ALAN BILLER AND ASSOCIATES

Alan D. Biller & Associates, Inc. ("ABA", the "Firm," or "we"), was founded in 1982 and registered with the Securities and Exchange Commission in 1995 as an investment adviser. We are a pension consultant, as defined under SEC regulations, and primarily provide investment advice with respect to ERISA-regulated single-employer and multi-employer ("Taft-Hartley") benefit plans, and other plans (some of which are ERISA-regulated) established by corporations, public entities, endowments, and foundations. All of these are collectively referred to as "Plans" and their appointed boards of trustees or other fiduciaries are referred to as the "Trustees." Upon Plan employer request, we also provide discretionary advisory services for small amounts of non-Plan assets (representing less than one-half percent of our total assets under advisement).

ABA's principal owners are Alan Biller, Chairman and CFO, and Nancy Melton, Vice Chair. The Firm is headquartered in Menlo Park, California.

We occasionally provide services to other institutions. These services may involve assistance with strategy and plan design, among other services to be negotiated on a client-by-client basis.

Services ABA Offers to Plan Clients

ABA offers services for defined benefit ("DB"), defined contribution ("DC"), Health & Welfare, and related Plans. Although ABA's services vary based on the type of Plan, in general, ABA offers the following standard services:

• - Attend meetings of Trustees
• - Report on account, manager and Plan performance
• - Report on ABA monitoring
• - Recommend/implement manager changes, as needed (e.g., put a manager on watch/replace it)
• - Monitor asset allocation and recommend/implement rebalancing changes, as needed*
• - Report on managers' periodic attestations of compliance with investment guidelines**
• - Review Plan investment policy and account guidelines and recommend/implement changes, as appropriate
• - Report on ABA work for the Plan to the Trustees
• - Analyze portfolio holdings and structure on an on-going basis
• - Review, monitor, and report on manager compliance with best execution policies and practices*
• - Conduct searches for new or replacement investment options, as needed
• - Draft guidelines for single client accounts (e.g., stable value), as needed
• - Conduct traditional asset class manager searches, negotiate fees, help draft contracts, and manage account funding
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*Services for Plans other than 401k Plans
**Services for Plans using single-client accounts

We negotiate the terms of each Plan's advisory agreement (the "Advisory Agreement"), including the services we will provide, whether we accept the Plan on a discretionary (OCIO Services) or non-discretionary basis, our fees, and other terms of the Plan's relationship with us. Refer to Negotiability of Fees and Terms, and Item 16, Investment Discretion, below. Because terms are subject to negotiation, the information provided in this Brochure is necessarily general and does not address all details that may be applicable to a particular Plan following negotiation. A Plan's Advisory Agreement governs its relationship with ABA and Trustees should refer to their Advisory Agreement for specific terms that apply to their Plan.

Investments

Depending on the needs of a client, we will select (for discretionary clients) or recommend and provide advice (for non-discretionary clients) commingled or separate account managers or private fund managers (collectively, "Managers") who invest in one or more of the following (collectively, “Investments”).

Listed or over-the-counter, domestic or foreign, common, preferred, or convertible equity securities (including active, index, enhanced index, and synthetic portfolios); domestic or foreign debt securities (including derivatives and synthetic portfolios); warrants and rights; options and futures contracts; guaranteed investment contracts ("GICs"); commercial paper; certificates of deposit; shares of open-end investment management companies ("mutual funds"); shares of closed-end investment management companies or unit investment trusts ("UITs"); exchange-traded funds ("ETFs"); municipal securities; obligations issued or guaranteed by the U.S. Treasury, government agencies, or government sponsored enterprises; and temporary "sweep" arrangements where cash balances are transferred into money market funds, mutual funds, or bank accounts; and

Where alternative asset classes are appropriate, for example: 

• - Real estate (equity, mortgage, core, and opportunistic)
• - Private equity (venture and buyout)
• - Hedge funds and market-neutral accounts
• - Group annuities
• - Terminal funding arrangements
• - Commodities and agricultural and timber land
• - Tactical asset allocation (both domestic and foreign)
• - Infrastructure.
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As explained in Item 16, Investment Discretion, ABA does not directly invest the assets of a client (or a client's Plan), except to allocate such assets to the Managers who will be responsible for investing and re-investing the assets of the client (or client's Plan) allocated to them by ABA. For discretionary clients, ABA is granted full authority and discretion (subject to any specific limitations on assets which are to be treated as non-discretionary), on the client's behalf and risk, to manage the client's investment account(s), including hiring, firing, allocating and re-allocating assets among, and otherwise managing the Managers. Clients understand and agree that the separate account managers and private Investment managers selected by ABA are responsible for making, monitoring, and managing the direct investments in securities, as described in this Item 4.

Tailored Services & Restrictions

We tailor our services and advice to the specific needs of each client (or a client's Plan). In the case of Plan clients, we base our advice on governing Plan documents and an investment policy statement developed to define the investing framework, asset allocation, goals, and measurement standards. Each Plan has unique expectations, as well as risk tolerance. We begin by identifying the applicable time horizon and acceptable levels of investment risk. For Plans with well-defined liabilities (typically Defined Benefit or Health & Welfare), based on detailed analyses of assets or of assets and liabilities, we set investment ranges for each asset class. Once policies and objectives have been adopted, we monitor them. As appropriate, we recommend modifications to keep them current with the Plan's changing needs and market developments. Subject to regulatory, fiduciary, and contractual requirements applicable to each Plan, we permit the Trustees to impose restrictions on investing in certain securities or types of securities.

Assets Advised

As of October 31, 2025, ABA had approximately $65,069,635,580 in assets under management related to holdings of clients for which it provides OCIO, retirement plan consulting, and advisory services.