VARIABLE RETURN SEPARATE ACCOUNTS OF NATIONWIDE TRUST COMPANY * Vngrd Ttl Stmkt Indx Fd As Pooled Separate Account

Based on U.S. Department of Labor Form 5500 filings (plan years 2022–2024), 1 U.S. retirement plans report holding VARIABLE RETURN SEPARATE ACCOUNTS OF NATIONWIDE TRUST COMPANY * Vngrd Ttl Stmkt Indx Fd As Pooled Separate Account in their Schedule of Assets, totaling $5.5M in parsed positions. Matched on the normalized security name across each plan’s latest filing and ranked by position size.