Mutual of America Capital Management LLC: investment adviser

Mutual of America and Registered Investment Companies Mutual of America is a life insurance company that is also a registered investment adviser under the Investment Advisers Act of 1940. Capital Management provides investment advisory services to Mutual of America and its general account pursuant to various group annuity contracts at negotiated rates. Capital Management also advises the MoA Funds Corporation (“MoA Funds”), a registered investment company, composed of a number of different series, which are made available to the variable insurance products offered through the Separate Accounts of Mutual of America, to retirement plans and retail investors through financial intermediaries, and to institutions, such as endowments, foundations, corporations, not-for-profit corporations, tribal organizations, municipalities and other public entities, and trusts. The MoA Funds are distributed by Foreside Fund Services, LLC, a registered broker-dealer. The MoA Funds include the following series: the Equity Index Fund, All America Fund, Small Cap Value Fund, Small Cap Growth Fund, Small Cap Equity Index Fund, Mid Cap Growth Fund, Mid Cap Value Fund, Mid Cap Equity Index Fund, Large Cap Value Index Fund, Large Cap Growth Index Fund, Catholic Values Index Fund, Balanced Fund, International Fund, US Government Money Market Fund, Intermediate Bond Fund, Core Bond Fund, Inflation Focused Bond Fund, three Allocation Funds (Conservative Allocation, Moderate Allocation and Aggressive Allocation) and twelve Target Date Funds (MoA Retirement Income, MoA Clear Passage 2020, MoA Clear Passage 2025, MoA Clear Passage 2030, MoA Clear Passage 2035, MoA Clear Passage 2040, MoA Clear Passage 2045, MoA Clear Passage 2050, MoA Clear Passage 2055, MoA Clear Passage 2060, MoA Clear Passage 2065 and MoA Clear Passage 2070). Capital Management manages the MoA Funds in accordance with their written investment objectives, strategies and guidelines, as disclosed in their SEC registration statements. The investment program of a MoA Fund cannot be tailored to the individual needs of any particular investor. Investment in a MoA Fund does not create an advisory client relationship between the investor and Capital Management. Therefore, investors should consult their financial representatives and consider whether a MoA Fund meets their investment objectives and risk tolerance prior to investing. Capital Management also serves as sub-adviser to the Cromwell Long Short Fund, a registered investment company.

II. Institutional Clients Capital Management provides investment advisory services to institutional clients, including pension and profit-sharing plans, state and local government retirement plans, endowments and foundations, charitable organizations, tribal organizations, and other institutional investors (“Institutional Clients”). A. Separately Managed Account Clients Capital Management offers Institutional Clients active and passive investment management across a broad range of asset classes, including equity, fixed income, and multi asset class Page | 4

strategies. Generally, we require 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, although these minimums may be waived at our discretion. B. Asset Allocation Clients Capital Management also provides asset allocation services to Institutional Clients. Asset allocation services are primarily investments among the MoA Funds, with certain limited investments in unaffiliated mutual funds. Pursuant to the client’s written authorization and investment guidelines, Capital Management will, at its discretion, allocate assets among the funds in accordance with the asset allocation strategy selected by the client. We tailor our advisory services to our clients consistent with our investment approach and management capabilities. This includes managing client assets based on the individual needs of the client, including any client-imposed restrictions on investing in particular securities or types of securities. As of December 31, 2025, we managed approximately $30,947,400,000 in assets on a discretionary basis. As of this same date, we did not manage any assets on a non-discretionary basis. This amount for assets managed on a discretionary basis includes the assets in the Target Date Funds and the Asset Allocation Funds, which invest in other MoA Funds for which we also serve as investment adviser.

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 Page | 5

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 Thereafter

30 bp 25 bp

Equities – Active Small Cap Assets under Management First $10 million Next $30 million Thereafter

90 bp 85 bp 75 bp

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

60 bp 50 bp 40 bp

Equities – Active Large Cap Assets under Management First $10 million Next $15 million Next $25 million Thereafter

45 bp 40 bp 35 bp 30 bp

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

10 bp 8 bp 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 Page | 6

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 allocation services because it primarily allocates the assets of the client account to or among one or more of the MoA Funds, each of which generate additional fees for Capital Management that it would not otherwise earn if it allocated the assets of the client account to investment funds that do not generate such fees for Capital Management. The charges, fees and expenses, including but not limited to investment management fees, with respect to the MoA Funds, as described in the Prospectus and SAI, differ among such funds. This creates a conflict of interest because it provides an incentive for Capital Management to allocate assets to a MoA Fund that charges a relatively higher fee rather than another MoA Fund that charges a relatively lower fee. Capital Management mitigates the conflicts of interest noted above through communications to, and training and supervision of, its employees; by implementing policies and procedures reasonably designed to ensure that Capital Management provides investment advice that is in client’s best interest; and through disclosure of these conflicts to clients. These conflicts of interest will also be mitigated by Capital Management’s adherence to any agreed upon asset allocation guidelines in the client’s Investment Policy Statement. Any custodial fees shall be the responsibility of client and shall be deducted directly from the account pursuant to client’s agreement with custodian. The fee does not include the additional investment management, administrative, and other fees that client will pay to Capital Management for the services it provides to each MoA Fund in which the client invests, or other MoA Funds operating expenses, as described in more detail in the Prospectus. III. Payment of Fees A. MoA Funds and Mutual of America General Account Capital Management’s fees under its investment management agreements with respect to the MoA Funds (and, where required by SEC rules other registered investment company clients) are shown in the funds’ registration statements, on file with the SEC. Fees for Mutual of America’s general account are described in the registration statement for the Separate Accounts. Clients should note that the fees for fund (and general account) investments differ from the fees for separately managed and asset allocation accounts in several ways. First, a separate account and asset allocation client arranges for custody, recordkeeping and other service providers for its portfolio on its own (and pays for these services separately). In contrast, the MoA Funds hire their own service providers and pay the related operating costs. Depending on the fund and account documentation, in some cases, Capital Management bears some of these expenses. For details, please refer to the specific MoA Funds or Separate Account registration statement. B. Separately Managed Account Clients In general, the advisory fee is billed and payable in quarterly installments, in arrears, and will be based on the market value of the net assets (excluding accrued income) in the account as of the end of the preceding calendar quarter. Fees for partial quarters will be prorated based on the number of days in the calendar quarter during which the account was under management, Page | 7

and if the partial quarter ends on a day that is not the last day of a calendar quarter, it will be based on the market value of the account as of the end of the period that comprises the partial quarter. Any custodial fees shall be the responsibility of client and shall be deducted directly from the account pursuant to client’s agreement with custodian. C. Asset Allocation Clients In general, the advisory fee is payable by the Client’s qualified custodian on behalf of and at the direction of the Client and is billed quarterly in arrears based on the market value of the net assets of the account as of the end of that billing quarter. Such fee shall be deducted from the account by the custodian in the month following the preceding calendar quarter. The fee is prorated on a daily basis for any quarter during which the investment advisory agreement is in effect for only a portion of the quarter and is calculated at one-fourth of the annual fee. Capital Management and its supervised persons do not receive any compensation for the purchase or sale of securities or other investment products that are recommended to clients.

Asset Allocation Strategies When providing the asset allocation services to Institutional Clients, we construct client portfolios using a strategic asset allocation approach primarily among the MoA Funds consistent with the client’s written authorization and investment guidelines. Portfolios are diversified among asset classes such as U.S. equity, international equity, fixed income, and cash equivalents. Page | 8

Material Risks Despite efforts to control risk, investing in securities involves risk of loss that clients should be prepared to bear. The following identifies the material risks associated with the investment strategies Capital Management offers.

Large Cap Equity Income – Larger, more established companies may be unable to respond quickly to new competitive challenges and also may not be able to attain the high growth rate of successful smaller companies.

Mid Cap Value/Mid Cap Core – Mid cap stocks experience more market risk and sharper price fluctuations than large-cap stocks due to the fact that the earnings of mid-size companies tend to be less predictable and the stocks are traded less frequently. At times, it may be difficult to sell mid cap stocks at a price equal to their value.

Small Cap Growth – Growth stocks generally have above average growth potential, low dividends and high prices relative to standard measures. Growth stocks may not outperform value style investing. They generally are subject to greater, less predictable price changes than the securities of companies with larger market capitalizations.

Small Cap Value – Value stocks are generally undervalued in the marketplace with low prices relative to standard measures. Value stocks may remain undervalued. They generally are subject to greater, less predictable price changes than the securities of companies with larger market capitalizations.

Passive Equity Index– Index strategies are exposed to the same market risks identified above, respective to each capitalization strategy. Additionally, an Index strategy presents the risk of not precisely tracking its respective Index. An Index Fund may have tracking differences due to the transaction cost associated with buying and selling the constituents of an Index. The timing of external cash flows will influence the extent of tracking differences. We use futures contracts and/or Index ETFs to equitize cash to more closely track a respective Index.

Core Fixed Income – Market forces may affect a single issuer, industry or sector of the economy resulting in declines in the value of fixed income securities. The portfolio is exposed to mortgage risk. As interest rates rise, the duration of mortgage-related securities extends; conversely, as interest rates fall, mortgage-related securities are prepaid at a faster rate. Debt obligations are subject to the risk that issues may not be able to pay off the principal and interest when due.

Inflation Linked Portfolios – Inflation linked portfolios are subject to the same risk as other bond funds; increases in real interest rates will likely cause a decline in the market value of the bonds in the portfolio, and debt obligations are subject to the risk that issuers may not be able to pay off the principal and interest when due. Inflation linked securities are subject to the additional risk of declining interest payments during periods of falling inflation and deflation. Since inflation linked securities are primarily issued by the U.S. Treasury and financial institutions, such portfolios are also subject to the risk of limited diversification. In addition, to the extent a portfolio invests in zero coupon securities, these securities tend to be subject to greater price volatility than interest-paying securities of similar maturities.

Asset Allocation: Asset Allocation Portfolios, Asset Allocation Funds and Target Date Funds – They are subject to the same risks as the underlying MoA Funds in which they invest. Accordingly, the ability of a portfolio/fund to achieve its investment objective will depend largely on the performance of the selected underlying MoA Funds. There can be no assurance that either the portfolio/fund or the underlying MoA funds will achieve their investment objectives. Page | 9

Additionally, because the portfolio/fund invests in underlying MoA Funds and pays its own fees and expenses as well as a proportional share of the fees and expenses of the underlying MoA Funds in which it invests, the portfolio/fund may pay higher fees and expenses than portfolios/funds that do not invest in other mutual funds. Additional information regarding risks and investment strategies for each of the MoA Funds and the Cromwell Long Short Fund is available in each fund’s prospectus and statement of additional information.

We provide investment advisory services to Mutual of America, an insurance company and a registered investment adviser under the Investment Advisers Act of 1940. Such investment services relate to the General Account assets of Mutual of America, and we provide these services pursuant to a contractual arrangement at negotiated rates. In addition, we provide investment advisory services to the MoA Funds, each are open-end diversified management investment companies. Mutual of America provides administrative and accounting services to us that are material for our business.

The Code of Ethics requires our advisory employees and supervised persons who are designated as access persons to submit periodic reports detailing their securities holdings and transactions (subject to several exemptions contained in the rules). It also requires preapproval for certain securities transactions by these individuals, including purchases and sales of reportable securities, investments in initial public offerings, and private placements. The Code of Ethics explicitly requires those individuals subject to its provisions to report violations of the Code of Ethics to the Chief Compliance Officer promptly. In cases where there is, or appears to be, a conflict of interest between advisory employees or supervisory employees and a client, that situation must be reported immediately to the Chief Compliance Officer or General Counsel, and the matter shall be resolved in the best interests of the client. Page | 10

In particular, access persons, including portfolio managers, research analysts, traders, and those who provide advice to such persons (collectively, “investment personnel”), are subject to the following specific requirements under our Code of Ethics, among other things:

With certain specified exceptions under the Code of Ethics, generally no securities transactions can be effected in a security that is currently being purchased or sold by a client (a) by an access person, other than by investment personnel, on the day of the client transaction, or (b) by investment personnel within seven (7) days before or after a client transaction.

Except for non-reportable securities, purchases and sales of securities can only be made by obtaining prior written clearance. Pre-cleared conditional orders are in effect until the order is cancelled, expired or executed. Pre-cleared private placement transactions must be effected within 30 calendar days. All other pre-cleared transactions must be effected within two business days.

No personal securities transactions can be made in anticipation of a client’s transaction.

Purchases of securities by investment personnel in initial public offerings are not permitted.

Brokers’ confirmations and periodic statement information relating to securities transactions and holdings must be provided to Capital Management.

A copy of the Code of Ethics is available to you free of charge, upon request. To obtain a free copy of our Code of Ethics, please call (212) 224-1769 or write to: Kyle Medlin Senior Vice President & Chief Compliance Officer Mutual of America Capital Management LLC 320 Park Avenue New York, N.Y. 10022-6839 With respect to Capital Management’s asset allocation services among the funds offered through MoA Funds, 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 allocation services because it will allocate the assets of the client account to or among one or more of the MoA Funds, each of which generate additional fees for Capital Management that it would not otherwise earn if it allocated the assets of the client account to investment funds that do not generate such fees for Capital Management. The charges, fees and expenses, including but not limited to investment management fees, with respect to the MoA Funds, as described in the Prospectus and SAI, differ among such funds. This creates a conflict of interest because it provides an incentive for Capital Management to allocate assets to a MoA Fund that charges a relatively higher fee rather than another MoA Fund that charges a relatively lower fee. Capital Management mitigates the conflicts of interest noted above through communications to, and training and supervision of, its employees; by implementing policies and procedures reasonably designed to ensure that Capital Management provides investment advice that is in client’s best interest; and through disclosure of these conflicts to client. These conflicts of interest will also be mitigated by Capital Management’s adherence to any agreed upon asset allocation guidelines in the client’s Investment Policy Statement. Mutual of America, for certain of its contract holders, allocates pension assets among various investment alternatives (including funds not managed by us) that are available under Mutual of America’s variable annuity contracts. This activity often results in more assets of these contract holders being invested in funds that we advise and for which we receive a management fee. Recommended Page | 11

allocations by Mutual of America often result in proportionately more assets of these contract holders being allocated to funds that we advise, as compared to funds that are advised by other investment advisers. This presents a conflict of interest for Mutual of America, which Mutual of America mitigates through communications to, and training and supervision of, its employees; by implementing policies and procedures reasonably designed to ensure that it provides investment advice that is in a client’s best interest; and through disclosure of these conflicts to clients. This conflict of interest will also be mitigated by Mutual of America’s adherence to any agreed upon investment guidelines. There may be occasions when the same securities are owned by Mutual of America or another related person to Capital Management, and/or our clients. To some extent, this may be unavoidable in view of the large investment portfolio of Mutual of America’s General Account. This presents a conflict of interest for us, which we mitigate through communications to, and training and supervision of, our employees; by implementing policies and procedures reasonably designed to ensure that we provide investment advice that is in a client’s best interest; and through disclosure of these conflicts to clients. This conflict of interest will also be mitigated by our adherence to any agreed upon investment guidelines. Capital Management may choose to invest its own assets in shares of the funds within the MoA Funds, which we manage. In general, Capital Management currently does not purchase securities for its own account that are recommended for the portfolios of mutual funds and other clients we manage; however, we invest our own excess cash in government issued securities and investment grade corporate bonds until funds are needed for payment of other obligations and it is possible that we recommend such government issued securities and investment grade bonds to our clients. We also currently do not invest in any mutual funds, including those that we manage, for the portfolios of our non-mutual fund clients, except for asset allocation services described herein. While it may be possible that we will buy or sell securities that we also recommend to clients, we will not be a party to any concurrent transaction with a client (except for transactions in government issued securities and investment grade corporate bonds, as noted above) nor will we seek to profit or avoid or lessen any loss as to our own portfolio by providing advice or taking action that would disadvantage a client. Although we have procedures that permit cross trading, generally, we do not engage in cross trades.

When selecting a broker to execute a client’s securities trade, we will consider the full range and quality of a broker’s services, including execution capability, commission rate, financial responsibility, and responsiveness to us. We are not obligated to get the lowest possible commission cost, but rather, we will determine whether the transaction represents the best qualitative execution for the managed account. We recognize that volume has a direct bearing on costs in terms of obtaining the most competitive bid and offering prices in fixed income securities and of obtaining reasonable per share commission rates and satisfactory executions in equities. At the same time, situations may arise where we may wish to pay higher commissions to broker-dealers in order to obtain specialized research assistance of various types such as statistical information and special studies. We do not enter into any formal soft dollar arrangements with brokers and accordingly do not have any formal commitments to trade with specific brokers or to generate a predetermined level of commissions Page | 12

with any brokers for the purposes of receiving research or other services. Under our soft dollar policy, when arranging transactions, we seek the most favorable net results available after taking into consideration such factors as the size and difficulty of an order to execute a transaction and the ability of a broker to complete the transaction satisfactorily through to clearance, confirmation and delivery. Commission rates can be subject to negotiation based on these factors, as well as services provided. The commissions paid, however, are in the amounts that we determine, in good faith, to be reasonable in relation to the value of the research services provided. Moreover, the transactions involved will be the most appropriate use of clients’ commissions considering available alternatives from other brokers. All the client accounts that paid commissions to the broker providing such research services will benefit. In addition, other client accounts may also benefit from the knowledge acquired from the research. We intend that any and all research products and services we receive in connection with brokerage services will be dedicated to appropriate assistance to us in our performance of our investment decision-making responsibilities, as contemplated under Section 28(e) of the Securities and Exchange Act of 1934. Some brokers do provide unsolicited proprietary research to us. This research is used for all client accounts, even though certain clients may not have paid direct commissions to the brokers who provided the specific research. This research includes, but is not limited to, white papers, statistical analysis, publications on economic and political strategy, credit analysis, equity and fixed income market conditions, and company specific projections. In addition to the research services described, certain brokers provide invitations to attend conferences and meetings with management representatives of issuers or with other analysts and specialists. The costs associated with these conferences and meetings, such as lodging and travel, are paid by us. While we currently do not have clients that direct trades to certain brokers, we will accommodate clients that request it and develop policies tailored to the client’s needs as we deem appropriate. We do not encourage directed brokerage because the client may not receive the most favorable execution and may end up paying higher transactions costs. There may be times when we execute transactions for clients concurrently. When executing such transactions for several accounts, we rely on existing procedures to allocate executions fairly among those several accounts at an average price and as nearly as practicable on a pro-rata basis.

On a daily basis, we price holdings and publish performance for mutual fund and variable annuity portfolios. Deviations from expected performance trigger further review and analysis. Our portfolio managers or supervisory and client service personnel typically meet with the client quarterly to review the account. A more comprehensive supervisory review is conducted on a monthly basis. Clients receive account statements on a quarterly basis. These generally include holdings, performance, and transaction reports. Reports to or meetings with clients will in large part be dependent upon these clients’ needs, but will usually occur quarterly. Page | 13

Capital Management, in its sole discretion, may make similar payments for subsequent investments in any Institutional Client account established as a result of a referral. This compensation is derived solely from compensation otherwise payable to Capital Management. Due to the fee that will be paid to Securities LLC by Capital Management for referrals, Securities LLC has a significant economic incentive to refer Institutional Clients to Capital Management, resulting in a material conflict of interest on Securities LLC’s part. Securities LLC is not a current advisory client of Capital Management. We do not receive compensation for investment advisory services from persons other than the client.

Clients may obtain a copy of our complete Proxy Voting Policy and Procedures upon request and may also obtain information from us about how we voted any proxies on behalf of their accounts. To do so, please call (212) 224-1769 or write to:

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Kyle Medlin Senior Vice President & Chief Compliance Officer Mutual of America Capital Management LLC 320 Park Avenue New York, N.Y. 10022-6839 Any client directed voting would occur in accordance with the terms of the investment advisory agreement. If a client does not provide authorization to vote its shares, it is the responsibility of the client to arrange to receive proxy solicitations from its custodian.