Thrivent Investment Management Inc.

• A percentage of assets under your management
• Fixed fees (other than subscription fees)

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

The brochure lists different fees for different services or strategies. See the firm's brochure (dated July 20, 2026) for its fees and any account minimum, on the SEC's IAPD site.

$20,769,867,010 as of October 2026, filing dated September 30, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Financial planning services
• Portfolio management for individuals and/or small businesses

Registration

SEC-registered investment adviser. Status as filed: Approved.

Registered since

1987 (39 years)

Employees

Total: 3,901. Performing investment advisory functions: 2,963.

Wrap fee program participation

Yes.

Other offices (Schedule D, Section 1.F)

25 other offices, as of the October 2026 filing

Allen, TXAllison Park, PAAppleton, WIAtlanta, GABellevue, WABoise, IDBurnsville, MNCarmel, INCedarburg, WIChicago, ILColorado Springs, CODel Mar, CADowners Grove, ILGlendale, CAGolden Valley, MNGreenwood Village, COIrvine, CAJohnston, IALas Vegas, NVNashville, TNOverland Park, KSRaleigh, NCSpokane, WASt. Louis, MOWaukesha, WI

States registered or notice-filed

51 states or jurisdictions

AKALARAZCACOCTDCDEFLGAHIIAIDILINKSKYLAMAMDMEMIMNMOMSMTNCNDNENHNJNMNVNYOHOKORPARISCSDTNTXUTVAVTWAWIWVWY

SEC-registered investment advisers are examined by the SEC. SEC, state, and exempt registration

10 Reports 10 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Criminal matters Items 11.A and 11.B

• 11.A(1) In the past ten years, has the firm or an advisory affiliate been convicted of, or pleaded guilty or no contest to, a felony?
• 11.B(1) In the past ten years, has the firm or an advisory affiliate been convicted of, or pleaded guilty or no contest to, a misdemeanor involving investments or an investment-related business, fraud, false statements or omissions, wrongful taking of property, bribery, perjury, forgery, counterfeiting, extortion, or a conspiracy to commit any of these?

Regulatory matters Items 11.C to 11.G

• 11.C(2) Has the SEC or the CFTC ever found that the firm or an advisory affiliate was involved in a violation of SEC or CFTC regulations or statutes?
• 11.C(4) Has the SEC or the CFTC ever entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.C(5) Has the SEC or the CFTC ever imposed a civil money penalty on the firm or an advisory affiliate, or ordered the firm or an advisory affiliate to cease and desist from an activity?
• 11.D(1) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate made a false statement or omission, or was dishonest, unfair, or unethical?
• 11.D(2) Has another federal regulator, a state regulator, or a foreign financial regulator ever found that the firm or an advisory affiliate was involved in a violation of investment-related regulations or statutes?
• 11.D(4) In the past ten years, has another federal regulator, a state regulator, or a foreign financial regulator entered an order against the firm or an advisory affiliate in connection with investment-related activity?
• 11.D(5) Has another federal regulator, a state regulator, or a foreign financial regulator ever denied, suspended, or revoked the registration or license of the firm or an advisory affiliate, prevented either by order from associating with an investment-related business, or restricted either one's activity?
• 11.E(2) Has a self-regulatory organization or a commodities exchange ever found that the firm or an advisory affiliate was involved in a violation of its rules, other than a minor rule violation under a plan the SEC approved?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

Regulatory assets under management: $10,688,804,761 in the October 2021 data and $20,769,867,010 in the October 2026 data, up 94%.

Total employees: 3,610 in October 2021 and 3,901 in October 2026.

As filed in each year's data for the same month. Assets under management move with markets as well as with clients coming and going; they measure scale, not skill or returns. Most firms update these figures once a year.

1. September 2026
   • Updated its list of owners and control persons (Schedule A).
2. April 2026
   • Employees performing advisory functions went from 2774 to 2963.
   • Regulatory assets under management went from $17,499,525,490 to $20,769,867,010 (+19%).
   • Changed its office addresses in Appleton, WI.
   • Added an office in Atlanta, GA.
   • Added an office in Colorado Springs, CO.
   • Added an office in Johnston, IA.
   • Added an office in Overland Park, KS.
   • Added an office in Spokane, WA.
   • No longer lists an office in Charlotte, NC.
   • No longer lists an office in Eagan, MN.
   • No longer lists an office in Minneapolis, MN.
   • No longer lists an office in Omaha, NE.
   • No longer lists an office in Scottsdale, AZ.
3. March 2026
   • Item 11 disclosure answers changed: 10 yes answers, previously 9 (now yes: 11.B(1)).
4. December 2025
   • Item 11 disclosure answers changed: 9 yes answers, previously 10 (now no: 11.B(1)).
   • Updated its list of owners and control persons (Schedule A).

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.