated with certain broker-dealers as a result of being under common control with them via the Owners. Wilshire maintains policies and procedures to ensure that no information is shared with any potential affiliated broker-dealer and Wilshire does not use or recommend any affiliated broker-dealers, except as may be directed by clients after appropriate disclosure (see “Conflicts of Interest” for more information). Select employees of Wilshire who engage in activity that requires their registration as a licensed agent of a broker-dealer are registered with a brokerage firm through which Wilshire distributes investment products. Wilshire does not otherwise regularly execute or direct trading on individual securities and Wilshire does not generally make recommendations to clients regarding brokerage services. For funds for which Wilshire has delegated investment authority to Trading Advisors, (i) it is the Trading Advisor who generally selects the brokers to be used to execute transactions on behalf of the fund, and (ii) Wilshire, together with the Trading Advisor, typically selects clearing brokers, prime brokers and other over-the-counter counterparties to be used by the respective fund. In addition, Wilshire typically negotiates and executes the various brokerage agreements with the relevant broker(s) to these funds; however, in certain circumstances Wilshire may approve, in consultation with the Trading Advisor and the relevant client, the use of trading relationships already established by the Trading Advisor to effect trading on behalf of a fund.

Best Execution On occasion, Wilshire executes transactions through a broker-dealer on behalf of Wilshire managed funds or empowers an agent to trade on behalf of Wilshire managed funds. When directly selecting a broker-dealer, Wilshire will seek to have orders executed at prices that are as favorable as possible under prevailing market conditions. Wilshire will seek broker-dealers that can provide the best qualitative execution, taking into consideration numerous factors, including, but not limited to the asset being traded, the capability of the firm to execute trades efficiently, quality of price execution, the competitiveness of commission rates and transaction fees, Wilshire’s limited trading activity, and the overall level of customer service. Thus, while Wilshire will give significant weight to the competitiveness of the available commission and transaction rates, it does not necessarily select the broker-dealer that offers the lowest possible rates. Additionally, even where Wilshire uses its best efforts to seek the lowest possible commission rate, it may not obtain the lowest rate for any particular transaction. If a client directs Wilshire to effect transactions through a particular broker-dealer, Wilshire may not be able to seek best execution services or prices from such directed broker-dealers nor may it be able to “bunch” the client’s transactions with orders for other accounts. As such, the client may incur higher commissions or other transaction costs than would otherwise be the case had the client determined to affect transactions through the brokerage relationships generally recommended by the advisory firm. With respect to Wilshire client assets that are managed by a third-party investment manager, the investment manager has a fiduciary obligation to seek best execution for all transactions executed on behalf of the client in accordance with its own policies and procedures. Wilshire does not typically execute securities trades on behalf of funds for which Wilshire has delegated trading responsibility to a Trading Advisor. It is Wilshire’s policy that the Trading Advisor have procedures in place designed to obtain best execution. Wilshire’s operational due diligence team, during its initial and periodic reviews of a Trading Advisor, conducts a review of the Trading Advisor’s best execution practices, policies and procedures.

Soft Dollars Wilshire does not have any soft dollar arrangements but may receive payment from third parties for certain analytics services as a result of soft dollar arrangements by our clients.

Order Aggregation Wilshire does not regularly execute trade transactions for multiple clients. Were the occasion to arise, Wilshire would aggregate transactions and execute orders as a single agent if aggregation would not disadvantage any of the clients participating.

Allocation Wilshire allocates investment opportunities among eligible clients in a manner it believes is fair and equitable over time, consistent with its fiduciary duties. When limited or oversubscribed investment opportunities arise, allocations are typically made on a pro rata basis among eligible clients, based on each client’s requested amount, subject to clients’ investment guidelines, available capital, and other relevant factors (such as portfolio diversification, minimum investment size, allocation history, and operational or legal constraints). Wilshire may deviate from a pro rata approach in its good faith discretion if it determines that circumstances warrant a different allocation, and may prioritize certain client programs where appropriate. Allocations are determined or reviewed by the relevant investment committees and are documented accordingly. Non-discretionary clients are informed of suitable opportunities and may participate on a first-come, first-served basis. In certain circumstances, Wilshire will make exceptions to its policies and procedures regarding investment allocation.

Co-Investments Where appropriate and feasible, Wilshire may offer one or more clients or other parties the opportunity to co-invest (directly or indirectly) in a potential co-investment. Co-investment opportunities may be offered in connection with the execution of the initial investment or at any reasonable time after the closing of such investment, as determined by Wilshire in its sole discretion. If a co-opportunity is offered to one or more clients or investors, such offer may not, and typically will not, correspond to their pro rata interests, and nothing in Wilshire’s policy obligates Wilshire to notify any client or investor of any co-investment opportunity. Wilshire does not receive transaction-based compensation for arranging co-investments, but may receive agreed-upon management or performance fees. In certain circumstances, Wilshire will make exceptions to its policies and procedures regarding co-investments.

Wilshire has engaged TopCap Partners, Inc. (“TopCap”) to refer potential prospects to Wilshire, primarily in European markets. Wilshire will pay TopCap fees in accordance with our agreement. These fees are borne by Wilshire and are not passed through to clients. Wilshire has engaged Rice Partners (“Rice”) to refer potential prospects to Wilshire. Wilshire will pay Rice fees in accordance with our agreement. These fees are borne by Wilshire and are not passed through to clients. WAPL has engaged Akindred Pty Ltd (“Akindred”) to promote Wilshire’s investment advisory services and products in Australia and New Zealand. Wilshire will pay Akindred incentive fees for successful referrals out of Wilshire’s management or advisory fees with respect to the applicable product or service. These fees are borne by Wilshire and are not passed through to clients. Wilshire has engaged Capstone Partners LP (“Capstone”) to refer potential prospects to Wilshire, primarily in AsianPacific markets. Wilshire will pay Capstone fees in accordance with our agreement. These fees are borne by Wilshire and are not passed through to clients.

Wilshire is required to disclose all material facts regarding any legal or disciplinary events that would be material to a client’s evaluation of Wilshire or the integrity of Wilshire’s management. Wilshire has no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Wilshire’s advisory business or the integrity of Wilshire’s management.

Periodic Reviews Each business unit performs periodic account reviews, as appropriate, when market conditions dictate or as agreed upon with the client. Client account reviews involve various Wilshire personnel and include portfolio managers, consultants, and members of our Manager Research team. In addition, our risk management team monitors compliance by each Trading Advisor with the investment restrictions and risk guidelines applicable to the fund that such Trading Advisor advises. Notwithstanding the foregoing, in the event a client’s account is within a “ramp-up period,” certain investment restrictions and/or risk guidelines may not be strictly adhered to in order to seek an orderly ramp-up of such client’s account.

Review Triggers Other conditions that trigger a review, without limitation, are changes in applicable tax laws, new investment information, and/or changes in a client’s situation.

Regular Reports Clients receive periodic communications on at least a monthly or quarterly basis, provided that certain clients may receive customized reports on an alternative timetable, as agreed to with such client. The updates may include a valuation statement, portfolio statement, fact sheets, and/or market commentary. Certain funds generally receive audited financial statements within 120 days after the end of the fund’s fiscal year.

Wilshire is deemed to have custody of assets held by private investment funds for which Wilshire serves as general partner, managing member, or investment adviser. With respect to the assets held by these funds: (i) all assets are held by qualified custodians; (ii) the funds are audited annually by a member of the Public Company Accounting Oversight Board; (iii) either Wilshire or the applicable custodian sends, not less than quarterly, statements to all investors in the fund; and (iv) audited financial statements prepared in accordance with "generally accepted accounting principles" are distributed to investors in a fund within 120 days (180 days for a fund of funds) of the end of each fiscal year. Investors are urged to carefully review and compare any account and financial statements that are received from the qualified custodian and Wilshire. Wilshire may be deemed to have custody over OCIO client accounts solely because of (i) the ability to debit advisory fees directly from client accounts, or (ii) the ability to move funds or securities to third parties, either through thirdparty internet portals or by direct instructions to clients’ qualified custodians. Wilshire’s OCIO Operations Team maintains written policies and procedures governing movements of client assets, including callback protocols and dual signatures for cash movements over specified values. Any such OCIO client account assets shall be maintained by a

qualified custodian that will transmit account statements to the clients, and will be subject to surprise annual asset verifications by an independent public accountant.

Wilshire provides discretionary services and accepts discretionary authority to manage assets on behalf of clients, including through the selection of External Funds, Trading Advisors, and External Managers, as more fully detailed above under Item 4. Wilshire’s discretionary authority on behalf of a client will be described in the client’s investment advisory agreement, including any investment restrictions. Wilshire may agree to certain investment restrictions and risk guidelines regarding the type and quantity of assets in which a client invests. Clients or investors may also have the right to opt-in/opt-out of specific investment opportunities.

Non-discretionary clients are expected to vote their own proxies unless they delegate this responsibility to the applicable investment manager. Wilshire has responsibility for voting proxies for some discretionary clients and, where a client has designated Wilshire such responsibility, Wilshire will attempt to consider relevant factors of its vote that could affect the value of the investments and will vote proxies in the manner that it believes will be consistent with efforts to maximize shareholder value. Wilshire uses the following process to address conflicts of interest when voting proxies on behalf of clients: (i) identify potential conflicts of interest; (ii) determine which conflicts, if any, are material; and (iii) establish procedures to ensure that Wilshire’s voting decisions are based on the best interests of clients and are not a product of the conflict. Wilshire has established multiple methods to address voting items that it has identified as those in which it has a material conflict of interest. In these cases, Wilshire will use an independent third party to recommend how a proxy presenting a conflict should be voted or authorize the third party to vote the proxy, refer the proposal to the client and obtain the client’s instruction on how to vote, or disclose the conflict to the client and obtain the client’s consent to Wilshire’s vote. Wilshire may have different voting policies and procedures for different clients and may vote proxies of different clients differently, if appropriate in the fulfillment of its duties. With respect to funds where we have delegated trading responsibility to the Trading Advisors, we generally authorize the Trading Advisors to vote proxies on behalf of the relevant funds. In accordance with our internal policies, our operational due diligence personnel monitor that such Trading Advisors have proxy voting procedures. We will provide, at no cost, a copy of our proxy voting policies and procedures and applicable information regarding how we voted proxies in the past at a client’s request.

Wilshire does not have any financial impairment that precludes the Firm from meeting contractual commitments with clients.

Privacy Notice Wilshire Advisors LLC (“Wilshire,”) and its affiliates have adopted the following policy describing how third party and consumer information is gathered by Wilshire and may be treated (Wilshire’s “Privacy Policy”). Wilshire is a global company and conducts business around the world, including within regions with unique rules that apply to the collection, processing, and retention of personal information (as defined below) from individuals within those areas. Appendices A, B and C include information regarding additional rights, policies and procedures applicable to global data privacy laws, including General Data Protection Regulation (“GDPR”, together with other EEA data privacy laws “EEA Laws”), the California Consumer Privacy Act of 2018 and the Cayman Islands Data Protection Act (as revised), respectively. Wilshire also complies with applicable federal regulations, including SEC Regulation S-P, which imposes certain safeguards and notification requirements with respect to customer information. Regulation S-P imposes requirements for the safeguarding and proper handling of nonpublic personal information (“customer information”) collected or processed by Wilshire in connection with its U.S.-regulated financial services activities, regardless of the client’s residence or citizenship. This includes, but is not limited to, Wilshire’s activities as an SEC-registered investment adviser. Key elements include: • Safeguards: Wilshire maintains administrative, technical, and physical safeguards to protect customer information from unauthorized access or use. • Incident Response and Notification: If Wilshire becomes aware of unauthorized access to or use of customer information, Wilshire will notify affected individuals as required by Regulation S-P, as soon as practicable and no later than 30 days after discovery, unless delayed by written request of the U.S. Attorney General based on national security or public safety grounds. • Service Provider Oversight: Third-party service providers with access to customer information are required to maintain appropriate security measures and promptly report incidents to Wilshire. Wilshire considers privacy to be a fundamental aspect of our relationships. We are committed to maintaining the confidentiality, integrity, and security of private, personal and confidential information in our possession. In the course of providing our products and services, we may collect, retain, and use private, personal and confidential information for the purpose of administering our operations, and complying with legal and regulatory requirements. The kinds of information we may collect will depend on the nature of the relationship in which we are engaged and may include Personal Information (as defined below) for all applicable global privacy laws. This information may include contact details such as address, email address and telephone number and, where required for contractual, legal or regulatory obligations, additional information (including, but not limited to, date of birth, bank account details and tax identification documents or numbers). The term “Personal information” as used in this Privacy Policy, and for purposes of all global privacy laws, means any information that identifies, relates to, describes, is reasonably capable of being associated, or could reasonably be linked, directly or indirectly to an identified or identifiable natural person (“Data Subject” or “ Consumer”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person. In most cases, we collect information directly from the person or entity with whom we have the relationship (e.g. through account applications, investment policy statements, website usage, customer surveys, and electronic or verbal correspondence); but may also obtain information from other sources (e.g. transactions; brokers, consultants or financial advisory firms; or public registers for background searches). Wilshire, generally, does not disclose private, personal and confidential information with outside organizations except for third party processors and service providers that are essential in administering our operations, or as otherwise required or permitted by law. As is common in the industry, non-affiliated companies may from time to time be used to provide certain services, such as preparing and mailing prospectuses, reports and account statements. These companies may be provided access to private, personal and confidential information solely to provide the specific service or as otherwise required or permitted by law. We may also provide confidential information to brokerage, financial advisory, or other third party financial intermediaries.

Wilshire reserves the right to disclose private, personal and confidential information where we believe in good faith that disclosure is required either under law or to cooperate with regulators or law enforcement authorities. In addition, we may disclose Personal Information to a non-affiliated third party upon the owner’s written request. Wilshire takes seriously the obligation to safeguard private, personal and confidential information (including Personal Information). We maintain appropriate safeguards which includes the use of security procedures to prevent revealing such information. Any questions regarding Wilshire’s Privacy Policy should be referred to the Chief Compliance Officer. As required by regulations, Wilshire will provide to its clients annually a statement regarding their rights to privacy.