flexPATH Strategies, LLC

Securities Disclosures

 Investment Advisory Services offered through flexPATH Strategies, LLC. Investor Disclosures: https://info.flexpathstrategies.com/disclosures

©2025 flexPATH Strategies, LLC. All Rights Reserved. The flexPATH Strategies name and logo are registered trademarks of flexPATH Strategies, LLC or its subsidiaries in the United States and elsewhere. All other trademarks are those of their respective owners.

Great Gray Trust Fund Disclosures 

Great Gray Trust Company, LLC Collective Investment Funds (“Great Gray Funds”) are bank collective investment funds; they are not mutual funds. Great Gray Trust Company, LLC serves as the Trustee of the Great Gray Funds and maintains ultimate fiduciary authority over the management of, and investments made in, the Great Gray Funds. flexPATH Strategies, LLC has been hired by the Trustee to assist in managing the Great Gray Funds. Great Gray Funds and their units are exempt from registration under the Investment Company Act of 1940 and the Securities Act of 1933, respectively. However, the Trustee maintains ultimate authority over the Fund.

Investments in the Great Gray Funds are not bank deposits or obligations of and are not insured or guaranteed by Great Gray Trust Company, LLC, any bank, the FDIC, the Federal Reserve, or any other governmental agency. The Great Gray Funds are commingled investment vehicles, and as such, the values of the underlying investments will rise and fall according to market activity; it is possible to lose money by investing in the Great Gray Funds.

Participation in Collective Investment Trust Funds is limited primarily to qualified retirement plans and certain state or local government plans and is not available to IRAs, health and welfare plans and, in certain cases, Keogh (H.R. 10) plans. Collective Investment Trust Funds may be suitable investments for plan fiduciaries seeking to construct a well-diversified retirement savings program. Investors should consider the investment objectives, risks, charges, and expenses of any pooled investment fund carefully before investing. The Additional Fund Information and Principal Risk Definitions (PRD) contains this and other information about a Collective Investment Trust Fund and is available at www.greatgray.com/principalriskdefinitions or ask for a free copy by contacting Great Gray Trust Company, LLC at (866) 427-6885.

Great Gray and Great Gray Trust Company are service marks used in connection with various fiduciary and non-fiduciary services offered by Great Gray Trust Company, LLC.

©2025 Great Gray Trust Company, LLC. All rights reserved.

Additional flexPATH Strategies, LLC Products Disclosures 

All documents are produced by and the opinions expressed are those of flexPATH Strategies, LLC as of the date of writing and are subject to change. This research is based on flexPATH Strategies proprietary research and analysis of global markets and investing. The information and/or analysis contained in this material have been compiled or arrived at from sources believed to be reliable, however flexPATH Strategies does not make any representation as their accuracy or completeness and does not accept liability for any loss arising from the use hereof. Some internally generated information may be considered theoretical in nature and is subject to inherent limitations associated therein. The reader should not assume that any investments in sectors and markets identified or described were or will be profitable. Investing entails risks, including possible loss of principal. The use of tools cannot guarantee performance. Past performance is no guarantee of future results. The information in this material may contain projections or other forward-looking statements regarding future events, targets or expectations, and is only current as of the date indicated. There is no assurance that such events or targets will be achieved, and may be significantly different than that shown here. The information in this material, including statements concerning financial market trends, is based on current market conditions, which will fluctuate and may be superseded by subsequent market events or for other reasons.

CITs are not mutual funds and are exempt from registration and regulation under the Investment Company Act of 1940 (the "1940 Act”), and their units are not registered under the Securities Act of 1933, or applicable securities laws of any state or other jurisdiction. Unit holders of the Funds are not entitled to the protections of the 1940 Act. The decision to invest in CITs should be carefully considered. The CITs unit values will fluctuate and may be worth more or less when redeemed, so unit holders may lose money. CITs are not sold by prospectus and are not available for investment by the public; Fund prices are not quoted in newspapers.

Risk Index: There is a quantitative and qualitative review of the glidepath that determines the risk category. The quantitative review starts with the RPAG proprietary TDF Risk Index, which incorporates four key measures: Equity exposure at retirement (age 65), Glidepath slope, Equity at the start of the glidepath, equity at the end of the glidepath.

Target Date Funds (TDF) series are categorized into three groups according to risk: Conservative, Moderate and Aggressive.

The risk index produces a number between 0 and 100— the higher the number, the more aggressive the strategy is. Conservative <55. Moderate is 55-69. Aggressive is > 69.

DOL TIPS

Target Date Retirement Funds – Tips for ERISA Plan Fiduciaries

U.S. Department of Labor | Employee Benefits Security Administration | February 2013
Target date retirement funds (also called target date funds or TDFs) have become an increasingly popular investment option in 401(k) plans and similar employee-directed retirement plans.  The U.S. Department of Labor’s Employee Benefits Security Administration (EBSA)prepared the following general guidance to assist plan fiduciaries in selecting and monitoring TDFs and other investment options in 401(k) and similar participant-directed individual account plans. Employers and other plan fiduciaries can learn more about their fiduciary responsibilities under the Employee Retirement Income Security Actof 1974 (ERISA) by visiting EBSA’s website at www.dol.gov/ebsa/compliance_assistance.html.

Target Date Fund Basics: With the growth of 401(k) and other individual account retirement plans, many more participants are responsible for investing their retirement savings. Target date retirement funds, or TDFs, can be attractive investment options for employees who do not want to actively manage their retirement savings. TDFs automatically rebalance to become more conservative as an employee gets closer to retirement. The “target date” refers to a target retirement date, and often is part of the name of the fund. For example, you might see TDFs with names like “Portfolio 2030,” “Retirement Fund 2030,” or “Target 2030” that are designed for individuals who intend to retire during or near the year 2030. Because of these features, many plan sponsors decide to use TDFs as their plan’s qualified default investment alternative (QDIA) under Department of Labor regulations. A QDIA is a default investment option chosen by a plan fiduciary for participants who fail to make an election regarding investment of their account balances.1 TDFs offer a long-term investment strategy based on holding a mix of stocks, bonds and other investments (this mix is called an asset allocation) that automatically changes over time as the participant ages. A TDF’s initial asset allocation, when the target date is a number of years away, usually consists mostly of stocks or equity investments, which often have greater potential for higher returns but also can be more volatile and carry greater investment risk. As the target retirement date approaches (and often continuing after the target date), the fund’s asset allocation shifts to include a higher proportion of more conservative investments, like bonds and cash instruments, which generally are less volatile and carry less investment risk than stocks. The shift in the asset allocation over time is called the TDF’s “glide path.” It is important to know whether a target date fund’s glide path uses a “to retirement” or a “through retirement” approach. A “to” approach reduces the TDF’s equity exposure over time to its most conservative point at the target date. A “through” approach reduces equity exposure through the target date so it does not reach its most conservative point until years later. Within this general framework, however, there are considerable differences among TDFs offered by different providers, even among TDFs with the same target date. For example, TDFs may have different investment strategies, glide paths, and investment-related fees. Because these differences can significantly affect the way a TDF performs, it is important that fiduciaries understand these differences when selecting a TDF as an investment option for their plan.

1 More information on QDIAs is available in the Departments publication “Automatic Enrollment 401(k) Plans for Small Businesses” (available at http://www.dol.gov/ebsa/pdf/automaticenrollment401kplans.pdf).

What to Remember When Choosing Target Date Funds: Establish a process for comparing and selecting TDFs. In general, plan fiduciaries should engage in an objective process to obtain information that will enable them to evaluate the prudence of any investment option made available under the plan. For example, in selecting a TDF you should consider prospectus information, such as information about performance (investment returns) and investment fees and expenses. You should consider how well the TDF’s characteristics align with eligible employees’ ages and likely retirement dates. It also may be helpful for plan fiduciaries to discuss with their prospective TDF providers the possible significance of other characteristics of the participant population, such as participation in a traditional defined benefit pension plan offered by the employer, salary levels, turnover rates, contribution rates and withdrawal patterns.

Establish a process for the periodic review of selected TDFs. Plan fiduciaries are required to periodically review the plan’s investment options to ensure that they should continue to be offered. At a minimum, the review process should include examining whether there have been any significant changes in the information fiduciaries considered when the option was selected or last reviewed. For instance, if a TDF’s investment strategy or management team changes significantly, or if the fund’s manager is not effectively carrying out the fund’s stated investment strategy, then it may be necessary to consider replacing the fund. Similarly, if your plan’s objectives in offering a TDF change, you should consider replacing the fund. Understand the fund’s investments – the allocation in different asset classes (stocks, bonds, cash), individual investments, and how these will change over time. Have you looked at the fund’s prospectus or offering materials? Do you understand the principal strategies and risks of the fund, or of any underlying asset classes or investments that may be held by the TDF? Make sure you understand the fund’s glide path, including when the fund will reach its most conservative asset allocation and whether that will occur at or after the target date. Some funds keep a sizeable investment in more volatile assets, like stocks, even as they pass their “target” retirement dates. Since these funds continue to invest in stock, your employees’ retirement savings may continue to have some investment risk after they retire. These funds are generally for employees who don’t expect to withdraw all of their 401(k) account savings immediately upon retirement, but would rather make periodic withdrawals over the span of their retirement years. Other TDFs are concentrated in more conservative and less volatile investments at the target date, assuming that employees will want to cash out of the plan on the day they retire. If the employees don’t understand the fund's glide path assumptions when they invest, they may be surprised later if it turns out not to be a good fit for them. Review the fund's fees and investment expenses. TDF costs can vary significantly, both in the amount and types of fees. Small differences in investment fees and costs can have a serious impact on reducing long term retirement savings. 2 Do you understand the fees and expenses, including any sales loads, for the TDF? If the TDF invests in other funds, did you consider the fees and expenses for both the TDF and the underlying funds? If the expense ratios of the individual component funds are substantially less than the overall TDF, you should ask what services and expenses make up the difference. Added expenses may be for asset allocation, rebalancing and access to special investments that can smooth returns in uncertain markets, and may be worth it, but it is important to ask. 2 A difference of just one percentage point in fees (1.5% as compared with 0.5%) over 35 years dramatically affects overall returns. If a worker with a 401(k) account balance of $25,000 averages a seven percent return, the worker will have $227,000 at retirement with the lower fee and $163,000 with the higher fee, assuming no further contributions. U.S. Department of Labor, Employee Benefits Security Administration, A Look At 401(k) Plan Fees, at http://www.dol.gov/ebsa/publications/401k_employee.html. Inquire about whether a custom or non-proprietary target date fund would be a better fit for your plan. Some TDF vendors may offer a pre-packaged product which uses only the vendor’s proprietary funds as the TDF component investments. Alternatively, a “custom” TDF may offer advantages to your plan participants by giving you the ability to incorporate the plan’s existing core funds in the TDF. Non- proprietary TDFs could also offer advantages by including component funds that are managed by fund managers other than the TDF provider itself, thus diversifying participants exposure to one investment provider. There are some costs and administrative tasks involved in creating a custom or non- proprietary TDF, and they may not be right for every plan, but you should ask your investment provider whether it offers them. Develop effective employee communications. Have you planned for the employees to receive appropriate information about TDFs in general, as a retirement investment option, and about individual TDFs available in the plan? Just as it is important for the plan fiduciary to understand TDF basics when choosing a TDF investment option for the plan, employees who are responsible for investing their individual accounts need information too. Disclosures required by law also must be considered. The Department published a final rule that, starting for most plans in August 2012, requires that participants in 401(k)-type individual account retirement plans receive greater information about the fees and expenses associated with their plans, including specific fee and expense information about TDFs and other investment options available under their plans. The Department of Labor is also working on regulations to improve the disclosures that must be made to participants specifically about TDFs. For example, in addition to general information about TDFs, the proposed regulations call for disclosures to include an explanation that an investment in a TDF is not guaranteed and that participants can lose money in the fund, including at and after the target date. Check EBSA’s website for updates on regulatory disclosure requirements. Take advantage of available sources of information to evaluate the TDF and recommendations you received regarding the TDF selection. While TDFs are relatively new investment options, there are an increasing number of commercially available sources for information and services to assist plan fiduciaries in their decision- making and review process. Document the process. Plan fiduciaries should document the selection and review process, including how they reached decisions about individual investment options. Related Information: From the Department of Labor, Investor Bulletin: Target Date Retirement Funds, A Look at 401(k) Plan Fees, Meeting Your Fiduciary Responsibilities, Understanding Retirement Plan Fees and Expenses, Understanding Your Retirement Plan Fees, Selecting and Monitoring Pension Consultants – Tips for Plan Fiduciaries From the SEC: Beginners’ Guide to Asset Allocation, Diversification, and Rebalancing, Invest Wisely: An Introduction to Mutual Funds, Mutual Fund Fees and Expenses From the Financial Industry Regulatory Authority (FINRA): Fund Analyzer

Scorecard System Methodology. The Scorecard System Methodology incorporates both quantitative and qualitative factors in evaluating fund managers and their investment strategies. The Scorecard System is built around pass/fail criteria, on a scale of 0 to 10 (with 10 being the best) and has the ability to measure active, passive and asset allocation investing strategies. Active and asset allocation strategies are evaluated over a five-year time period, and passive strategies are evaluated over a three-year time period. Eighty percent of the fund’s score is quantitative (made up of eight unique factors), incorporating modern portfolio theory statistics, quadratic optimization analysis, and peer group rankings (among a few of the quantitative factors). The other 20 percent of the score is qualitative, taking into account things such as manager tenure, the fund’s expense ratio relative to the average fund expense ratio in that asset class category, and the fund’s strength of statistics (statistical significance). Other criteria that may be considered in the qualitative score includes the viability of the firm managing the assets, management or personnel issues at the firm, and/or whether there has been a change in direction of the fund’s stated investment strategy. RPAG Average Underlying Fund Score. The Average Underlying Fund Score is a simple average of the RPAG score for the underlying funds within each TDF series.

Index Definitions:

US Aggregate Index. The Barclays US Aggregate Bond Index is a broad-based flagship benchmark that measures the investment grade, US dollar-denominated, fixed-rate taxable bond market. The index includes Treasuries, government-related and corporate securities, MBS (agency fixed-rate and hybrid ARM pass-throughs), ABS and CMBS (agency and non-agency). Provided the necessary inclusion rules are met, US Aggregatee ligible securities also contribute to the multi-currency Global Aggregate Index and the US Universal Index, which includes high yield and emerging markets debt. The US Aggregate Index was created in 1986 with history backfilled to January 1, 1976. S&P 500. The S&P 500® is widely regarded as the best single gauge of large-cap U.S. equities. There is over USD 7.8 trillion benchmarked to the index, with index assets comprising approximately USD 2.2 trillion of this total. The index includes 500 leading companies and captures approximately 80% coverage of available market capitalization. Dow Jones US Completion Total Stock Market Index. To represent all U.S. equity issues with readily available prices, excluding components of the S&P 500. To be included in the index, a security must be the primary equity issue of a U.S. company. Excluded are bulletin-board issues, because in general they do not have consistently readily available prices. — The index is weighted by float-adjusted market capitalization. — The Dow Jones U.S. Completion Total Stock Market Index was first calculated on January 30, 1987. MSCI ACWI Ex USA IMI. The MSCI ACWI ex USA Investable Market Index (IMI) captures large, mid and small cap representation across 22 of 23 Developed Markets (DM) countries (excluding the United States) and 23 Emerging Markets (EM) countries*. With 6,056 constituents, the index covers approximately 99% of the global equity opportunity set outside the US. FTSE EPRA/NAREIT Developed Index. The FTSE EPRA/NAREIT Developed Index is designed to track the performance of listed real estate companies and REITS worldwide. By making the index constituents free-float adjusted, liquidity, size and revenue screened, the series is suitable for use as the basis for investment products, such as derivatives and Exchange Traded Funds (ETFs). US Tips. The Barclays US Government Inflation-Linked Bond Index measures the performance of the US Treasury Inflation Protected Securities ("TIPS") market. The index includes TIPS with one or more years remaining maturity with total outstanding issue size of $500m or more. History for the TIPS index goes back to the inception of the market (1997) and returns are available in local currency and in most major currencies hedged or un-hedged. Sub indices are available by maturity. The TIPS index is the largest component of World Government inflation-linked index and is widely to benchmark the asset class.

Bloomberg Commodities Index. The index is made up of 22 exchange-traded futures on physical commodities. » The index currently represents 20 commodities, which are weighted to account for economic significance and market liquidity. » Weighting restrictions on individual commodities and commodity groups promote diversification. Russell 1000 Index. The Russell 1000 Index measures the performance of the large-cap segment of the U.S. equity universe. It is a subset of the Russell 3000® Index and includes approximately 1000 of the largest securities based on a combination of their market cap and current index membership. The Russell 1000 represents approximately 92% of the U.S. market. The Russell 1000 Index is constructed to provide a comprehensive and unbiased barometer for the large-cap segment and is completely reconstituted annually to ensure new and growing equities are reflected. Russell 2000 Index. The Russell 2000 Index measures the performance of the small-cap segment of the U.S. equity universe. The Russell 2000 Index is a subset of the Russell 3000® Index representing approximately 10% of the total market capitalization of that index. It includes approximately 2000 of the smallest securities based on a combination of their market cap and current index membership. The Russell 2000 is constructed to provide a comprehensive and unbiased small-cap barometer and is completely reconstituted annually to ensure larger stocks do not distort the performance and characteristics of the true small-cap opportunity set. U.S. Large Cap Stocks. Primarily large capitalization companies. U.S. Mid/Small Cap Stocks. Primarily small and mid capitalization companies. International Stocks. Primarily foreign companies. U.S. Bonds. A government bond that offers a fixed rate of interest over a fixed period of time. U.S. Inflation-linked Bonds. Securities designed to help protect investors from inflation. Global Real Estate. Investments that seek to track an index related to the purchase of global real estate investment trusts (a company that owns or finances income-producing real estate). Commodities. Basic goods used in commerce that are interchangeable with other commodities of the same type. Investing involves risk, including possible loss of principal. The funds are not FDIC insured and there is no bank guarantee. The principal value of the funds is not guaranteed at any time including at and after the target date. Asset allocation models and diversification do not promise any level of performance or guarantee against loss of principal. Investment in the funds is subject to the risks of the underlying funds. flexPATH Strategies, LLC funds are Collective Investment Trusts available only to qualified plans and governmental 457(b) plans. They are not mutual funds and are not registered with the Securities and Exchange Commission.  Great Gray Retirement and Institutional Services Company serves as Trustee and is responsible for maintaining and administering the funds. Investment Advisory Services offered through flexPATH Strategies, LLC.

The data and information presented are for informational purposes only. The data and information contained herein should be treated in a confidential manner and may not be transmitted, reproduced or used in whole or in part for any other purpose, nor may it be disclosed without the prior written consent of flexPATH Strategies, LLC. By accepting this material, the Recipient agrees not to distribute or provide this information to any other person.This material is qualified in its entirety by the flexPATH Target Date Funds (“the Funds”) offering memoranda and any supplements thereto, which may be obtained from flexPATH by calling 800.974.0188. Please refer to the offering documentation and Fund documents for further important information regarding the Funds, including the risks and costs associated with making investments in the Funds. No representation regarding the suitability of these instruments and strategies for a particular investor or plan participant is made. Separately managed account and bank collective fund guidelines and strategies may differ and may involve different asset classes and different degrees and types of risks. Eligible plans should consider whether an investment in one or more of the Funds satisfies the diversification requirements and prudence requirements of ERISA and/or other applicable law and regulations thereunder applied to the plans’ own circumstances and should inform themselves as to any other applicable legal requirements, and taxation and exchange control regulations in the countries of their sponsors’ or participants’ citizenship, residence or domicile which might be relevant. Predictions, opinions, and other information contained in this material are subject to change continually and without notice of any kind and may no longer be true after the date indicated. Any forward-looking statements speak only as of the date they are made, and flexPATH Strategies assumes no duty to and does not undertake to update forward-looking statements. Forward-looking statements are subject to numerous assumptions, risks and uncertainties, which change over time. Actual results may differ materially from those projected in these materials due to factors including, without limitation, economic and market conditions, political events and investor sentiments, liquidity of secondary markets, level and volatility of interest rates, currency exchange rates, and competitive conditions. flexPATH Strategies is not and will not become a fiduciary or investment financial professionals with respect to any person or plan by reason of providing this material. This material is intended solely for use by retirement plan sponsors, their consultants, and advisors to provide them background information. This material is not intended for use by the general public or for use by any retirement plan participants, nor is it an offer or solicitation to the general public or any retirement plan participants to buy or sell any investment products. NO SECURITIES REGISTRATION: THE UNITS OFFERED BY THE FUNDS (“UNITS”) HAVE NOT BEEN REGISTERED WITH, AND THE MERITS OF THE OFFERING OF UNITS HAVE NOT BEEN PASSED UPON BY, THE SECURITIES AND EXCHANGE COMMISSION OR ANY OTHER FEDERAL OR STATE REGULATORY AGENCY IN RELIANCE ON EXEMPTIONS FROM REGISTRATION UNDER FEDERAL AND STATE SECURITIES LAWS.

Market indexes are included in this report only as context reflecting general market results during the period. flexPATH Strategies may provide research on funds that are not represented by such market indexes. Accordingly, no representations are made that the performance or volatility of any fund where flexPATH Strategies provides research will track or reflect any particular index. Market index performance calculations are gross of management and performance incentive fees. Scorecard System evaluates funds based proprietary research. Scorecard System results may vary with each use and over time. The use of the Scorecard System does not guarantee results. It is an investment analysis tool intended to aid in the investment decision making process. Any decision to invest in a fund should be made in consultation with qualified tax, legal or investment professional advice. The performance data used in this material represents past performance. Past performance does not guarantee future results. Investing involves risk, including the possible loss of principal. Past performance does not guarantee future results. Asset allocation alone cannot eliminate the risk of fluctuating prices and uncertain returns. There is no guarantee that a diversified portfolio will outperform a non-diversified portfolio in any given market environment. No investment strategy, such as asset allocation, can guarantee a profit or protect against a loss. Actual client results will vary based on investment selection, timing, and market conditions. It is not possible to invest directly in an index. A mutual fund's investment return and principal value will fluctuate. Upon redemption, shares may be worth more or less than their original cost. This material was created to provide accurate and reliable information on the subjects covered but should not be regarded as a complete analysis of these subjects. It is not intended to provide specific legal, tax or other professional advice. The services of an appropriate professional should be sought regarding your individual situation. flexPATH Strategies nor its subsidiaries or affiliates offer tax or legal advice. Mutual funds are sold by prospectus only. Before investing, investors should carefully consider the investment objectives, risks, charges and expenses of a mutual fund. The fund prospectus provides this and other important information. Please contact your representative or the Company to obtain a prospectus. Please read the prospectus carefully before investing or sending money. A collective investment trust fund (CIT) is a pooled investment vehicle that is exempt from SEC registration as an investment company under Section 3(c)(11) of the Investment Company Act of 1940 and maintained by a bank or trust company for the collective investment of qualified retirement plans. CITs are authorized by the Office of the Comptroller of the Currency (OCC) and are also known as “A2” funds, referring to the section in OCC rules that defines them. The Fund is not a mutual fund and not subject to the same registration requirements and restrictions as mutual funds. These funds are NOT FDIC insured, NOT an obligation or a deposit, and involve investment risk, including possible loss of principal. This report is for informational purposes only, and is not a solicitation, and should not be considered as investment or tax advice. The information has been drawn from sources believed to be reliable, but its accuracy is not guaranteed, and is subject to change. Investing involves risk, including the possible loss of principal. Past performance does not guarantee future results. Asset allocation alone cannot eliminate the risk of fluctuating prices and uncertain returns. There is no guarantee that a diversified portfolio will outperform a non-diversified portfolio in any given market environment. No investment strategy, such as asset allocation, can guarantee a profit or protect against a loss. Actual client results will vary based on investment selection, timing, and market conditions. It is not possible to invest directly in an index. Investing involves risk, including possible loss of principal. The funds are not FDIC insured and there is no bank guarantee. The principal value of the funds is not guaranteed at any time including at and after the target date. Asset allocation models and diversification do not promise any level of performance or guarantee against loss of principal. Investment in the funds is subject to the risks of the underlying funds. flexPATH Strategies are Collective Investment Trusts available only to qualified plans and governmental 457(b) plans. They are not mutual funds and are not registered with the Securities and Exchange Commission. Great Gray and Institutional Services Company serves as Trustee and is responsible for maintaining and administering the funds. The data and information presented are for informational purposes only. The data and information contained herein should be treated in a confidential manner and may not be transmitted, reproduced or used in whole or in part for any other purpose, nor may it be disclosed without the prior written consent of flexPATH Strategies, LLC. By accepting this material, the Recipient agrees not to distribute or provide this information to any other person. l. The PRD should be read carefully before investing.