STATEMENT OF ADDITIONAL INFORMATION
MUTUAL OF AMERICA INVESTMENT CORPORATION
320 PARK AVENUE,
NEW YORK, NEW YORK 10022
800-468-3785
EQUITY INDEX FUND (MAEIX)
2015 RETIREMENT FUND (MURFX)
ALL AMERICA FUND (MAAKX)
2020 RETIREMENT FUND (MURGX)
SMALL CAP VALUE FUND (MAVKX)
2025 RETIREMENT FUND (MURHX)
SMALL CAP GROWTH FUND (MAGKX)
2030 RETIREMENT FUND (MURIX)
SMALL CAP EQUITY INDEX FUND (MASOX)
2035 RETIREMENT FUND (MURJX)
MID CAP VALUE FUND (MAMVX)
2040 RETIREMENT FUND (MURLX)
MID-CAP EQUITY INDEX FUND (MAMEX)
2045 RETIREMENT FUND (MURMX)
COMPOSITE FUND (MACHX)
2050 RETIREMENT FUND (MURNX)
INTERNATIONAL FUND (MAIFX)
2055 RETIREMENT FUND ((MUROX)
CATHOLIC VALUES INDEX FUND (MACCX)
2060 RETIREMENT FUND (MURPX)
MONEY MARKET FUND (MAAXX)
2065 RETIREMENT FUND (MURQX)
MID-TERM BOND FUND (MAMBX)
CONSERVATIVE ALLOCATION FUND (MACAX)
BOND FUND (MABDX)
MODERATE ALLOCATION FUND (MAMOX)
RETIREMENT INCOME FUND (MARMX)
AGGRESSIVE ALLOCATION FUND (MAANX)

This Statement of Additional Information (SAI) is not a prospectus. You should read it in conjunction with the Mutual of America Investment Corporation (the “Investment Company” or “MOAIC”) Prospectus dated May 1, 2023, and you should keep it for future use. The Investment Company’s audited financial statements, and the independent registered public accounting firm’s report thereon, included in its most recent annual report to shareholders for the period ended December 31, 2022 are incorporated by reference and made a part of this SAI. (See File No. 811-05084, filed March 9, 2023).
Copies of the Prospectus and most recent shareholder report are available to you at no charge. To obtain a copy of either document, you may write to the Investment Company at the above address or call the toll-free telephone number listed above.
Statement of Additional Information dated May 1, 2023, supplemented as of July 18, 2023 to update the distribution arrangements disclosure and provide certain other updates

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INVESTMENT COMPANY’S FORM OF OPERATIONS
History and Operating Form
The Investment Company was formed on February 21, 1986 as a Maryland corporation. It is an open-end management investment company registered under the Investment Company Act of 1940, as amended (the “1940 Act”). The Investment Company was created to replace a former actively managed separate account of Mutual of America Life Insurance Company (“Insurance Company”).
The Investment Company issues separate classes (or series) of stock, each of which represents a separate portfolio of investments (a “Fund”). There are currently twenty-eight Funds: the Equity Index Fund, All America Fund, Mid Cap Value Fund, Mid-Cap Equity Index Fund, Small Cap Value Fund, Small Cap Growth Fund, Small Cap Equity Index Fund, Composite Fund, International Fund, Catholic Values Index Fund, Bond Fund, Mid-Term Bond Fund, Money Market Fund, Retirement Income Fund, 2015 Retirement Fund, 2020 Retirement Fund, 2025 Retirement Fund, 2030 Retirement Fund, 2035 Retirement Fund, 2040 Retirement Fund, 2045 Retirement Fund, 2050 Retirement Fund, 2055 Retirement Fund, 2060 Retirement Fund and 2065 Retirement Fund (together, these twelve Funds are sometimes referred to as the “Retirement Funds”), Conservative Allocation Fund, Moderate Allocation Fund and Aggressive Allocation Fund (together, these three Funds are sometimes referred to as the “Allocation Funds”). Prior to May 1, 1994, the All America Fund was known as the Stock Fund and had different investment objectives.
Offering of Shares
Shares of the Funds are available for purchase in connection with variable annuity contracts supporting qualified retirement plans and also available for purchase by institutional and retail investors. In addition, the shares of the Funds may be made available to other investors without prior advance notice.
Description of Shares
The authorized capital stock of the Investment Company consists of 18.75 billion shares of common stock, $0.10 par value. The Investment Company currently has twenty-eight classes of common stock, with each class representing a Fund. The Investment Company may establish additional Funds and may allocate its authorized shares either to new classes or to one or more of the existing classes.
All shares of common stock, of whatever class, are entitled to one vote. The votes of all classes are cast on an aggregate basis, except that if the interests of the Funds differ or a matter relates to fewer than all of the Funds, then the voting is on a Fund-by-Fund basis. Examples of matters that would require a Fund-by-Fund vote are changes in the fundamental investment policy of a particular Fund and approval of the Investment Advisory Agreement or a Subadvisory Agreement for the Fund. The shares of each Fund, when issued, will be fully paid and nonassessable and will have no preference, preemptive, conversion, exchange or similar rights. Shares do not have cumulative voting rights. Each issued and outstanding share in a Fund is entitled to participate equally in dividends and other distributions declared by the Fund and in the net assets of that Fund upon liquidation or dissolution remaining after satisfaction of outstanding liabilities. Accrued liabilities that are not allocable to one or more Funds will generally be allocated among the Funds in proportion to their relative net assets. In the unlikely event that any Fund incurred liabilities in excess of its assets, the other Funds could be liable for the excess.

INVESTMENT STRATEGIES AND RELATED RISKS
The Prospectus describes each Fund’s principal investment strategy(ies) and the related risks. You should refer to “Additional Information on Fund Objectives, Principal Investment Strategies and Principal Investment Risks” in the Prospectus to learn about those strategies and risks.
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Additional Permitted Investments
The Funds may use investment strategies and purchase types of securities in addition to those discussed in the Prospectus.
Equity Index Fund, Mid-Cap Equity Index Fund, Small Cap Equity Index Fund, and Catholic Values Index Fund: In addition to common stocks, the Funds may invest in:
futures and options,
exchange traded funds,
money market instruments, and
U.S. Government and U.S. Government agency obligations.
All America Fund: In addition to common stocks, Mutual of America Capital Management LLC (the “Adviser” or “Capital Management”), who actively manages approximately 40% of the net assets of the All America Fund (the “Active Assets”), may invest assets in:
futures and options contracts,
exchange traded funds,
securities convertible into common stocks, including warrants and convertible bonds,
bonds,
money market instruments,
U.S. Government and U.S. Government agency obligations,
foreign securities and ADRs, and
preferred stock.
The portion of the All America Fund invested to replicate the S&P 500 ® Index (the “Indexed Assets”) also may be invested in:
money market instruments, and
U.S. Government and U.S. Government agency obligations.
The Adviser may manage cash allocated to the Active Assets prior to investment in securities.
Mid Cap Value Fund: In addition to common stocks, the Mid Cap Value Fund may invest in:
securities convertible into common stocks, including warrants and convertible bonds,
bonds,
money market instruments,
U.S. Government and U.S. Government agency obligations,
foreign securities and ADRs,
futures and options contracts, and
preferred stock.
Small Cap Value Fund: In addition to common stocks, the Small Cap Value Fund may invest in:
securities convertible into common stocks, including warrants and convertible bonds,
bonds,
money market instruments,
U.S. Government and U.S. Government agency obligations,
foreign securities and ADRs,
futures and options contracts, and
preferred stock.
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Small Cap Growth Fund: In addition to common stocks, the Small Cap Growth Fund may invest in:
securities convertible into common stocks, including warrants and convertible bonds,
bonds,
money market instruments,
U.S. Government and U.S. Government agency obligations,
foreign securities and ADRs,
futures and options contracts, and
preferred stock.
Composite Fund: In addition to common stocks, the equity portion of the Composite Fund may be invested in:
securities convertible into common stocks, including warrants,
preferred stock,
money market instruments,
U.S. Government and U.S. Government agency obligations,
foreign securities and ADRs, and
futures and options contracts.
In addition to investment grade debt securities of the type described in the Prospectus, the fixed-income portion of the Composite Fund may be invested in:
asset-backed securities,
money market instruments,
non-investment grade debt securities,
foreign securities,
options, futures contracts and options on futures contracts, and
equipment trust certificates.
International Fund: In addition to common stocks, foreign securities and ADRs, and exchange traded funds, the International Fund may invest in:
futures and options contracts, and
money market instruments.
Bond Fund and Mid-Term Bond Fund (the “Bond Funds”): In addition to investment grade debt securities of the type described in the Prospectus, each Bond Fund may invest in:
asset-backed securities,
below-investment grade securities, for up to 20% of its assets,
foreign securities,
cash and money market instruments,
stocks acquired either by conversion of fixed-income securities or by the exercise of warrants attached to fixed income securities,
preferred stock,
options, futures contracts and options on futures contracts, and
equipment trust certificates.
Money Market Fund: In addition to commercial paper and U.S. Treasury Bills, the Fund may invest in any of the following kinds of money market instruments, payable in United States dollars:
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securities issued or guaranteed by the U.S. Government or a U.S. Government agency or instrumentality;
negotiable certificates of deposit, bank time deposits, bankers’ acceptances and other short-term debt obligations of domestic banks and foreign branches of domestic banks and U.S. branches of foreign banks, which at the time of their most recent annual financial statements show assets in excess of $5 billion;
certificates of deposit, time deposits and other short-term debt obligations of domestic savings and loan associations, which at the time of their most recent annual financial statements show assets in excess of $1 billion;
repurchase agreements covering government securities, certificates of deposit, commercial paper or bankers’ acceptances;
variable amount floating rate notes; and
debt securities issued by a corporation.
The Money Market Fund may also enter into transactions in options, futures contracts and options on futures contracts on United States Treasury securities.
Under the Money Market Fund’s investment policy, money market instruments and other short-term debt securities means securities that have a remaining term to maturity of 397 calendar days or less. The dollar-weighted average maturity of the securities held by the Money Market Fund will not exceed 60 days.
The securities in the Money Market Fund must meet the following quality requirements —
All of the securities held by the Money Market Fund must have a remaining maturity of 397 calendar days or less; and
All of the securities held by the Money Market Fund must have been determined to present minimal credit risks to the Fund at the time of purchase In accordance with policies and procedures adopted by the Fund’s Board of Directors.
The Adviser must provide an ongoing review of whether each security (other than any U.S. government security) continues to present minimal credit risks. Upon the occurrence of a default with respect to a portfolio security, a portfolio security ceasing to be an eligible security, or an event of insolvency with respect to the issuer of a security or the provider of any guarantee, then the Fund will sell any such securities as soon as practicable, unless the Board of Directors determines that sale of those securities would not be in the best interests of the Fund.
The Money Market Fund will not invest more than 5% of its total assets in securities of, or subject to puts from, any one issuer (other than U.S. government securities and repurchase agreements fully collateralized by U.S. government securities) provided that (a) the Fund may invest up to 10% of its total assets in securities issued or guaranteed by a single issuer with respect to which the Fund has purchased an unconditional put and (b) the Fund may invest up to 25% of its total assets in the securities of a single issuer for up to three business days, provided that it does so with respect to only one issuer at any time.
Retirement Funds: In addition to shares of other Funds of the Investment Company, the Retirement Funds may each invest in:
securities issued or guaranteed by the U.S. Government or a U.S. Government agency or instrumentality; and
commercial paper and other short-term paper as defined in the 1940 Act.
Allocation Funds: In addition to shares of other Funds of the Investment Company, the Aggressive Allocation, Moderate Allocation and Conservative Allocation Funds may each invest in:
securities issued or guaranteed by the U.S. Government or a U.S. Government agency or instrumentality; and
commercial paper and other short-term paper as defined in the 1940 Act.
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Additional Investment Strategies
Lending of Securities
The Funds have the authority to lend their securities. The Funds will not lend any securities until the Investment Company’s Board of Directors approves a form of securities lending agreement. Refer to “Fundamental Investment Restrictions”, paragraph 9, and “Non-Fundamental Investment Policies”, paragraph 9, for descriptions of the fundamental and current restrictions on lending by the Funds.
Upon lending securities, a Fund must receive as collateral cash, securities issued or guaranteed by the United States Government or its agencies, or standby letters of credit, not issued by the Fund’s banking lending agent. The collateral amount at all times while the loan is outstanding must be maintained in amounts equal to at least 100% of the current market value of the loaned securities.
The Fund will continue to be entitled to receive substitute payments in the amount of interest or dividends on the securities lent. In addition, it will receive a portion of the income generated by the short-term investment of cash received as collateral, or, alternatively, where securities or a letter of credit are used as collateral, a lending fee paid directly to the Fund by the borrower of the securities. A Fund will have the right to terminate a securities loan at any time. The Fund will have the right to regain record ownership of loaned securities in order to exercise beneficial rights, such as voting rights or subscription rights.
Loans of securities will be made only to firms that the Adviser deems creditworthy. There are risks of delay in recovery and even loss of rights in the collateral if the borrower of securities defaults, becomes the subject of bankruptcy proceedings or otherwise is unable to fulfill its obligations or fails financially.
Repurchase Agreements
The Funds have the authority to enter into repurchase agreements. A Fund may not invest more than 10% of its total assets in repurchase agreements or time deposits that mature in more than seven days. The Funds will not enter into any repurchase agreements until the Investment Company’s Board of Directors approves a form of repurchase agreement and authorizes entities as counterparties.
Under a repurchase agreement, a Fund acquires underlying debt instruments for a relatively short period (usually not more than one week or more than one year) subject to an obligation of the seller to repurchase (and the Fund to resell) the instrument at a fixed price and time, thereby determining the yield during the Fund’s holding period. This results in a fixed rate of return insulated from market fluctuation during such period. Accrued interest on the underlying security will not be included for purposes of valuing a Fund’s assets.
Repurchase agreements have the characteristics of loans by a Fund and will be fully collateralized (either with physical securities or evidence of book entry transfer to the account of the custodian bank) at all times. During the term of the repurchase agreement, the Fund retains the security subject to the repurchase agreement as collateral securing the seller’s repurchase obligation, continually monitors the market value of the security subject to the agreement and requires the Fund’s seller to deposit with the Fund additional collateral equal to any amount by which the market value of the security subject to the repurchase agreement falls below the resale amount provided under the repurchase agreement.
The Funds will enter into repurchase agreements only with member banks of the Federal Reserve System and with dealers in U.S. Government securities whose creditworthiness has been reviewed and found satisfactory. Securities underlying repurchase agreements will be limited to certificates of deposit, commercial paper, bankers’ acceptances, or obligations issued or guaranteed by the United States Government or its agencies or instrumentalities, in which the Funds may otherwise invest.
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A seller of a repurchase agreement could default and not repurchase from a Fund the security that is the subject of the agreement. The Fund would look to the collateral underlying the seller’s repurchase agreement, including the securities subject to the repurchase agreement, for satisfaction of the seller’s obligation to the Fund. In such event, the Fund might incur disposition costs in liquidating the collateral and might suffer a loss if the value of the collateral declines. There is a risk that if the issuer of the repurchase agreement becomes involved in bankruptcy proceedings, the Fund might be delayed or prevented from liquidating the underlying security or otherwise obtaining it for its own purposes, if the Fund did not have actual or book entry possession of the security.
When Issued and Delayed Delivery Securities
The Funds may from time to time in the ordinary course of business purchase fixed income securities on a when-issued or delayed delivery basis, which means that at the time of purchase the price and yield are fixed, but payment and delivery occur at a future date. Upon purchase of a when-issued or delayed delivery security, a Fund will record the transaction and include the security’s value in determining its net asset value (“NAV”). When the security is delivered to the Fund, its market value may be more or less than the purchase price. A Fund will enter into commitments for when-issued or delayed delivery securities only when it intends to acquire the securities, but if it does sell securities before delivery, the Fund may have a capital gain or loss.
Rule 144A Investments, Section 4(a)(2) Commercial Paper and Illiquid Securities
Each Fund, with respect to not more than 15% of its total assets, may purchase securities that are illiquid investments (i.e., any investment that the Fund reasonably expects cannot be sold or disposed of in current market conditions in seven calendar days or less without the sale or disposition significantly changing the market value of the investment). A Fund may incur higher transaction costs and require more time to complete transactions for the purchase and sale of illiquid securities than for readily marketable securities. When a Fund determines to sell an illiquid security within a relatively short time period, it may have to accept a lower sales price than if the security were readily marketable. Refer to “Non-Fundamental Investment Policies”, paragraph 10.
Options and Futures Contracts
Each of the Funds other than the Allocation Funds and the Retirement Funds may purchase and sell options and futures contracts, as described below. Refer to “Non-Fundamental Investment Policies” below, paragraph 1, for a description of the current restrictions on the Funds’ purchase of options and futures contracts.
Each Fund may sell a call option contract on a security it holds in its portfolio (called a covered call), and it may buy a call option contract on the security to close out a position created by the sale of a covered call.
A call option is a short-term contract (generally having a duration of nine months or less) which gives the purchaser of the option the right to purchase the underlying security at a fixed exercise price at any time prior to the expiration of the option regardless of the market price of the security during the option period.
As consideration for writing a covered call option, a Fund (the seller) receives from the purchaser a premium, which the Fund retains whether or not the option is exercised. The seller of the call option has the obligation, upon the exercise of the option by the purchaser, to sell the underlying security at the exercise price at any time during the option period.
Each Fund may buy a put option contract on a security it holds in its portfolio, and it may sell a put option contract on the security to close out a position created by the purchase of the put option contract.
A put option is a similar short-term contract that gives the purchaser of the option the right to sell the underlying security at a fixed exercise price at any time prior to the expiration of the option regardless of the market price of the security during the option period. As consideration for the put option, a Fund (the purchaser) pays the seller a premium, which the seller retains whether or not the option is exercised.
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The seller of the put option has the obligation, upon the exercise of the option by the purchaser, to purchase the underlying security at the exercise price at any time during the option period. The buying of a covered put contract limits the downside exposure for the investment in the underlying security to the combination of the exercise price less the premium paid.
Each Fund may purchase and sell futures contracts, and purchase options on futures contracts, on fixed-income securities or on an index of securities, such as the Standard & Poor’s 100 ® Index, the Standard & Poor’s 500 ® Index or the New York Stock Exchange Composite Index.
A futures contract on fixed income securities requires the seller to sell, and the purchaser to buy, a stated quantity of a given type of fixed income security for a fixed price at a specified time in the future. A futures contract or option on a futures contract on a stock index provides for the making and acceptance of a cash settlement equal to the change in value of a hypothetical portfolio of stocks between the time the contract is entered into and the time it is closed out, times a fixed multiplier. Futures contracts may be traded domestically only on exchanges which have been designated as “contract markets” by the Commodity Futures Trading Commission, such as the Chicago Board of Trade.
An option on a futures contract provides the purchaser with the right, but not the obligation, to enter into a “long” position in the underlying futures contract (in the case of a call option on a futures contract), or a “short” position in the underlying futures contract (in the case of a put option on a futures contract), at a fixed price up to or on a stated expiration date. Upon exercise of the option by the holder, the contract market clearing house establishes a corresponding short position for the writer of the option, in the case of a call option, or a corresponding long position in the case of a put option. The trading of options on futures contracts subjects the parties to many of the risks associated with the trading of futures contracts, such as, with respect to the writers of options on futures contracts, the payment of margin. In the event that an option is exercised, the parties are subject to all of the risks associated with the trading of futures contracts, such as payment of margin deposits.
A Fund does not pay or receive a payment upon its purchase or sale of a futures contract. Initially, a Fund will be required to deposit with the Fund’s custodian in the broker’s name an amount of cash or U.S. Treasury bills known as “initial margin.”
While a futures contract is outstanding, there will be subsequent payments, called “maintenance margin”, to and from the broker. These payments will be made on a daily or intraday basis as the price of the underlying instrument or stock index fluctuates, making the long and short positions in the futures contract more or less valuable. This process is known as “mark to market”. At any time prior to expiration of the futures contract, a Fund may elect to close the position by taking an opposite position, which will operate to terminate the Fund’s position in the futures contract and may require additional transaction costs. A final determination of margin is then made, additional cash is required to be paid by or released to the Fund, and the Fund realizes a loss or gain.
A Fund may use futures contracts to protect against general increases or decreases in the levels of securities prices, in the manner described below.
When a Fund anticipates a general decrease in the market value of portfolio securities, it may sell futures contracts. If the market value falls, the decline in the Fund’s net asset value may be offset, in whole or in part, by corresponding gains on the futures position.
A Fund may sell futures contracts on fixed-income securities in anticipation of a rise in interest rates that would cause a decline in the value of fixed-income securities held in the Fund’s portfolio.
A Fund may sell stock index futures contracts in anticipation of a general market wide decline that would reduce the value of its portfolio of stocks.
When a Fund projects an increase in the cost of fixed-income securities or stocks to be acquired in the future, the Fund may purchase futures contracts on fixed-income securities or stock indexes. If the hedging transaction is successful, the increased cost of securities subsequently acquired may be offset, in whole or in part, by gains on the futures position.
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Instead of purchasing or selling futures contracts, a Fund may purchase call or put options on futures contracts in order to protect against declines in the value of portfolio securities or against increases in the cost of securities to be acquired.
Purchases of options on futures contracts may present less risk in hedging a portfolio than the purchase and sale of the underlying futures contracts, since the potential loss is limited to the amount of the premium paid for the option, plus related transaction costs.
As in the case of purchases and sales of futures contracts, a Fund may be able to offset declines in the value of portfolio securities, or increases in the cost of securities acquired, through gains realized on its purchases of options on futures.
The Funds also may purchase put options on securities or stock indexes for the same types of securities for hedging purposes. The purchase of a put option on a security or stock index permits a Fund to protect against declines in the value of the underlying security or securities in a manner similar to the sale of futures contracts.
In addition, the Funds may write call options on portfolio securities or on stock indexes for the purpose of increasing their returns and/or to protect the value of their portfolios.
When a Fund writes an option which expires unexercised or is closed out by the Fund at a profit, it will retain the premium paid for the option, less related transaction costs, which will increase its gross income and will offset in part the reduced value of a portfolio security in connection with which the option may have been written.
If the price of the security underlying the option moves adversely to the Fund’s position, the option may be exercised and the Fund will be required to sell the security at a disadvantageous price, resulting in losses which may be only partially offset by the amount of the premium.
A call option on a security written by a Fund will be covered through ownership of the security underlying the option or through ownership of an absolute and immediate right to acquire such security upon conversion or exchange of other securities held in its portfolio.
Risks in futures and options transactions include the following:
There may be a lack of liquidity, which could make it difficult or impossible for a Fund to close out existing positions and realize gains or limit losses.
The liquidity of a market in futures contracts or options on futures contracts may be adversely affected by “daily price fluctuation limits,” established by the exchanges on which such instruments are traded, which limit the amount of fluctuation in the price of a contract during a single trading day. Once the limit in a particular contract has been reached, no further trading in such contract may occur beyond such limit, thus preventing the liquidation of positions, and requiring traders to make any additional variation margin payments that may be required. Market liquidity in options, futures contracts or options on futures contracts may also be adversely affected by trading halts, suspensions, exchange or clearing house equipment failures, government intervention, insolvency of a brokerage firm or clearing house or other disruptions of normal trading activity.
The securities held in a Fund’s portfolios may not exactly duplicate the security or securities underlying the options, futures contracts or options on futures contracts traded by the Fund, and as a result the price of the portfolio securities being hedged will not move in the same amount or direction as the underlying index, securities or debt obligation.
A Fund purchasing an option may lose the entire amount of the premium plus related transaction costs.
For options on futures contracts, changes in the value of the underlying futures contract may not be fully reflected in the value of the option.
With respect to options and options on futures contracts, the Funds are subject to the risk of market movements between the time that the option is exercised and the time of performance thereunder.
In writing a covered call option on a security or a stock index, a Fund may incur the risk that changes in the value of the instruments used to cover the position will not correlate precisely with changes in the value of the option or underlying the index or instrument.
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The opening of a futures position and the writing of an option are transactions that involve substantial leverage. As a result, relatively small movements in the price of the contract can result in substantial gains or losses.
Additional Information about Specific Types of Securities
Non-Investment Grade Securities
The Bond Funds may purchase non-investment grade debt securities. In addition, the Bond Funds and the other Funds that purchase debt securities may hold a security that becomes non-investment grade as a result of impairments of the issuer’s credit.
Fixed-income securities that are rated in the lower rating categories of the nationally recognized rating services (Ba or lower by Moody’s and BB or lower by Standard & Poor’s), or unrated securities of comparable quality, are commonly known as non-investment grade securities or “junk bonds”. Junk bonds are regarded as being predominantly speculative as to the issuer’s ability to make payments of principal and interest. Investment in non-investment grade securities involves substantial risk. Junk bonds may be issued by less creditworthy companies or by larger, highly leveraged companies, and are frequently issued in corporate restructurings, such as mergers and leveraged buy-outs. Such securities are particularly vulnerable to adverse changes in the issuer’s industry and in general economic conditions. Junk bonds frequently are junior obligations of their issuers, so that in the event of the issuer’s bankruptcy, claims of the holders of junk bonds will be satisfied only after satisfaction of the claims of senior security holders.
Non-investment grade bonds tend to be more volatile than higher-rated fixed-income securities, so that adverse economic events may have a greater impact on the prices of junk bonds than on higher-rated fixed-income securities. Junk bonds generally are purchased and sold through dealers who make a market in such securities for their own accounts. However, there are fewer dealers in the non-investment grade bond market, and the market may be less liquid than the market for higher-rated fixed-income securities, even under normal economic conditions. Also, there may be significant disparities in the prices quoted for junk bonds by various dealers. Adverse economic conditions or investor perceptions (whether or not based on economic fundamentals) may impair the liquidity of this market, and may cause the prices that a Fund may receive for any non-investment grade bonds to be reduced, or might cause a Fund to experience difficulty in liquidating a portion of its portfolio.
U.S. Government and U.S. Government Agency Obligations
All of the Funds may invest in U.S. Government and U.S. Government agency obligations. Some of these securities also may be considered money market instruments. Some also may be mortgage-backed securities or zero coupon securities.
U.S. Government Obligations: These securities are issued and guaranteed as to principal and interest by the United States Government. They include a variety of Treasury securities, which differ only in their interest rates, maturities and times of issuance. Treasury bills have a maturity of one year or less. Treasury notes at the time of issuance have maturities of two to ten years and Treasury bonds have a maturity of 30 years.
U.S. Government Agency Obligations: Agencies of the United States Government that issue or guarantee obligations include, among others, Export-Import Bank of the United States, Farmers Home Administration, Federal Housing Administration, Government National Mortgage Association, Student Loan Marketing Association, Maritime Administration, Small Business Administration and the Tennessee Valley Authority.
Instrumentalities of the United States Government that issue or guarantee obligations include, among others Federal Farm Credit Banks, Federal National Mortgage Association, Federal Home Loan Banks, Federal Home Loan Mortgage Corporation, Federal Intermediate Credit Banks, Federal Land Banks and Banks for Cooperatives.
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Some of the securities issued by U.S. Government agencies and instrumentalities are supported by the full faith and credit of the U.S. Treasury; others are supported by the right of the issuer to borrow from the Treasury, while others are supported only by the credit of the instrumentality that issued the obligation. In the latter case, the investor must look principally to the agency or instrumentality issuing or guaranteeing the obligation for ultimate repayment and may not be able to assert a claim against the United States if the agency or instrumentality does not meet its commitment. There can be no assurance that the U.S. Government would provide financial support to its agencies or instrumentalities where it is not obligated to do so.
Money Market Instruments
All of the Funds may purchase money market instruments, which include the following.
Certificates of Deposit. Certificates of deposit are generally short term, interest-bearing negotiable certificates issued by banks or savings and loan associations against funds deposited in the issuing institution.
Time Deposits. Time deposits are deposits in a bank or other financial institution for a specified period of time at a fixed interest rate, for which no negotiable certificate is received.
Bankers’ Acceptance. A bankers’ acceptance is a draft drawn on a commercial bank by a borrower usually in connection with an international commercial transaction (to finance the import, export, transfer or storage of goods). The borrower is liable for payment as well as the bank, which unconditionally guarantees to pay the draft at its face amount on the maturity date. Most acceptances have maturities of six months or less and are traded in secondary markets prior to maturity.
Commercial Paper. Commercial paper refers to short-term, unsecured promissory notes issued by corporations to finance short-term credit needs. Commercial paper is usually sold on a discount basis and has a maturity at the time of issuance not exceeding nine months.
Variable Amount Floating Rate Notes. Variable floating rate notes are short-term, unsecured promissory notes issued by corporations to finance short-term credit needs. These are interest-bearing notes on which the interest rate generally fluctuates on a weekly basis.
Corporate Debt Securities. Corporate debt securities with a remaining maturity of less than one year tend to become extremely liquid and are traded as money market securities.
Treasury Bills. See “U.S. Government and U.S. Government Agency Obligations” above.
Zero Coupon Securities and Discount Notes; Redeemable Securities
The Bond Funds and the fixed income portion of the Composite Fund may invest in discount notes and zero coupon securities. Discount notes mature in one year or less from the date of issuance. Zero coupon securities may be issued by corporations or by certain U.S. Government agencies.
Discount notes and zero coupon securities do not pay interest. Instead, they are issued at prices that are discounted from the principal (par) amount due at maturity. The difference between the issue price and the principal amount due at maturity (or the amount due at the expected redemption date in some cases if the securities are callable) is called “original issue discount”. A Fund must accrue original issue discount as income, even if the Fund does not actually receive any payment under the security during the accrual period. The purchase price paid for zero coupon securities at the time of issuance, or upon any subsequent resale, reflects a yield-to-maturity required by the purchaser from the purchase date to the maturity date (or expected redemption date).
Zero coupon securities and discount notes may fluctuate more in market value and be more difficult for a Fund to resell during periods of interest rate changes in the economy than comparable securities that pay interest in cash at regular intervals. The market values of outstanding debt securities generally decline when interest rates are rising, and during such periods a Fund may lose more investment capital if it sells zero coupon securities prior to their maturity date or expected redemption date than if it sells comparable interest-bearing securities. In general, the longer the remaining term to maturity or expected redemption of a security, the greater the impact on market value from rising interest rates.
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Foreign Securities and American Depository Receipts (ADRs)
In addition to investing in domestic securities, each of the Funds other than the Money Market Fund and the Allocation Funds may invest in securities of foreign issuers, including securities traded outside the United States. Foreign issues guaranteed by domestic corporations are considered to be domestic securities.
ADRs are dollar-denominated receipts issued generally by domestic banks and representing the deposit with the bank of a security of a foreign issuer. ADRs are publicly traded on exchanges or over-the-counter in the United States.
The Investment Company has a non-fundamental investment policy that limits foreign securities, including foreign exchange transactions, and ADRs to 25% of a Fund’s total assets, except that this policy does not apply to the International Fund. (See “Non-Fundamental Investment Policies”, paragraph 2.)
Considerations relevant to investing in foreign securities and ADRs include:
changes in currency rates or currency exchange control regulations,
the unavailability of financial information or the difficulty of interpreting financial information prepared under foreign accounting standards,
lower levels of liquidity and more volatility in foreign securities markets (not applicable to ADRs),
the impact of political, social or diplomatic developments, and
the difficulty of assessing economic trends in foreign countries.
The Funds could encounter greater difficulties in bringing legal processes abroad than would be encountered in the United States. Foreign securities may also entail certain other risks, such as the risks of disparate or subpar accounting practices, imposition of dividend or interest withholding or confiscatory taxes, higher brokerage costs, thinner trading markets, currency blockages or transfer restrictions, expropriation, nationalization, military coups, economic sanctions, or other adverse political or economic developments, and less government supervision and regulation of securities exchanges, brokers and listed companies.
Exchange Traded Funds
An exchange traded fund (ETF) is a type of investment company. The shares of ETFs are traded on an exchange, similar to shares of stocks. The Equity Index Fund, Small Cap Equity Index Fund, Mid-Cap Equity Index Fund, Catholic Values Index Fund, and the passive portion of the All America Fund may invest in ETFs to efficiently and cost effectively keep the Fund fully invested on a daily basis in an attempt to minimize deviation from the performance of its respective index. The International Fund may invest in ETFs that reflect, replicate or closely follow the holdings in the MSCI EAFE Index.
Convertible Securities
The Bond Funds and the fixed income portion of the Composite Fund may invest in convertible securities. Convertible securities can be converted by the holder into common stock of the issuer, at the price and on the terms set forth by the issuer when the convertible securities are initially sold. Convertible securities normally provide a higher yield than the underlying stock but a lower yield than a fixed-income security without the convertibility feature. The price of the convertible security normally will vary to some degree with changes in the price of the underlying stock, although the higher yield tends to make the convertible security less volatile than the underlying common stock. The income component of a convertible security may cushion the security against declines in the price of the underlying asset but may also cause the price of the security to fluctuate depending on the credit quality of the issuer. The price of the convertible security also will vary to some degree inversely with interest rates.
Equipment Trust Certificates
The Bond Funds and the fixed income portion of the Composite Fund may invest in equipment trust certificates. The proceeds of those certificates are used to purchase equipment, such as railroad cars, airplanes or other equipment, which in turn serve as collateral for the related issue of certificates.
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The equipment subject to a trust generally is leased by a railroad, airline or other business, and rental payments provide the projected cash flow for the repayment of the equipment trust certificates. Holders of equipment trust certificates must look to the collateral securing the certificates, and any guarantee provided by the lessee or any parent corporation for the payment of lease amounts, in the case of default in the payment of principal and interest on the certificates.
The Investment Company currently has a non-fundamental investment policy that no Fund will invest more than 5% of its total assets in equipment trust certificates.
Asset-Backed Securities
The Bond Funds and the fixed income portion of the Composite Fund may invest in securities backed by consumer or credit card loans or other receivables or may purchase interests in pools of such assets.
Changes in interest rates may significantly affect the value of these securities, and prepayment rates will impact the yield and price of the securities. A decline in interest rates may result in increases in prepayment, and a Fund will have to invest prepayment proceeds at the prevailing lower interest rates. Asset-backed securities generally are not expected to prepay to the same extent as mortgage-backed securities in such circumstances. An increase in interest rates may result in prepayment at a rate slower than was assumed when the security was purchased. The credit quality of asset-backed securities depends primarily on the quality of the underlying assets, the rights of recourse available against the underlying assets and/or the issuer, the level of credit enhancement, if any, provided for the securities, and the credit quality of the credit-support provider, if any. The values of asset-backed securities may be affected by other factors, such as the availability of information concerning the pool of assets and its structure, the market’s perception of the asset backing the security, the creditworthiness of the servicing agent for the pool of assets, the originator of the underlying assets, or the entities providing the credit enhancement.
The Investment Company currently has a non-fundamental investment policy that no Fund will:
invest more than 10% of its total assets in asset-backed securities,
invest in interest-only strips or principal-only strips of asset-backed securities, or
purchase the most speculative series or class of asset-backed securities issues.
Mortgage-Backed Securities
The Bond Funds and the fixed income portion of the Composite Fund may invest in mortgage-backed securities. You should refer to the discussion of Mortgage-Backed Securities in the Prospectus under “Description of Principal Risks”.
The Investment Company currently has a non-fundamental investment policy that no Fund will:
if the Fund invests primarily in fixed income securities, invest more than 10% of its total assets in mortgage-backed securities that are not also considered to be U.S. Government or U.S. Government agency securities,
if the Fund invests primarily in equity securities, invest in mortgage-backed securities unless they are also considered to be U.S. Government Securities,
invest in interest-only strips or principal-only strips of mortgage-backed securities, or
purchase the most speculative series or class of collateralized mortgage obligation issues or other mortgage-backed securities issues.
Warrants
The Bond Funds and the fixed income portion of the Composite Fund may acquire warrants. A warrant is an option to purchase common stock of an issuer and is issued in conjunction with another security, such as a debt obligation. A warrant specifies the price at which the holder may purchase shares of common stock and usually expires after a period of time. A warrantholder generally may pay cash for the common stock to be purchased or may surrender principal amount of the related debt security the warrantholder owns equal to the purchase price for the stock.
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The common stock underlying a warrant may not increase in value after the date the warrant was issued, or may not increase up to the warrant exercise price. In this case, the warrant generally would have little value and could expire unexercised.
The Investment Company currently has a non-fundamental investment policy that no Fund will invest more than 5% of its assets in warrants.
Preferred Stock
The Bond Funds and the fixed income portion of the Composite Fund may purchase preferred stock. A corporation may issue a form of equity security called preferred stock. Compared to common stock, preferred stock has advantages in the receipt of dividends and in the receipt of the corporation’s assets upon liquidation. Preferred stockholders, however, usually do not have voting rights at meetings of the corporation’s shareholders.
An issuer of preferred stock must pay a dividend to holders of preferred stock before it distributes a dividend to holders of common stock. When a corporation issues preferred stock, it sets a dividend rate, or a formula to determine the rate. If a corporation does not have sufficient earnings to pay the specified dividend to preferred stockholders, the unpaid dividend may accrue (cumulate) and become payable when the corporation’s earnings increase. Bondholders, in contrast, are entitled to receive interest and principal due, regardless of the issuer’s earnings.
Some issues of preferred stock give the holder the right to convert the preferred stock into shares of common stock, when certain conditions are met. A holder of preferred stock that is not convertible, or of preferred stock that is convertible but has not met the conditions for conversion, does not share in the earnings of the issuer other than through the receipt of dividends on the preferred stock. The market value of convertible preferred stock generally fluctuates more than the market value of nonconvertible preferred stock, because the value of the underlying common stock will affect the price of the convertible stock.
Preferred stock has the risk that a corporation may not have earnings from which to pay the dividends as they become due. Even if a corporation is paying dividends, if the dividend rate is fixed (and not variable), changes in interest rates generally will affect the market value of the preferred stock in the same manner as for debt obligations. The value of preferred stock will usually react more strongly than debt instruments to actual or perceived changes in the issuer’s financial condition or prospects, because issuer’s preferred stock generally pays dividends only after the issuer makes required payments to holders of its debt instruments and other debt.
The Investment Company currently has a non-fundamental investment policy that no Fund will invest more than 10% of its assets in preferred stock.
The Use of Futures Contracts, Options, and Certain Swaps
Each non-money market fund may enter into futures contracts, options, options on futures contracts, or swap agreements as permitted by its investment policies and the Commodity Futures Trading Commission (CFTC) rules. The Adviser to each Fund has claimed an exclusion from the definition of the term “commodity pool operator” under the Commodity Exchange Act (CEA) with respect to each Fund and, therefore, the Adviser is not subject to registration or regulation as commodity pool operator under the CEA with respect to its operation of each Fund.
For the Adviser to remain eligible for this exclusion, each Fund must comply with certain limitations, including limits on its ability to use any futures, options on futures or commodities, swaps, or other financial instruments regulated under the CEA and the rules thereunder ("commodity interests") and limits on the manner in which it holds out its use of such commodity interests. These limitations may restrict each Fund's ability to pursue its investment objectives and strategies, increase the costs of implementing its strategies, result in higher expenses for it, and/or adversely affect its total return. In the event that the Adviser believes that any Fund may no longer be able to comply with or that it may no longer be desirable for it to comply with these limitations, the Adviser may register as a commodity pool operator with the CFTC with respect to such Fund. Any such
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registration may adversely affect such Fund's performance, for example, by subjecting it to increased costs and expenses. If the Adviser registers as a commodity pool operator with the CFTC with respect to any Fund, the commodity pool operators of any shareholders that are pooled investment vehicles may be unable to rely on certain commodity pool operator registration exemptions.
To the extent required by law, each Fund will segregate cash, cash equivalents or other appropriate liquid securities on its records in an amount sufficient to cover its obligations under the futures contracts and options.
The CFTC and certain futures exchanges have established (and continue to evaluate and revise) limits, referred to as “position limits,” on the maximum net long or net short positions which any person or entity may hold or control in particular futures and options on futures contracts. In addition, federal position limits apply to swaps that are economically equivalent to futures contracts that are subject to CFTC set limits. All positions owned or controlled by the same person or entity, even if in different accounts, must be aggregated for purposes of determining whether the applicable position limits have been exceeded, unless an exemption applies. Thus, even if a Fund does not intend to exceed applicable position limits, it is possible that positions of different clients managed by the Adviser and its affiliates may be aggregated for this purpose. It is possible that the trading decisions of the Adviser may have to be modified and that positions held by a Fund may have to be liquidated in order to avoid exceeding such limits. The modification of investment decisions or the elimination of open positions, if it occurs, may adversely affect the performance of the Fund. A violation of position limits could also lead to regulatory action materially adverse to a Fund's investment strategy.

INSURANCE LAW RESTRICTIONS
Insurance laws and regulations in States where the Insurance Companies operate govern investments by Separate Accounts. If necessary in order for shares of the Investment Company’s Funds to remain eligible investments for the Separate Accounts, a Fund may from time to time limit the amount of its investments in certain types of securities, such as foreign securities and debt or equity securities of certain issuers.

FUNDAMENTAL INVESTMENT RESTRICTIONS
The following investment restrictions are fundamental policies. The Funds may not change these policies unless a majority of the outstanding voting shares of each affected Fund approves the change. A majority of the outstanding voting shares means the lesser of: (1) 67% or more of the outstanding shares of the Fund present at the meeting, if the holders of more than 50% of the outstanding shares of the Fund are present or represented at such meeting; or (2) more than 50% of the outstanding shares of the Fund. No Fund will:
1.
underwrite the securities issued by other companies, except to the extent that the Fund’s purchase and sale of portfolio securities may be deemed to be an underwriting;
2.
purchase physical commodities or contracts involving physical commodities;
3.
based on its investments in individual issuers, be non-diversified as defined under the 1940 Act, which currently restricts a Fund, with respect to 75% of the value of its total assets, from investing more than 5% of its total assets in the securities of any one issuer, other than (i) securities issued or guaranteed by the United States Government or its agencies or instrumentalities (“U.S. Government Securities”), and (ii) securities of other registered investment companies; in addition the Money Market Fund will not invest in any securities that would cause it to fail to comply with applicable diversification requirements for money market funds under the 1940 Act and rules thereunder, as amended from time to time;
4.
based on its investment in an issuer’s voting securities, be non-diversified as defined under the 1940 Act, which currently restricts a Fund, with respect to 75% of the value of its total assets, from purchasing more than 10% of the outstanding voting securities of any one issuer other than (i) U.S. Government Securities, and (ii) securities of other registered investment companies;
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5.
issue senior securities, except as permitted under the 1940 Act and the rules thereunder as amended from time to time;
6.
invest more than 25% of its assets in the securities of issuers in one industry, other than U.S. Government Securities, except that the Money Market Fund may invest more than 25% of its total assets in the financial services industry. For Funds that invest in other Funds and/or exchange traded funds, the Fund will look through to the underlying Funds and/or exchange traded funds to ensure compliance with this policy;
7.
purchase real estate or mortgages directly, but a Fund may invest in mortgage-backed securities and may purchase the securities of companies whose businesses deal in real estate or mortgages, including real estate investment trusts;
8.
borrow money, except to the extent permitted by the 1940 Act and rules thereunder, as amended from time to time, which currently limit a Fund’s borrowing to 33 13% of total assets (including the amount borrowed) minus liabilities (other than borrowings) and require the reduction of any excess borrowing within three business days; or
9.
lend assets to other persons (with a Fund’s entry into repurchase agreements or the purchase of debt securities not being considered the making of a loan), except to the extent permitted by the 1940 Act and rules thereunder, as amended from time to time, which currently limit a Fund’s lending to 33 13% of its total assets, or pursuant to any exemptive relief granted by the SEC.
Current 1940 Act provisions applicable to fundamental investment restriction #3 above: The 1940 Act and rules thereunder currently restrict a Fund, with respect to 75% of the value of its total assets, from investing more than 5% of its total assets in the securities of any one issuer, other than (i) securities issued or guaranteed by the United States Government or its agencies or instrumentalities (“U.S. Government Securities”), and (ii) securities of other registered investment companies;
With respect to fundamental investment restrictions #3 and #4 above: The Equity Index Fund, Mid-Cap Equity Index Fund, Small-Cap Equity Index Fund, and Catholic Values Index Fund will typically be diversified in approximately the same proportion as the index each Fund tracks is diversified. Shareholder approval will not be sought if the Fund crosses from diversified to non-diversified status due to a change in the relative market capitalization or index weighting of one or more constituents of the Fund’s respective benchmark index.
Current 1940 Act provisions applicable to fundamental investment restriction #4 above: The 1940 Act and rules thereunder currently restrict a Fund, with respect to 75% of the value of its total assets, from purchasing more than 10% of the outstanding voting securities of any one issuer other than (i) U.S. Government Securities, and (ii) securities of other registered investment companies, and imposes additional restrictions on the Money Market Fund.
With respect to fundamental investment restriction #6 above: The Money Market Fund does not invest more than 25% of its total assets in the financial services industry. At the time of the next shareholder vote, the Fund will seek approval of the shareholders to remove from fundamental investment restriction #6 the language stating “except that the Money Market Fund may invest more than 25% of its total assets in the financial services industry.”
With respect to fundamental investment restriction #6 above: The Equity Index Fund, Small Cap Equity Index Fund, Mid-Cap Equity Index Fund and Catholic Values Index Fund will typically be concentrated to the same degree as the index each Fund tracks.
With respect to fundamental investment restriction #6 above: The International Fund will look through to the investments of the underlying funds to determine the Fund’s concentration.
Current 1940 Act provisions applicable to fundamental investment restriction #8 above: The 1940 Act and rules thereunder currently limit a Fund’s borrowing to 33 13 % of total assets (including the amount borrowed) minus liabilities (other than borrowings) and require the reduction of any excess borrowing within three days (excluding Sundays and holidays).
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Current 1940 Act provisions applicable to fundamental investment restriction #9 above: The 1940 Act and rules thereunder currently limit a Fund’s lending to 33 13% of its total assets, with a Fund’s entry into repurchase agreements or the purchase of debt securities not being considered the making of a loan for this purpose.

NON-FUNDAMENTAL INVESTMENT POLICIES
The following investment restrictions are not fundamental policies. They may be changed without shareholder approval by a vote of the Board of Directors of the Investment Company, subject to any limits imposed by the 1940 Act or applicable regulatory authorities and subject to each Fund’s investment objectives and permitted investments. No Fund will:
1.
purchase or sell options or futures contracts or options on futures contracts unless the options or contracts relate to U.S. issuers or U.S. stock indexes and are not for speculation, and in addition (i) a Fund may write only covered call options and may buy put options only if it holds the related securities, (ii) a Fund may invest in futures contracts to hedge not more than 20% of its total assets, and (iii) premiums paid on outstanding options contracts may not exceed 5% of the Fund’s total assets;
2.
with the sole exception of the International Fund, invest in foreign exchange nor invest more than 25% of its total assets in securities of foreign issuers and American Depository Receipts (ADRs);
3.
invest for the purpose of exercising control over management of an issuer (either separately or together with any other Funds);
4.
make short sales, except when the Fund owns or has the right to obtain securities of equivalent kind and amount that will be held for as long as the Fund is in a short position;
5.
if its investment policy is to invest primarily in equity securities, purchase mortgage-backed securities unless they are also U.S. Government Securities, or if its investment policy is to invest primarily in fixed income securities, invest more than 10% of its total assets in mortgage-backed securities that are not also U.S. Government Securities;
6.
invest in the securities of any registered investment company except as permitted under the Investment Company Act of 1940 and the rules thereunder, as amended from time to time, or by any exemptive relief granted by the SEC;
7.
purchase securities on margin, except that credits for the clearance of portfolio transactions and the making of margin payments for futures contracts and options on futures contracts shall not constitute the purchasing of securities on margin;
8.
borrow money except for temporary or emergency purposes (not for investment or leveraging) or under any reverse repurchase agreement, provided that a Fund’s aggregate borrowings may not exceed 10% of the value of the Fund’s total assets and it may not purchase additional securities if its borrowings exceed that limit;
9.
lend more than 10% of its assets;
10.
invest more than 15% of its total assets (5%, in the case of the Money Market Fund) in securities that are considered to be illiquid because they cannot be sold or disposed of in current market conditions in seven calendar days or less without the sale or disposition significantly changing the market value of the investment;
11.
invest more than 5% of its total assets in equipment trust certificates;
12.
invest more than 10% of its total assets in asset-backed securities or purchase the most speculative series or class of asset-backed securities issues;
13.
purchase the most speculative series or class of collateralized mortgage obligation issues or other mortgage-backed securities issues;
14.
invest in interest-only strips or principal only strips of asset-backed securities, mortgage-backed securities or other debt securities;
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15.
invest more than 5% of its assets in warrants; or
16.
invest more than 10% of its assets in preferred stock.
A Fund may, from time to time, take temporary defensive positions that are inconsistent with the Fund’s principal investment strategies in attempting to respond to adverse market, economic, political or other conditions, which may cause the Fund to not achieve its investment objective. Should a Fund takes a temporary defensive position, it may change its allocation among the asset classes in which the Fund invests, including by increasing the percentage of cash or short-term debt securities held by the Fund. In addition, except as otherwise expressly stated, all percentage limitations and requirements as to investments stated in the Prospectus and this Statement of Additional Information apply only at the time of an investment to which the limitation or requirement is applicable and shall not be considered violated unless an excess or deficiency occurs or exists immediately after and as a result of such investment. Accordingly, any later increase or decrease resulting from a change in values, net assets or other circumstances will not be considered in determining whether any investment complies with a Fund’s limitation or requirement.
For purposes of applying any limitations on a Fund’s investments in bonds rated of a certain quality, when an investment is rated by more than one nationally recognized securities rating organization, the Adviser will utilize the highest credit rating for that security for purposes of applying any investment policies that incorporate credit ratings (e.g., a policy to invest a certain percentage of a Fund’s assets in securities rated investment grade) except where a Fund has a policy to invest a certain minimum percentage of its assets in securities that are rated below investment grade, in which case the Fund will utilize the lowest credit rating that applies to that investment.

DISCLOSURE OF PORTFOLIO SECURITIES INFORMATION
The policies and procedures of the Investment Company with respect to disclosure of portfolio securities information are set forth in its compliance manual, which has been approved and adopted by the Board of Directors. The Investment Company posts its top 10 holdings on its website each month at mutualofamerica.com/IC/TopTenHoldings. Typically the information is five to ten calendar days old when posted. The Investment Company discloses to shareholders and others only information that is made available to the public, on a quarterly basis. With the sole exception of certain disclosures to certain parties (“Recipients”) that are for legitimate business purposes and beneficial to the Investment Company, such as providing information reasonably requested by regulatory authorities, by consultants and rating services, no information on portfolio securities will be disclosed to any party until it has first been made available to the public on the Investment Company’s website. Requests by Recipients will be reviewed on a case-by-case basis, and aside from the agreements described below, there are no ongoing arrangements for disclosing information to Recipients. Any disclosures to Recipients may be made only with advance approval of the Chief Executive Officer (“CEO”), Chief Compliance Officer (“CCO”) and counsel, must contain limitations on use, and, if the requested disclosure should include information not already available to the public as stated above, it must be covered by a confidentiality and nondisclosure agreement.
With respect to the Money Market Fund, the Money Market Fund makes certain portfolio holdings information pursuant to Rule 2a-7 of the Investment Company Act of 1940 available monthly on Mutual of America Life Insurance Company’s public website by posting the required information as of the last business day of the previous month, no later than the 5th business day of the month. This information will be maintained on the website for 6 months after posting, and a link is provided to the Fund information on the SEC website. Additionally the Fund provides the SEC with more detailed portfolio holdings information pursuant to Rule 2a-7 via a monthly electronic filing on Form N-MFP. Such information will be submitted electronically to the SEC as of the last business day of the prior month within 5 business days after the end of each month, in an eXtensible Markup Language (“XML”) tagged data format. A link to the Form N-MFP filings is provided on Mutual of America Life Insurance Company’s public website. Pursuant to Rule 2a-7 of the Investment
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Company Act of 1940, the Money Market Fund makes certain portfolio holdings information available daily on Mutual of America Life Insurance Company’s public website by posting the required information each business day as of the end of the preceding business day. The website includes information for each day of the preceding six months, and a link is provided to the Fund information on the SEC website.
Recipients of non-public portfolio holdings of the Funds, at the present time include third parties that provide pricing services, market research providers and other service providers to the Funds. Entities receiving this information agree to: reasonably ensure that the holdings information will be kept confidential, prevent employee use of the information for their personal benefit, and restrict the nature and type of information that they may disclose to third-parties. Primary reliance is placed on the reputation and experience of the third party in properly handling confidential information and non-disclosure agreements when determining that disclosure is not likely to be harmful to a fund.
At this time, the entities receiving information described in the prior paragraph under agreements containing confidentiality obligations are: KPMG LLP (provides an opinion on the financial statements, receive holdings data regularly); ICE Data Services (provides fixed income security pricing and fair value equity security pricing for the purposes of NAV calculation, full or partial fund holdings daily, with no lag time); Factset Research Systems Inc. (equity and fixed income quantitative analytical application that provides attribution analysis for the portfolios, full or partial fund holdings daily, no lag time); Bloomberg Finance, L.P., (provides a trading platform for fixed income and equity securities, provides a comprehensive listing of portfolio security holdings and provides fixed income portfolio analytics, full or partial fund holdings daily, no lag time); Morningstar (provides statistics and rankings, full or partial fund holdings daily, with no lag time); Reuters (provides equity security pricing for the purposes of NAV calculation and provides fixed income portfolio analytics, full or partial fund holdings daily, no lag time); Brown Brothers Harriman & Co. (performs fund accounting and calculates daily NAV, no lag time); Clearwater, LLP (provides analytics and calculates daily shadow NAV, no lag time); Bondedge (provides fixed income quantitative analytical application, full or partial holdings daily, no lag time); GT Analytics (provides best execution analysis, on a quarterly basis transactions are sent to GT, several days after the end of each quarter); Institutional Shareholder Services (provides proxy voting services and class action filing services for portfolio holdings, daily feed of custodial holdings, no lag time); and Compliance Science (used to monitor persons subject to the codes of ethics for their compliance with the codes of ethics including black-out periods, is provided equity and fixed income transaction data daily, with no lag time). Mutual of America Capital Management LLC as Adviser manages the portfolio and is therefore aware of all portfolio holdings information whether public or non-public on a daily basis.
Further, it is the Investment Company’s policy that neither the Investment Company, nor the Adviser, nor any other party receives any compensation for any disclosure of portfolio securities information by the Investment Company.

MANAGEMENT OF THE INVESTMENT COMPANY
Directors and Officers
The tables below show information about the Directors and officers of the Investment Company. The Directors of the Investment Company consist of seven individuals, six of whom are not “interested persons” of the Investment Company as defined in the 1940 Act (“Independent Directors”). The Directors are responsible for the overall supervision of the Investment Company’s operations and perform the various duties imposed on the directors of investment companies by the 1940 Act and the laws of Maryland. The Directors elect officers of the Investment Company. The address of each Director and officer is c/o Mutual of America Investment Corporation, 320 Park Avenue, New York, New York 10022-6839.
The Investment Company does not hold annual meetings of shareholders, and each Director, except for Mr. Festog and Mr. Grayson who were appointed by the Board of Directors, has been elected by shareholders to serve until a successor is duly elected at a meeting of shareholders called for the purpose of electing directors. Each officer of the Investment Company has been elected by the Board of Directors to serve until a successor is duly elected. The Independent Directors do not serve as directors of any other investment
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companies advised by or affiliated with the Adviser or the Insurance Company with the exception of serving on the Board of Directors of Mutual of America Variable Insurance Portfolios, Inc. (“Variable Insurance Portfolios” or “MOAVIP”), an affiliated registered management investment company, which also receives investment advice from the Adviser. The Interested Directors and officers of the Investment Company do not receive compensation from the Investment Company for their service. Chris W. Festog serves as director of another investment company advised by or affiliated with the Adviser, Variable Insurance Portfolios.
Currently, the Chairman of the Board is an interested person of the Fund and is also the Chief Executive Officer. The Board has an Audit Committee consisting entirely of the independent directors. The Audit Committee serves as the Nominating Committee as and when required. The Board has determined that the Board’s current structure, with an interested person as Chairman of the Board is satisfactory given the characteristics of the Corporation and its business and the Board considered the potential for conflicts of interest, in its determination with regard to the interested Chairman of the Board. The Board has determined that the Chairman of the Audit Committee has historically functioned as the Lead Director of the disinterested members of the Board of Directors. The Board has determined that the Disinterested Director serving at any given time as Chair of the Audit Committee shall also be the Lead Director who shall preside at separate meetings of the Disinterested Directors, communicate concerns and issues raised by the Disinterested Directors to management and others as appropriate, preside at the annual Board Self-Assessment and whenever appropriate, shall be the spokesperson for the Disinterested Directors. The Fund’s bylaws have been amended to reflect this determination. Currently the Audit Committee Chairman and Lead Director is John W. Sibal.
Board oversight of risk is carried out through Board reports and Audit Committee reports. The Board receives directly detailed reports at each quarterly meeting on the financial situation of the Corporation, the performance of the Corporation’s funds, portfolio management matters, a Chief Compliance Officer Report covering the Corporation’s Codes of Ethics, Compliance Policy and other matters, a Frequent Trading report, reports confirming compliance with Rule 2a-7, procedures, valuation procedures, and the trading policy of the Corporation, and regulatory updates. In addition, on a periodic basis the Board directly receives reports on the annual Compliance Report, proxy voting of the Funds’ securities, the Investment Advisory and Distribution Agreements, the Corporation’s Fidelity Bond and annual updates to the Corporation’s registration statement. The independent directors making up the Audit Committee receive quarterly reports from the inside and independent auditors, review annual Audit Reports, review the Corporation’s insurance coverages and examine the quarterly and annual financial statements in detail.
The Board is made up of persons possessing a variety of skills and experience that, at this time, support the conclusion that they should serve on the Board. A brief description of such skills and experience for each Director follows:
Chris W. Festog. Mr. Festog is the Senior Executive Vice President and Chief Financial Officer of Mutual of America Life Insurance Company, a position he has held since 2016. Prior to that date, Mr. Festog was the Executive Vice President and Treasurer and held numerous financial roles in Mutual of America Life Insurance Company since joining in 2009. Mr. Festog is also Chairman, President and CEO of Mutual of America Investment Corporation, and Mutual of America Variable Insurance Portfolios, Inc., as well as the Chairman President and Chief Executive Officer of Mutual of America Holding Company LLC and a Manager of Mutual of America Securities LLC. Prior to joining Mutual of America, Mr. Festog served as a Chief Financial Officer at several entities including Renaissance Re (USA), Zurich Global Energy (a business unit of Zurich Financial Services), and Heritage Life Insurance. Mr. Festog also served as Chief Information Officer for Virginia Farm Bureau Insurance Company from 2005-2009. Mr. Festog began his career with Arthur Andersen where he worked for nine years and is a Certified Public Accountant. He received a B.S. in Accounting from the University of Colorado in 1982. Mr. Festog brings to the Board a 40 year history in the insurance industry.
Carolyn N. Dolan. Ms. Dolan is an Executive Vice President, Head of Fiera Capital’s U.S. Private Wealth Group in New York City. Prior thereto she was Managing Principal and Portfolio Manager of Samson Capital Advisors, L.L.C. in New York City, where she served as a member of the Advisory Committee, Investment Committee and Management Committee. She was a co-founder of OFFITBANK, which was merged with Wachovia in 2002, and she remained after the merger as Managing Director of Wachovia’s
20

Offit Investment Group. Prior to that, she was employed by Julius Baer Securities, Oppenheimer Capital Corporation and Equitable Life Insurance, in capacities ranging from portfolio manager to analyst. She is a Chartered Financial Analyst (CFA), and received her undergraduate degree from Marymount College, followed by a Master’s degree from the Columbia School of Social Work and a Master’s degree from Columbia University Business School. She is a Trustee Fellow of Fordham University. In June 2014, Ms. Dolan was elected as a trustee of the Board of Trustees of Market Street Trust Company, where she serves on the Investment and Compensation Committees. She is a member of the Economic Club of New York, and the Women’s Forum of New York. She has been a member of the Board of the Investment Company since April 2011, and a Board Member of Variable Insurance Portfolios since November 2019.
Stanley E. Grayson. Mr. Grayson, currently retired, most recently served as the Vice Chairman and Chief Operating Officer at M.R. Beal & Company, until the firm was acquired by Blaylock Robert Van LLC. Prior thereto, he served as the Managing Director and Manager of the Public Finance Department at Prudential Securities, Inc. That position was preceded by his service as a Vice President at Goldman, Sachs & Co. in the Municipal Bond Department, Fixed Income Division. Prior to his career in investment banking, he held several senior positions within the government of the City of New York under the administration of Former Mayor Edward J. Koch, including Deputy Mayor for Finance and Economic Development. Prior thereto, he served as an attorney in the Law Department of Metropolitan Life Insurance Company in New York City. He is a director of TD Bank, N.A., and serves on its Audit Committee and HR/Compensation Committee. He is also a director of the YMCA of Greater New York and serves as the Chair of the Public Policy Committee and is a Member of the Finance Committee. He serves on the Board of Trustees for the College of the Holy Cross. Mr. Grayson received his Bachelor of Arts in Economics from the College of the Holy Cross, followed by earning a Juris Doctorate from University of Michigan Law School, and is a retired member of the New York State Bar Association. He has been a member of the Board of Investment Corporation since November 2017, and a member of the Board of Variable Insurance Portfolios since November 2019.
LaSalle D. Leffall, III. Mr. Leffall currently is the President and Founder of LDL Financial, LLC, a corporate advisory and investment firm with an emphasis on real estate and financial services. Prior thereto, he served as Acting Chief Executive Officer of The NHP Foundation, which owned thousands of affordable housing units in 14 states, and had also served as President, Chief Operating Officer and Chief Financial Officer of that firm. This experience was preceded by six years as a mergers and acquisitions investment banker, first at Credit Suisse First Boston, and then at UBS, where he handled complex commercial and financial transactions, including debt, equity and merger and acquisition matters. Prior to his career in investment banking, Mr. Leffall spent four years at the law firm of Cravath, Swaine & Moore. Mr. Leffall is a member of the Economic Club of Washington, D.C. He is an Advisory Board member for Cabot Properties, an industrial real estate company with assets in the U.S., U.K., continental Europe, and Australia. He was a director of the Federal Home Loan Bank of Atlanta, where he previously served as chair of the Finance Committee and a member of the Audit and Enterprise Risk and Operations Committees. Mr. Leffall received his Bachelor of Arts in History Magna Cum Laude from Harvard University, followed by simultaneously earning a Juris Doctorate from Harvard Law School Cum Laude and a Master’s in Business Administration with second year honors from Harvard Business School. Mr. Leffall is admitted to the bars of New York and Washington, D.C. He was elected to the Investment Company Board in April 2011, and has been a Board Member of Variable Insurance Portfolios since November 2019.
John W. Sibal. Mr. Sibal currently serves as a Director, President and Chief Executive Officer of Eustis Commercial Mortgage Corporation, a commercial mortgage company in New Orleans, Louisiana. Prior thereto, he served as a Vice President and Treasurer at a New Orleans based savings bank. That experience was preceded by working his way up from Economic Analyst to Assistant Treasurer for a multinational energy company, concentrating in economic analysis, finance and corporate planning. Mr. Sibal serves as a Senior Warden and Vestry member of Christ Church Cathedral in New Orleans. Mr. Sibal received a Bachelor of Arts in Economics from Harvard University. He was elected to the Investment Company board in April 2011, and has been a Board Member of Variable Insurance Portfolios since November 2019.
21

Margaret M. Smyth. Ms. Smyth is currently a Partner at Queensland Investment Corporation (QIC), an ESG-themed infrastructure investment company, and a member of Deloitte's Finance Advisory Council. She was formerly US Chief Financial Officer at National Grid. Previously, she was Vice President of Finance at Con Edison and prior thereto, she was the Chief Financial Officer and Vice President, Finance of Hamilton Sundstrand, in Windsor Locks, Connecticut, a United Technologies company. Prior to that, she was Vice President and Controller of United Technologies Corporation, Vice President and Chief Accounting Officer of 3M Company and Managing Partner at Deloitte Touche. Prior to joining Deloitte Touche, she was Partner in Charge of the North America Media Practice for Arthur Andersen. Ms. Smyth is a Certified Public Accountant (C.P.A.) with a Bachelor’s degree in economics from Fordham University and a Master’s degree in Accounting from New York University. She serves as a member of the Board of Trustees and the Audit Committee of Concern Worldwide and is a member of the Executive Committee of Fordham University President’s Council and a Director at Lilium, Remitly, Frontier Communications, Etsy, CenTrio and Renewa. Ms. Smyth has been a member of the Board of the Investment Company since 2007, and has been member of the Board of Variable Insurance Portfolios since November 2019. Ms. Smyth currently serves as the Financial Expert for the Audit Committees for Investment Corporation and Variable Insurance Portfolios.
William E. Whiston. Mr. Whiston is currently the Chief Financial Officer for the Archdiocese of New York, where he is responsible for the oversight of the Financial Office and financial operations of various organizations that are directly responsible to the Archdiocese. Prior to joining the Archdiocese, Mr. Whiston was Executive Vice President and member of the United States Management Board at Allied Irish Bank. In his 29 years at Allied Irish Bank, he handled many key functions, including head of acquisitions and brand development, head of e-commerce and information technology head of church and non-profit financial consulting services and head of operations. Mr. Whiston holds an undergraduate degree from Pace University and a Master’s in Business Administration from New York University. He is currently a trustee and Treasurer of the Trustees of St. Patrick’s Cathedral in New York City and a Trustee of St. Joseph’s Seminary. Mr. Whiston is a director of Webster Financial Services Corporation and CEO of New York Catholic Healthcare Plan. He has also been honored by the Catholic Church by being named a Knight of the Holy Sepulchre and a member of the Pontifical Equestrian Order of St. Gregory the Great. Mr. Whiston was appointed to fill a vacancy on the Investment Company Board in November 2010, effective February 17, 2011, and has been a Board Member of Variable Insurance Portfolios since November 2019.
Independent Directors
As of March 31, 2023, none of the independent directors or their immediate family members owned beneficially or of record any securities of Mutual of America Investment Corporation or the distributor of the Funds, or in a person (other than a registered investment company) directly or indirectly controlling, controlled by or under common control with Mutual of America Investment Corporation or any sub-advisers or the distributor of the Funds.
Name and Age
Position Held
With Fund
Length of
Time Served
Principal Occupation(s)
During Past Five Years
Number of
Portfolios in
Fund Complex
Overseen by
Director
Other Directorships
Held by Director
Carolyn N. Dolan,
age 76
Director
since
April 2011
Executive Vice
President, Head of
Direct Client
Investments, Fiera
Capital Inc.; prior
thereto Founding
Principal and
Portfolio Manager,
Samson Capital
Advisors LLC
53
Director, Market
Street Trust
Company; Trustee
Fellow, Fordham
University; Mutual
of America
Variable Insurance
Portfolios, Inc.
22

Name and Age
Position Held
With Fund
Length of
Time Served
Principal Occupation(s)
During Past Five Years
Number of
Portfolios in
Fund Complex
Overseen by
Director
Other Directorships
Held by Director
Stanley E. Grayson,
age 72
Director
since
November
2017
Vice Chairman and
Chief Operating
Officer, M.R. Beal &
Company (Retired
2014)
53
Director, TD Bank,
N.A.; Director,
YMCA of Greater
New York; Trustee,
College of the
Holy Cross;
Director, Mother
Cabrini Health
Foundation;
Mutual of America
Variable Insurance
Portfolios, Inc.
LaSalle D. Leffall, III,
age 60
Director
since
April 2011
President and
Founder of LDL
Financial, LLC
53
Advisory Board
member, Cabot
Properties; Mutual
of America
Variable Insurance
Portfolios, Inc.
John W. Sibal,
age 70
Director
since
April 2011
President & Chief
Executive Officer,
Eustis Commercial
Mortgage
Corporation
53
Director, Eustis
Commercial
Mortgage
Corporation;
Director, New
Orleans
Recreation
Development
Foundation;
Mutual of America
Variable Insurance
Portfolios, Inc.
Margaret M. Smyth,
age 59
Director
since
February
2007
Partner,
Queensland
Investment
Corporation (QIC);
prior thereto U.S.
Chief Financial
Officer, National
Grid until 2021;
prior thereto Vice
President of
Finance, Con
Edison; prior thereto
Vice President,
Chief Financial
Officer, Hamilton
Sundstrand, a
United
Technologies
Company
53
Director, Lilium
N.V.; Director,
Remitly, Inc.;
Director, Frontier
Communications;
Director, Etsy, Inc.;
Director, CenTrio;
Director, Renewa;
Board of Trustees,
Concern
Worldwide, USA;
Executive
Committee,
Fordham
University
President's
Council; Mutual of
America Variable
Insurance
Portfolios, Inc.
23

Name and Age
Position Held
With Fund
Length of
Time Served
Principal Occupation(s)
During Past Five Years
Number of
Portfolios in
Fund Complex
Overseen by
Director
Other Directorships
Held by Director
William E. Whiston,
age 69
Director
since
February
2011
Chief Financial
Officer, the
Archdiocese of
New York; Adjunct
Professor in
Finance, Fordham
University Graduate
School of Business;
prior thereto
Executive Vice
President and
member, United
States Management
Board at Allied Irish
Bank
53
Director, Webster
Financial Services
Corporation;
Trustee and
Treasurer,
Trustees of St.
Patrick’s Cathedral
in New York City;
Trustee, St.
Joseph’s
Seminary; Mutual
of America
Variable Insurance
Portfolios, Inc.
Interested Director and Officers
Name, Age and
Address(1)
Position Held
With Fund
Length of
Time Served
Principal Occupation(s)
During Past Five Years
Number of
Portfolios in
Fund Complex
Overseen
Directorships
Held by Officer
(During Past Five
Years)
Chris W. Festog,
age 61
Chairman,
Chief
Executive
Officer and
Principal
Executive
Officer
since
July 2022
Senior Executive
Vice President and
Chief Financial
Officer, Mutual of
America since
March 2017;
Chairman,
President and CEO
of Mutual of
America Investment
Corporation and
Mutual of America
Variable Insurance
Portfolios, Inc. since
July 2022
53
Mutual of America
Variable Insurance
Portfolios, Inc.;
Mutual of America
Holding Company
LLC; Mutual of
America Securities
LLC
Jason A. D'Angelo,
age 50
Chief Legal
Officer
since
July 2022
Executive Vice
President and
General Counsel
since July 2022;
prior thereto
Executive Vice
President and
Deputy General
Counsel since
February 2022;
prior thereto
Partner, Herrick
Feinstein LLP
53
None
24

Name, Age and
Address(1)
Position Held
With Fund
Length of
Time Served
Principal Occupation(s)
During Past Five Years
Number of
Portfolios in
Fund Complex
Overseen
Directorships
Held by Officer
(During Past Five
Years)
Richard Fabietti,
age 64
Assistant
Treasurer
Effective
October
2023
Vice President,
Investment
Products, Mutual of
America Capital
Management LLC
as of January 2023;
prior thereto Senior
Vice President,
HSBC Global Asset
Managment (USA)
and President,
HSBC Funds until
2020
53
Board Member,
Options for
Community Living;
Former Board
Member,
Sacramento
Braille
Transcribers, Inc.
Aferdita Gutierrez,
age 37
Treasurer,
Chief
Financial
Officer and
Principal
Financial
Officer
since
July 2022
Executive Vice
President, Deputy
Treasurer, Mutual of
America since
2021; prior thereto
Senior Vice
President
53
None
Amy Latkin,
age 45
Secretary
since
May 2022
Corporate
Secretary, Mutual of
America Investment
Corporation and
Mutual of America
Variable Insurance
Portfolios since May
2022; Vice
President,
Associate General
Counsel, Mutual of
America
53
None
Kyle Medlin,
age 39
Chief
Compliance
Officer
since
April 2023
Senior Vice
President and Chief
Compliance Officer,
Mutual of America
since April 2023;
prior thereto Vice
President,
Compliance, Mutual
of America
53
None
Christopher M.
Miseo,
age 67
Assistant
Treasurer
Since
March 2013
and until
October
2023
Senior Vice
President and
Director of
Accounting &
Financial Reporting,
Mutual of America
53
None
25

Name, Age and
Address(1)
Position Held
With Fund
Length of
Time Served
Principal Occupation(s)
During Past Five Years
Number of
Portfolios in
Fund Complex
Overseen
Directorships
Held by Officer
(During Past Five
Years)
Michelle A. Rozich,
age 49
Chief Risk
Officer
since
March 2018
Executive Vice
President,
Enterprise Risk
Management and
Internal Auditor as
of November 2020;
prior thereto Senior
Vice President and
Internal Auditor,
Mutual of America
as of March 2018;
Senior Vice
President and
Internal Auditor,
Mutual of America
Investment
Corporation, and
Mutual of America
Variable Insurance
Portfolios, Inc., and
Senior Vice
President and
Internal Auditor,
Mutual of America
Institutional Funds,
Inc. until July 2020;
formerly Audit
Senior Manager,
KPMG LLP
53
None
R. Jeffrey Young,
age 58
President
Since
June 2023
Executive Vice
President, Mutual of
America Capital
Management LLC
as of May 2022;
prior thereto Senior
Director, FIS
Transfer Agency
53
Former
Independent
Trustee, Zell
Capital

(1)The address of each director and officer is c/o Mutual of America Investment Corporation, 320 Park Avenue, New York, New York 10022-6839.
Officers and Directors who are participants under group or individual variable accumulation annuity or life insurance contracts issued by the Insurance Company or Wilton Re, may allocate portions of their account balances to one or more of the Investment Company’s Funds. The following table shows the amounts allocated to each Fund under contracts owned by each director of the Investment Company as of December 31, 2022.
Fund
Dollar Range of Equity Securities in the Funds
Chris W.
Festog
Carolyn N.
Dolan
Stanley E.
Grayson
LaSalle D.
Leffall
John W.
Sibal
Margaret M.
Smyth
William E.
Whiston
Equity Index
[Over
$100,000]
None
None
None
None
None
None
All America
None
None
None
None
None
None
None
Small Cap Value
None
None
None
None
None
None
None
26

Fund
Dollar Range of Equity Securities in the Funds
Chris W.
Festog
Carolyn N.
Dolan
Stanley E.
Grayson
LaSalle D.
Leffall
John W.
Sibal
Margaret M.
Smyth
William E.
Whiston
Small Cap Growth
None
None
None
None
None
None
None
Small Cap Equity Index
None
None
None
None
None
None
None
Mid Cap Value
None
None
None
None
None
None
None
Mid-Cap Equity Index
[Over
$100,000]
None
None
None
None
None
None
Composite
None
None
None
None
None
None
None
International
None
None
None
None
None
None
None
Money Market
None
None
None
None
None
None
None
Catholic Values Index
None
None
None
None
None
None
None
Mid-Term Bond
None
None
None
None
None
None
None
Bond
None
None
None
None
None
None
None
Retirement Income
None
None
None
None
None
None
None
2015 Retirement
None
None
None
None
None
None
None
2020 Retirement
None
None
None
None
None
None
None
2025 Retirement
None
None
None
None
None
None
None
2030 Retirement
None
None
None
None
None
None
None
2035 Retirement
None
None
None
None
None
None
None
2040 Retirement
None
None
None
None
None
None
None
2045 Retirement
None
None
None
None
None
None
None
2050 Retirement
None
None
None
None
None
None
None
2055 Retirement
None
None
None
None
None
None
None
2060 Retirement
None
None
None
None
None
None
None
2065 Retirement
None
None
None
None
None
None
None
Conservative Allocation
None
None
None
None
None
None
None
Moderate Allocation
None
None
None
None
None
None
None
Aggressive Allocation
None
None
None
None
None
None
None
Aggregate Dollar Range of
Equity Securities in the
Funds:
[Over
$100,000]
None
None
None
None
None
None
The officers and directors of the Investment Company own none of its outstanding shares directly, but as shares of separate accounts of the Insurance Company and the American Separate Accounts.
Capital Management and its parent company provide the Independent Directors with business travel and accident insurance and life insurance coverage of $75,000 at no charge to the Funds or the Independent Directors. In addition, the Independent Directors are eligible to participate in a program where Capital Management or its parent company provide a matching gift of up to $30,000 to a charity of the Independent Director's selection.
The Investment Company has an Audit Committee consisting of all the independent directors, which meets four times per year prior to each and every quarterly Board meeting. The purposes of the Committee are to assist the Board with its oversight of management and the Investment Company’s auditors regarding corporate accounting, financial reporting practices, and the quality and integrity of the Investment Company’s financial reports, including the Investment Company’s compliance with legal and regulatory requirements, the independent auditors’ qualifications and independence, the performance of the Investment Company’s internal audit function and of its independent auditors, and the preparation of all reports required by SEC rules. The Audit Committee met four times in 2022. Mr. Sibal is the Chairman of the Audit Committee.
The Investment Company has formed a Nominating Committee consisting of all the independent directors, which meets on an as-needed basis. The purposes of the Nominating Committee are to assist the Board, as necessary by identifying individuals qualified to become Board members; to recommend to the Board the director nominees if any are to be voted on at the next annual meeting of shareholders; to assist the Board in the event of any vacancy on the Board by identifying individuals qualified to become Board members, and to
27

recommend to the Board qualified individuals to fill any such vacancy; and to recommend to the Board director nominees for each Board committee. The Nominating Committee will review and consider nominations from shareholders of record that are made in writing to the Secretary of the Investment Corporation at the time that there is a Board vacancy requiring a shareholder vote. The Nominating Committee did not meet in 2022.
As of March 31, 2023, the following owned of record and/or beneficially 5% or more of the outstanding shares of a Mutual of America Investment Corporation Fund:
Fund Name
Owner Name
City, State
Owned of Record %
Equity Index
Mutual of America Separate Account No. 1
New York, New York
8.03%
 
Mutual of America Separate Account No. 2
New York, New York
19.80%
 
Mutual of America 2025 Retirement Fund
New York, New York
7.10%
 
Mutual of America 2030 Retirement Fund
New York, New York
9.07%
 
Mutual of America 2035 Retirement Fund
New York, New York
9.38%
 
Mutual of America 2040 Retirement Fund
New York, New York
8.69%
 
Mutual of America 2045 Retirement Fund
New York, New York
9.52%
 
Mutual of America 2050 Retirement Fund
New York, New York
7.47%
All America
Mutual of America Separate Account No. 1
New York, New York
14.17%
 
Mutual of America Separate Account No. 2
New York, New York
78.72%
Small Cap Value
Mutual of America Separate Account No. 1
New York, New York
17.85%
 
Mutual of America Separate Account No. 2
New York, New York
38.51%
 
Mutual of America 2030 Retirement Fund
New York, New York
5.09%
 
Mutual of America 2040 Retirement Fund
New York, New York
5.50%
Small Cap Growth
Mutual of America Separate Account No. 1
New York, New York
17.09%
 
Mutual of America Separate Account No. 2
New York, New York
46.73%
 
Mutual of America 2045 Retirement Fund
New York, New York
5.06%
Small Cap Equity
Index
Mutual of America Separate Account No. 1
New York, New York
6.60%
 
Mutual of America Separate Account No. 2
New York, New York
17.10%
 
Mutual of America 2030 Retirement Fund
New York, New York
7.78%
 
Mutual of America 2035 Retirement Fund
New York, New York
14.06%
 
Mutual of America 2040 Retirement Fund
New York, New York
9.58%
 
Mutual of America 2045 Retirement Fund
New York, New York
11.97%
 
Mutual of America 2050 Retirement Fund
New York, New York
12.88%
 
Mutual of America 2055 Retirement Fund
New York, New York
5.02%
Mid Cap Value
Mutual of America Separate Account No. 1
New York, New York
34.30%
 
Mutual of America Separate Account No. 2
New York, New York
61.47%
Mid-Cap Equity
Index
Mutual of America Separate Account No. 1
New York, New York
8.62%
 
Mutual of America Separate Account No. 2
New York, New York
25.50%
 
Mutual of America 2025 Retirement Fund
New York, New York
5.52%
 
Mutual of America 2030 Retirement Fund
New York, New York
7.49%
 
Mutual of America 2035 Retirement Fund
New York, New York
8.63%
 
Mutual of America 2040 Retirement Fund
New York, New York
7.77%
 
Mutual of America 2045 Retirement Fund
New York, New York
7.94%
 
Mutual of America 2050 Retirement Fund
New York, New York
5.97%
Composite
Mutual of America Separate Account No. 1
New York, New York
12.40%
 
Mutual of America Separate Account No. 2
New York, New York
86.52%
International
Mutual of America 2025 Retirement Fund
New York, New York
9.01%
 
Mutual of America 2030 Retirement Fund
New York, New York
11.91%
 
Mutual of America 2035 Retirement Fund
New York, New York
13.25%
 
Mutual of America 2040 Retirement Fund
New York, New York
12.50%
 
Mutual of America 2045 Retirement Fund
New York, New York
13.77%
 
Mutual of America 2050 Retirement Fund
New York, New York
10.89%
 
Mutual of America 2055 Retirement Fund
New York, New York
5.94%
28

Fund Name
Owner Name
City, State
Owned of Record %
Catholic Values
Index
Mutual of America Life Insurance Company
New York, New York
79.77%
 
Archdiocese of Kansas City
Kansas City, Kansas
14.69%
Money Market
Mutual of America Separate Account No. 1
New York, New York
21.27%
 
Mutual of America Separate Account No. 2
New York, New York
17.59%
 
Mutual of America 2020 Retirement Fund
New York, New York
5.92%
 
Mutual of America 2025 Retirement Fund
New York, New York
9.62%
 
Mutual of America 2030 Retirement Fund
New York, New York
10.29%
 
Mutual of America 2035 Retirement Fund
New York, New York
7.66%
 
Mutual of America 2040 Retirement Fund
New York, New York
5.44%
Mid-Term Bond
Mutual of America Separate Account No. 1
New York, New York
8.90%
 
Mutual of America Separate Account No. 2
New York, New York
9.08%
 
Mutual of America Conservative Allocation Fund
New York, New York
6.76%
 
Mutual of America Moderate Allocation Fund
New York, New York
7.05%
 
Mutual of America Retirement Income Fund
New York, New York
7.66%
 
Mutual of America 2020 Retirement Fund
New York, New York
12.78%
 
Mutual of America 2025 Retirement Fund
New York, New York
19.47%
 
Mutual of America 2030 Retirement Fund
New York, New York
15.61%
 
Mutual of America 2035 Retirement Fund
New York, New York
6.25%
Bond
Mutual of America Separate Account No. 1
New York, New York
5.29%
 
Mutual of America Separate Account No. 2
New York, New York
9.27%
 
Mutual of America 2020 Retirement Fund
New York, New York
7.99%
 
Mutual of America 2025 Retirement Fund
New York, New York
16.48%
 
Mutual of America 2030 Retirement Fund
New York, New York
14.03%
 
Mutual of America 2035 Retirement Fund
New York, New York
10.47%
 
Mutual of America 2040 Retirement Fund
New York, New York
7.15%
 
Mutual of America 2045 Retirement Fund
New York, New York
5.35%
Retirement Income
Mutual of America Separate Account No. 1
New York, New York
32.10%
 
Mutual of America Separate Account No. 2
New York, New York
49.13%
2015 Retirement
Mutual of America Separate Account No. 1
New York, New York
23.36%
 
Mutual of America Separate Account No. 2
New York, New York
68.98%
2020 Retirement
Mutual of America Separate Account No. 1
New York, New York
30.11%
 
Mutual of America Separate Account No. 2
New York, New York
62.22%
2025 Retirement
Mutual of America Separate Account No. 1
New York, New York
31.87%
 
Mutual of America Separate Account No. 2
New York, New York
57.68%
2030 Retirement
Mutual of America Separate Account No. 1
New York, New York
32.34%
 
Mutual of America Separate Account No. 2
New York, New York
56.65%
 
 
 
 
2035 Retirement
Mutual of America Separate Account No. 1
New York, New York
33.27%
 
Mutual of America Separate Account No. 2
New York, New York
54.50%
2040 Retirement
Mutual of America Separate Account No. 1
New York, New York
33.34%
 
Mutual of America Separate Account No. 2
New York, New York
55.99%
2045 Retirement
Mutual of America Separate Account No. 1
New York, New York
31.47%
 
Mutual of America Separate Account No. 2
New York, New York
58.37%
2050 Retirement
Mutual of America Separate Account No. 1
New York, New York
32.57%
 
Mutual of America Separate Account No. 2
New York, New York
57.37%
2055 Retirement
Mutual of America Separate Account No. 1
New York, New York
33.41%
 
Mutual of America Separate Account No. 2
New York, New York
55.45%
2060 Retirement
Mutual of America Separate Account No. 1
New York, New York
32.74%
 
Mutual of America Separate Account No. 2
New York, New York
54.94%
2065 Retirement
Mutual of America Separate Account No. 1
New York, New York
34.70%
 
Mutual of America Separate Account No. 2
New York, New York
53.46%
29

Fund Name
Owner Name
City, State
Owned of Record %
Conservative
Allocation
Mutual of America Separate Account No. 1
New York, New York
30.20%
 
Mutual of America Separate Account No. 2
New York, New York
68.50%
Moderate
Allocation
Mutual of America Separate Account No. 1
New York, New York
25.55%
 
Mutual of America Separate Account No. 2
New York, New York
73.61%
Aggressive
Allocation
Mutual of America Separate Account No. 1
New York, New York
24.78%
 
Mutual of America Separate Account No. 2
New York, New York
74.31%
Set forth below is a table showing compensation paid to the Independent Directors during 2022. The directors and officers as a group own less than 1% of the shares of the Fund.
Name of Director
Aggregate
Compensation from
Investment
Company(1)
Pension or
Retirement Benefits
Accrued as Part of
Fund Expenses
Estimated
Benefits
Upon Retirement
Total Compensation from
Investment Company and
Other Investment
Companies in Complex(2)
Carolyn N. Dolan
$103,880
None
None
$106,000
Stanley E. Grayson
$103,880
None
None
$106,000
LaSalle D. Leffall, III
$103,880
None
None
$106,000
John W. Sibal
$105,840
None
None
$108,000
Margaret M. Smyth
$105,840
None
None
$108,000
William E. Whiston
$103,880
None
None
$106,000

(1)In 2022, Directors who are not “interested persons” of the Investment Company received from the Investment Company an annual retainer of $90,000. The Directors who are not “interested persons” also received a fee of $2,000 for each Board or Committee meeting they attend. The Audit Committee Chairman and Audit Committee Financial Expert received an additional $500 for each committee meeting they attend. The total retainer, meeting fees and other expenses are allocated proportionately to the Investment Company, and Mutual of America Variable Insurance Portfolios, as all the Directors serve on the Boards of these Funds.
(2)
Directors who are not interested persons of the Investment Company also serve as directors of Mutual of America Variable Insurance Portfolios, an affiliated registered investment company in the same complex as the Investment Company.

INVESTMENT ADVISORY ARRANGEMENTS
Investment Adviser. The Investment Company’s investment adviser is Mutual of America Capital Management LLC an indirect wholly-owned subsidiary of the Insurance Company. The Adviser’s address is 320 Park Avenue, New York, New York 10022-6839. The Adviser is a registered investment adviser under the Investment Advisers Act of 1940.
Capital Management has served as Adviser since November 1993, when it assumed investment management obligations for the Investment Company from the Insurance Company. The Adviser provides investment management services to the Investment Company, Mutual of America Variable Insurance Portfolios, Inc., the General Account of the Insurance Company and unaffiliated entities.
The Adviser provides advisory services for the Investment Company’s Funds, in accordance with the Funds’ investment policies, objectives and restrictions as set forth in the Prospectus and this Statement of Additional Information. The Adviser’s activities are subject at all times to the supervision and approval of the Investment Company’s Board of Directors.
Under the Investment Advisory Agreement, the Adviser agrees to provide investment management services to the Investment Company. These services include:
performing investment research and evaluating pertinent economic, statistical and financial data;
30

consultation with the Investment Company’s Board of Directors and furnishing to the Investment Company’s Board of Directors recommendations with respect to the overall investment plan;
implementation of the overall investment plan, including carrying out decisions to acquire or dispose of investments;
management of investments;
reporting to the Investment Company’s Board of Directors on a regular basis on the implementation of the investment plan and the management of investments;
maintaining all required records;
making arrangements for the safekeeping of assets; and
providing office space facilities, equipment, material and personnel necessary to fulfill its obligations.
The Adviser is responsible for all expenses incurred in performing the investment advisory services, including compensation of officers and payment of office expenses, and for providing investment management services.
The Adviser has separately entered into an arrangement with the Insurance Company for the provision of investment accounting and recordkeeping, legal and certain other services.
Advisory Fees. As compensation for its services to each of the Funds of the Investment Company, the Funds pay the Adviser a fee at the following annual rates of net assets, calculated as a daily charge:
Equity Index, Mid-Cap Equity Index, and Small Cap Equity Index Funds — .075%
All America, Composite and Mid-Term Bond Funds — .40%
Bond Fund — .39%
Small Cap Growth Fund — .75%
Small Cap Value Fund — .75%
Mid Cap Value Fund — .55%
Catholic Values Index Fund — .15%
International Fund — .075%
Money Market Fund — .15%
Allocation Funds — .00%
Retirement Funds — .05%
Investment Advisory Fees Paid by Funds to Adviser For Past Three Years
Fund
2022
2021
2020
Equity Index
$3,322,091
$3,292,400
$2,442,682
All America
$1,245,574
$1,413,859
$1,105,923
Small Cap Value
$3,759,493
$4,092,184
$2,988,814
Small Cap Growth
$3,773,096
$5,160,123
$4,143,040
Small Cap Equity Index
$114,206
$102,234
$35,368
Mid Cap Value
$688,700
$626,699
$447,573
Mid-Cap Equity Index
$1,303,342
$1,500,838
$1,114,109
Composite
$773,399
$826,220
$719,182
International
$852,735
$829,997
$540,011
Catholic Values Index
$6,434
$5,811
$1,196(1)
Money Market
$340,706
$222,276
$204,909
Mid-Term Bond
$3,541,315
$3,266,362
$2,910,345
Bond
$7,227,364
$7,720,703
$6,670,579
Retirement Income
$103,921
$101,593
$76,883
2010 Retirement(3)
$0
$0
$7,846
2015 Retirement
$61,893
$70,374
$67,619
2020 Retirement
$269,304
$305,161
$280,783
2025 Retirement
$541,634
$555,358
$456,553
31

Fund
2022
2021
2020
2030 Retirement
$562,626
$554,326
$420,640
2035 Retirement
$504,891
$486,977
$353,585
2040 Retirement
$419,149
$411,679
$292,915
2045 Retirement
$434,269
$425,120
$302,817
2050 Retirement
$327,087
$316,147
$216,237
2055 Retirement
$157,978
$138,092
$81,554
2060 Retirement
$67,488
$49,940
$22,772
2065 Retirement
$11,810
$4,849
$320(2)
Total Fees
$30,410,505
$32,479,322
$25,904,255

(1)For the period September 30, 2020 (commencement of operations) to December 31, 2020.
(2)
For the period August 3, 2020 (commencement of operations) to December 31, 2020.
(3)
Assets transferred into the Retirement Income Fund on July 31, 2020.
Other Fund Expenses. Each Fund is responsible for paying its advisory fee and other expenses incurred in its operation, including:
brokers’ commissions, transfer taxes and other fees relating to the Fund’s portfolio transactions,
directors’ fees and expenses,
fees and expenses of its independent registered public accountants for audit and tax compliance services,
all legal and compliance costs incurred by the Fund in its operations, including as a registered investment company under the Investment Company Act of 1940,
the cost of the printing and mailing annual and semi-annual reports to shareholders, Proxy Statements, Prospectuses, Prospectus Supplements and Statements of Additional Information,
the cost of preparation and filing registration statements and amendments thereto,
bank transaction charges and custodian’s fees,
any proxy solicitors’ fees and expenses,
SEC filing fees,
any federal, state or local income or other taxes,
any membership or licensing fees of the Investment Company Institute and similar organizations,
fidelity bond and directors’ liability insurance premiums,
accounting and recordkeeping services, and
any extraordinary expenses, such as indemnification payments or damages awarded in litigation or settlements made.
Certain of the expenses are for services not included in the Investment Advisory Agreement that are provided to the Funds by the Adviser and are allocated to the Funds by the Adviser or an affiliate of the Adviser. Expenses allocated to the Funds were $2,800,040 in 2022, $2,415,957 in 2021 and $2,266,555 in 2020.
Portfolio Manager Compensation — Adviser
This description of the structure of, and the method used to determine the compensation of, the portfolio managers applies to all portfolio managers of the Adviser and the person overseeing the index Funds of the Investment Company.
32

All portfolio managers of the Adviser receive a fixed base annual salary and may qualify for an annual incentive compensation award, or bonus. The bonus is based upon the pre-tax annual performance of the portions or segments (“portfolio”) of Funds managed by the portfolio manager relative to the appropriate nationally recognized benchmarks which have been selected for each portfolio, which can be adjusted by a factor related to the performance of the Insurance Company. The portfolio benchmarks consist of well-recognized indices such as the Standard and Poor’s® 500 Index, and the Russell 2000® Index, which vary by portfolio and are more specifically described by portfolio in the Prospectus and this SAI.
All employees of the Adviser are entitled to health insurance, group life insurance and group disability coverage, a non-contributory defined benefit pension plan, and an employer-matched 401(k) plan. Certain senior management employees are also eligible for a long term performance-based incentive compensation plan. Under the plan, shares are granted each year and generally vest over a three-year period. The value of such shares is based upon increases in the Insurance Company’s General Account statutory surplus and the maintenance of certain financial ratios. No relocation plan applies to the portfolio managers.
Name
Title
Portfolios Managed/Overseen
Incentive Compensation
Benchmark
Joseph R.
Gaffoglio
President
Large Cap (All America Fund)
Large Cap Core (Composite Fund)
Retirement Funds
Allocation Funds
S&P 500®
S&P 500®
S&P 500®
Bloomberg U.S.
Aggregate Bond
Christopher
Malfant
Executive Vice
President,
Fixed Income
Bond Fund
Fixed Income (Composite Fund)
Mid-Term Bond Fund
Bloomberg U.S.
Aggregate Bond
Bloomberg U.S.
Aggregate Bond
Bloomberg Intermediate
U.S. Government/Credit
Bond
Stephen J. Rich
Chief Executive
Officer
Small Cap Value (All America Fund)
Small Cap Value Fund
Mid Cap Value (All America Fund)
Mid Cap Value Fund
Russell 2000® Value
Russell 2000® Value
Russell Midcap® Value
Russell Midcap® Value
Jacqueline
Sabella
Senior Vice
President, Fixed
Income
Bond Fund
Fixed Income (Composite Fund)
Mid-Term Bond Fund
Bloomberg
U.S. Aggregate Bond
Bloomberg
U.S. Aggregate Bond
Bloomberg Intermediate
U.S. Government/Credit
Bond
Marguerite
Wagner
Executive Vice
President,
Portfolio Manager
Small Cap Growth (All America
Fund)
Small Cap Growth Fund
Mid Cap Core (All America Fund)
Russell 2000® Growth
Russell 2000® Growth
S&P 500®
Erik Wennerstrum
Second Vice
President,
Portfolio Manager
Equity Index Fund
Small Cap Equity Index Fund
Mid-Cap Equity Index Fund
Equity Index (All America Fund)
Catholic Values Index Fund
S&P 500®
S&P 600®
S&P 400®
S&P 500®
S&P 500® Catholic
Values Index
33

Name
Title
Portfolios Managed/Overseen
Incentive Compensation
Benchmark
Jamie A. Zendel
Executive Vice
President,
Quantitative
Research, Equity
Indexes, Trading
and
Administration
Equity Index Fund
Small Cap Equity Index Fund
Mid-Cap Equity Index Fund
Equity Index (All America Fund)
Catholic Values Index Fund
International Fund
Retirement Funds
Allocation Funds
S&P 500®
S&P 600®
S&P 400®
S&P 500®
S&P 500® Catholic
Values Index
MSCI EAFE
S&P 500®
Bloomberg U.S.
Aggregate Bond
Other Information — Adviser
The Adviser’s portfolio managers do not manage funds or portfolios for entities other than clients of the Adviser. In addition to unaffiliated entities, the Adviser manages funds of the Investment Company, Mutual of America Variable Insurance Portfolios, Inc. (“Variable Insurance Portfolios”), and a few individually managed pension plans holding contracts with the Insurance Company, all of which are identified below. In regard to possible conflicts, if a portfolio manager identifies a limited investment opportunity which may be suitable for more than one fund or other account, a Fund may not be able to take full advantage of that opportunity due to an allocation of filled purchase or sale orders across all eligible Funds and other accounts. To deal with these situations, the Funds have adopted procedures for allocating portfolio transactions across multiple Funds and accounts. The following information concerning the portfolio managers and the person overseeing the index Funds is in addition to that provided in the Prospectus under the heading, “Portfolio Managers”.
The section under each Portfolio Manager’s name entitled “Ownership of Securities” sets forth the dollar range of equity securities in the Investment Company Funds beneficially owned by the Portfolio Manager. The access persons of the Adviser are subject to restrictions contained in the Code of Ethics adopted by the Adviser in accordance with Rule 204A-1 under the Investment Advisers Act of 1940, which addresses conflicts of interest between access persons and a Fund. Trades are allocated pro rata among clients. The information is presented in tabular format followed by more detailed explanatory text.
Portfolio Manager
Registered Investment
Companies [Assets
as of 12/31/22]
Other
Pooled
Investment
Vehicles
[Assets as
of 12/31/22]
Other Accounts
[Assets as of
12/31/22]
Ownership of
Securities
Joseph R. Gaffoglio
30 Funds [$7,986.6
million]
0
0
IC Composite Fund
[Over $100,000]
IC Equity Index
[$10,001 - $50,000]
IC Mid- Cap Equity
Index Fund
[$10,001 - $50,000]
IC Small Cap Value
Fund
[$10,001-50,000]
MOAIC Mid-Term
Bond Fund
[$10,00 - $50,000]
MOAIC International
[$10,001 - $50,000]
Christopher Malfant
5 Funds [$2,833.9
million]
0
7 other accounts:
[$8,682.5 million]
IC 2040 Retirement
Fund
[$50,001 - $100,000]
34

Portfolio Manager
Registered Investment
Companies [Assets
as of 12/31/22]
Other
Pooled
Investment
Vehicles
[Assets as
of 12/31/22]
Other Accounts
[Assets as of
12/31/22]
Ownership of
Securities
Stephen Rich
8 Funds [$588.1 million]
0
2 other accounts:
[$28.5 million]
IC Small Cap Value
Fund
[over $100,000]
IC Mid Cap Value
Fund [over $100,000]
Jacqueline Sabella
5 Funds [$2,833.9
million]
0
7 other accounts:
[$8,682.5 million]
 
Marguerite Wagner
6 Funds [$515.2 million]
0
2 other accounts:
[$18.8 million]
IC Mid- Cap Equity
Index Fund
[$50,001- $100,000]
IC Small Cap Growth
Fund
[$50,001-100,000]
Erik Wennerstrum
9 Funds [$6,445.1
million]
0
4 other accounts
[$109.9 million]
MOAIC Equity Index
Fund
[$10,001 - $50,000]
MOAIC Mid-Cap
Equity Index Fund
[$10,001 - $50,000]
MOAIC Small Cap
Equity Index Fund
[$1,001-$10,000]
MOAIC Mid Cap
Value Fund
[$1,001-$10,000]
MOAIC Small Cap
Growth Fund
[$1,001-$10,000]
MOAIC Small Cap
Value Fund
[$1,001-$10,000]
Jamie A. Zendel
11 Funds [$7,660.2
million]
0
4 other accounts
[$109.9 million]
IC Equity Index
[over $100,000]
IC Mid- Cap Equity
Index Fund
[$50,001 - $100,000]
IC Small Cap Growth
Fund
[$10,001-50,000]
IC Small Cap Value
Fund
[$50,001-$100,000]
Joseph R. Gaffoglio — President
Length of Service:
16 years at Adviser, 27 years in the investment management field
35

Role:
Focus on quantitative research and risk management, and responsible for
rebalancing and reallocation of the investments of the Investment Corporation
Retirement Funds and Allocation Funds, and the Variable Insurance Portfolios
Retirement Portfolios and Allocation Portfolios, and for managing large cap portfolios
for Investment Corporation and Variable Insurance Portfolios
Education:
Undergraduate, Fordham University; MBA New York University; CFA; CPA
Christopher Malfant — Executive Vice President and Port folio Manager
Length of Service:
First year at Adviser; 15 years investment experience
Role:
Sets fixed income strategy and manages the Investment Corporation Bond Fund,
Mid-Term Bond Fund and the fixed income portion of the Composite Fund, and
manages the Variable Insurance Portfolios Bond Portfolio and Mid-Term Bond
Portfolio
Education:
Undergraduate, Duke University; MBA, University of Chicago Booth School of
Business
Stephen J. Rich — Chief Executive Officer
Length of Service:
18 years at Adviser; 30 years investment experience
Role:
Portfolio Manager for the Investment Corporation Small Cap Value Fund, Mid Cap
Value Fund and the small cap and mid-cap value segments of the Investment
Corporation All America Fund; and for the Variable Insurance Portfolios Small Cap
Value Portfolio, Mid Cap Value Portfolio and the small and mid-cap value segments of
the Variable Insurance Portfolios All America Portfolio
Education:
Undergraduate, Princeton University; MBA, New York University
Jacqueline Sabella — Senior Vice President and Portfolio Manager
Length of Service
22 years at Adviser, 25 years investment experience
Role
Manager of mortgage-backed securities portfolio of fixed income funds and portfolios
for the Investment Corporation and Variable Insurance Portfolios
Education
Undergraduate, Marymount Manhattan College
Marguerite Wagner — Executive Vice President and Portfolio Manager
Length of Service:
17 years at Adviser; 39 years investment experience
Role:
Portfolio manager for the Investment Corporation Small Cap Growth Fund and the
small cap and mid-cap growth segments of the Investment Corporation All America
Fund; and for the Variable Insurance Portfolios Small Cap Growth Portfolio and the
small cap and mid-cap growth segments of the Variable Insurance Portfolios All
America Portfolio
Education:
Undergraduate, Penn State University; MBA New York University
Erik Wennerstrum – Second Vice President and Portfolio Manager
Length of Service:
2 years at Adviser; 7 years investment experience
Role:
Works with the Adviser’s quantitative research group and serves as a portfolio
manager of the Investment Corporation and Variable Insurance Portfolios equity
index funds and portfolios.
Education:
Undergraduate, James Madison University; CPA
Jamie A. Zendel — Executive Vice President, Quantitative Research, Equity Indexes, Trading and
Administration
36

Length of Service:
15 years at Adviser, 24 years investment experience
Role:
Portfolio manager for the Investment Corporation and Variable Insurance Portfolios
index funds and portfolios, and Retirement and Allocation funds and portfolios, and
portfolio manager of Investment Corporation International Fund and Variable
Insurance Portfolios International Portfolio
Education:
Undergraduate, University of Wisconsin — Madison; FRM
Subadvisory Fees. There were no Subadvisory fees paid during 2022, 2021 or 2020.
Codes of Ethics. The Investment Company, the Adviser, and the Insurance Company have adopted codes of ethics under Rule 17j-1 of the 1940 Act. Persons subject to these codes (generally, persons with access to information about the investment programs of the Funds) may not purchase certain securities in which the Investment Company’s Funds may invest unless their purchases have been precleared in accordance with the codes and do not occur within certain black-out periods imposed under the codes. The Investment Company has also adopted a code of ethics applicable to its chief executive officer and principal financial and accounting officers as disclosed in its shareholder reports.
The Adviser has adopted a code of ethics that meets the requirements of Rule 204A-1 under the Investment Advisers Act of 1940.

PORTFOLIO TRANSACTIONS AND BROKERAGE
Selection of Brokers and Dealers
The Adviser is responsible for decisions to buy and sell securities for the Funds of the Investment Company for which it provides services as well as for selecting brokers and, where applicable, negotiating the amount of the commission rate paid.
The Adviser selects broker-dealers which, in its best judgment, provide prompt and reliable execution at favorable security prices and reasonable commission rates.
The Adviser may select broker-dealers that provide it with research services and may cause a Fund to pay such broker-dealers commissions which exceed those other broker-dealers may charge, if in its view the commissions are reasonable in relation to the value of the brokerage and/or research services provided by the broker-dealer.
The Adviser may place certain orders with their affiliates, subject to the requirements of the 1940 Act.
Brokerage commissions are negotiated, as there are no standard rates. All brokerage firms provide the service of execution of the order made. Some brokerage firms routinely provide research and statistical data to their customers, and some firms customarily provide research reports on particular companies and industries to customers that place a certain volume of trades with them.
The Adviser will place orders with brokers providing useful research and statistical data services if reasonable commissions can be negotiated for the total services furnished even though lower commissions may be available from brokers not providing such services. The Adviser uses these services in connection with all investment activities, and some of the data or services obtained in connection with the execution of transactions for the Investment Company may be used in managing other investment accounts. Conversely, data or services obtained in connection with transactions in other accounts may be used by the Adviser in providing investment advice to the Investment Company. To the extent that the Adviser uses research and statistical data services so obtained, its expenses may be reduced.
37

At times, transactions for the Investment Company may be executed together with purchases or sales of the same security for other accounts of the Adviser. When making concurrent transactions for several accounts, an effort is made to allocate executions fairly among them. Transactions of this type are executed only when the Adviser believes it to be in the best interests of the affected Fund(s), as well as any other accounts involved. However, the possibility exists that concurrent executions may work out to the disadvantage of the Fund(s) involved.
The Investment Company paid aggregate brokerage commissions of $1,615,412 in 2022, $2,257,053 in 2021, and $2,058,378 in 2020.
Commissions to Affiliated Brokers
For the years 2022, 2021, and 2020 no commissions were paid to affiliated brokers.
Portfolio Turnover
The Adviser does not consider portfolio turnover rate to be a limiting factor when the Adviser deems it appropriate to purchase or sell securities for a Fund. The portfolio turnover rate for a Fund in any year will depend on market conditions, and the rate may increase depending on market conditions or if a new portfolio manager for a Fund restructures its holdings. The Adviser does not consider how long a Fund has held a security, or how capital gain upon sale would be characterized, in deciding whether and when to sell that security.

PURCHASE, REDEMPTION AND PRICING OF SHARES
Calculation of Net Asset Value
A shareholder (including a Separate Account) purchases or redeems shares of a Fund at net asset value. A Fund’s net asset value is equal to:
the sum of the value of the securities the Fund holds,
plus any cash or other assets, including interest and dividends accrued, and
minus all liabilities, including accrued expenses.
The net asset value of each Fund is determined once daily immediately after the declaration of dividends, if any, and is determined as of the time of the close of the regular trading session on the New York Stock Exchange (generally 4:00 p.m. Eastern Time) on each day the Exchange is open for trading (a Valuation Day). A Valuation Period for calculation of a Fund’s net asset value per share is the period after the close of a Valuation Day and ending at the close of the next Valuation Day.
A Fund’s net asset value per share is equal to the Fund’s net asset value divided by the number of Fund shares outstanding.
Pricing of Securities Held by the Funds
In determining a Fund’s net asset value, the Adviser must value the securities and other assets the Fund owns.
1)
If market quotations are readily available for an investment, the Adviser uses market value as follows:
Equity securities that are traded on a securities exchange are generally valued at their last quoted sale price or official closing price on the primary exchange for such security, as reported by a pricing service.
38

Debt securities, including corporate bonds; obligations of the U.S. Treasury and U.S. Government agencies; foreign sovereign issues; and non-U.S. bonds, are generally valued based upon evaluated or composite quotations obtained from third party pricing services and/or brokers and dealers selected by the Adviser (each a “pricing service”).
2)
If no current market quotation is readily available or reliable for a security, the fair value of the security will be determined in accordance with the Funds' valuation procedures. See “Pricing of Fund Shares” in the Prospectus.
3)
If a money market security has a remaining maturity of 60 days or less, the Adviser will generally use the amortized cost method of valuation to approximate market value, except that:
Market value will be used instead if the amortized cost value is determined to be materially different from the actual market value of the security.
4)
For stock options and futures contracts, these valuation methodologies generally apply:
Stock options written by a Fund are valued at the mean of the last bid and asked price on the principal exchange where the option is traded, as of the close of trading on that exchange.
Futures contracts, and options thereon, traded on commodities exchanges are valued at their official settlement price as of the close of such commodities exchanges.
5)
For Funds that invest in underlying investment companies:
For any portion of a Fund’s assets that are invested in an underlying investment company, that Fund’s net asset value is calculated based on the net asset values of the investment company in which the Fund has invested except for investments in ETFs, which are based on the market value of the ETFs.
Frequent Transfers
The Prospectus discloses the Investment Company’s policy on frequent transfers.
The Investment Company has no arrangements with any person or entities to permit frequent transfers and no such arrangements are permitted.

TAXATION OF THE FUNDS
The following discussion of U.S. federal income tax consequences of an investment in the Funds is based on the Internal Revenue Code of 1986, as amended (the “Code”), U.S. Treasury regulations, and other applicable authority, as of the date of this SAI. These authorities are subject to change by legislative or administrative action, possibly with retroactive effect. The following discussion is only a summary of some of the important U.S. federal income tax considerations generally applicable to investments in the Funds. There may be other tax considerations applicable to particular shareholders. Shareholders should consult their own tax advisors regarding their particular situation and the possible application of foreign, state and local tax laws.
Special tax rules apply to investments through defined contribution plans and other tax-qualified plans or tax-advantaged arrangements. Shareholders should consult their tax advisors to determine the suitability of Sshares of a Fund as an investment through such plans and arrangements and the precise effect of an investment on their particular tax situations. The discussion below does not address the tax considerations applicable to investors through Separate Accounts.
39

Taxes on Funds’ Investment Earnings and Income
Each Fund has in the past qualified for the special tax treatment afforded a “regulated investment company” (“RIC”) under Subchapter M of the Code, and each Fund intends to continue to qualify and be eligible for treatment under Subchapter M. A Fund will not owe Federal income tax on the ordinary income and net realized capital gains that it distributes to shareholders, if it qualifies for treatment as a regulated investment company.
If any Fund were to fail to qualify for treatment as a regulated investment company, it would be subject to Federal income tax on its ordinary income and net realized capital gains, whether or not it distributes the income and gains to shareholders. If a Fund were to pay Federal income tax, its investment performance would be negatively affected.
To qualify or continue to qualify for treatment as a RIC, a Fund must distribute with respect to each taxable year to its shareholders at least 90% of the sum of its investment company taxable income (as that term is defined in the Code without regard to the deduction for dividends paid — generally taxable ordinary income and the excess, if any, of net short-term capital gains over net long-term capital losses) and net tax-exempt income, for such year, and must meet several additional requirements. For each Fund, these requirements include the following: (1) the Fund must derive at least 90% of its gross income each taxable year from (a) dividends, interest, payments with respect to securities loans, and gains from the sale or other disposition of securities or foreign currencies or other income (including gains from options, futures, or forward contracts) derived with respect to its business of investing in securities or those currencies and (b) net income from an interest in a “qualified publicly traded partnership” (“QPTP”); and (2) the Fund must diversify its holdings so that, at the close of each quarter of the Fund’s taxable year, (a) at least 50% of the value of its total assets must be represented by cash and cash items, U.S. Government Securities, securities of other RICs, and other securities that are limited, in respect of any one issuer, to an amount that does not exceed 5% of the value of the Fund’s total assets and that does not represent more than 10% of the issuer’s outstanding voting securities (equity securities of QPTPs being considered voting securities for these purposes) and (b) not more than 25% of the value of its total assets may be invested, including through corporations in which the Fund owns a 20% or more voting stock interest, in (i) the securities (other than U.S. Government Securities or securities of other RICs) of any one issuer, (ii) the securities (other than securities of other RICs) of two or more issuers the Fund controls that are determined to be engaged in the same, similar, or related trades or businesses, or (iii) the securities of one or more QPTPs (collectively, “RIC Diversification Requirements”).
In general, for purposes of the 90% gross income requirement described above, income derived from a partnership will be treated as qualifying income only to the extent such income is attributable to items of income of the partnership which would be qualifying income if realized directly by the RIC.
For purposes of the RIC Diversification Requirements, the term “issuer’s outstanding voting securities” will include the equity securities of a qualified publicly traded partnership. Also, for purposes of the RIC Diversification Requirements above, the identification of the issuer (or, in some cases, issuers) of a particular Fund investment can depend on the terms and conditions of that investment. In some cases, identification of the issuer (or issuers) is uncertain under current law, and an adverse determination or future guidance by the Internal Revenue Service (“IRS”) with respect to issuer identification for a particular type of investment may adversely affect a Fund’s ability to meet the RIC Diversification Requirements.
If a Fund qualifies as a RIC that is accorded special tax treatment, the Fund will not be subject to federal income tax on income or gains distributed in a timely manner to its shareholders in the form of dividends (including Capital Gain Dividends, as defined below). If a Fund were to fail to meet the income, diversification or distribution test described above, the Fund could in some cases cure such failure, including by paying a Fund-level tax, paying interest or disposing of certain assets. If such Fund were ineligible to or otherwise did not cure such failure for any year, or if such Fund otherwise failed to qualify for treatment as a RIC for any taxable year, then for Federal tax purposes it would be taxed as an ordinary corporation on the full amount of its taxable income for that year without being able to deduct the distributions it makes to its shareholders, and all distributions from earnings and profits, including any distributions of net tax-exempt income (if any) and net capital gains (as defined below), would be taxable to shareholders as ordinary income. Some portions of such distributions may be eligible for the dividends-received deduction in the case of corporate shareholders and
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may be eligible to be treated as “qualified dividend income” in the case of shareholders taxed as individuals, provided, in both cases, the shareholder meets certain holding period and other requirements in respect of a Fund’s shares (each as described below). Furthermore, the Fund could be required to recognize unrealized gains, pay substantial taxes and interest, and make substantial distributions before requalifying for RIC treatment.
Each Fund intends to distribute at least annually to its shareholders all or substantially all of its investment company taxable income (computed without regard to the dividends-paid deduction) and its net tax-exempt income (if any), and may distribute its net capital gain (that is, the excess of net long-term capital gain over net short-term capital loss, in each case determined with reference to any loss carryforwards). Any taxable income retained by a Fund will be subject to tax at the Fund level at regular corporate rates.
If a Fund were to fail to distribute in a calendar year at least an amount equal, in general, to the sum of 98% of its ordinary income for such year and 98.2% of its capital gain net income for the one-year period ending October 31 of such year (or November 30 or December 31 if the Fund is eligible to elect and so elects), plus any such amounts retained from the prior year, the Fund would be subject to a nondeductible 4% excise tax on the undistributed amounts. Each Fund intends generally to make distributions sufficient to avoid imposition of the excise tax, although there can be no assurance that it will be able to do so. Distributions declared by a Fund during October, November and December to shareholders of record on a date in any such month and paid by the Fund during the following January will be treated for federal tax purposes as paid by the Fund and received by shareholders on December 31 of the year in which declared.
Capital losses in excess of capital gains (“net capital losses”) are not permitted to be deducted against a Fund’s net investment income. Instead, potentially subject to certain limitations, a Fund may carry net capital losses from any taxable year forward to subsequent taxable years to offset capital gains, if any, realized during such subsequent taxable years. Distributions from capital gains are generally made after applying any available capital loss carryforwards. Capital loss carryforwards are reduced to the extent they offset current-year net realized capital gains, whether the Fund retains or distributes such gains. A Fund may carry net capital losses forward to one or more subsequent taxable years without expiration; any such carryforward losses will retain their character as short-term or long-term. The Fund must apply such carryforwards first against gains of the same character. See a Fund’s annual shareholder report for the Fund’s available capital loss carryovers as of the end of its most recently ended fiscal year.
Taxation of Distributions Received by Shareholders
For U.S. federal income tax purposes, distributions of investment income are generally taxable to shareholders as ordinary income. Taxes on distributions of capital gains are determined by how long a Fund has owned (or is deemed to have owned) the investments that generated them, rather than how long a shareholder has owned his or her Fund shares. In general, a Fund will recognize long-term capital gain or loss on the disposition of assets the Fund has owned (or is deemed to have owned) for more than one year, and