WILSHIRE

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 270 employees in 9 offices. Biographical information on certain key personnel is contained in the supplement to this Brochure.

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.

Wilshire provides diverse discretionary and non-discretionary investment advisory and management services and products to funds, accounts, investors, and intermediaries. Wilshire has assets under advisement of approximately $1,515,402,163,921 as of December 31, 2024, including approximately $122,810,000,227 in discretionary assets under management and $854,894,075 in non-discretionary assets under management. 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 clients 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 or opt-in/out of specific investment opportunities in External Funds. Such sponsored funds include Wilshires 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 Wilshires 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 clients portfolio of External Funds
• 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 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 Wilshire-sponsored 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 funds 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 clients risk tolerances, return goals, and any legal or regulatory restrictions. Clients are provided with regular reports detailing Wilshires assessment. Clients may be given access to Wilshires 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 Wilshires products, services, investment approach and advice differ between clients (including discretionary accounts and even where similarly situated) and not all of Wilshires 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.

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 Wilshires services are provided on an open architecture model (in which Wilshire uses exclusively third-party products to implement the clients 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.

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. Wilshires analytics solutions, including Wilshire Compass and Wilshire Trust Universe Comparison Services, are intended to help clients in their investment evaluation and decision-making.

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 Wilshires analytical tools, responsibilities of the customer, fees and other standard contractual terms.