Prime Capital Investment Advisors, LLC (referred to as “PCIA”, “Adviser”, “Firm”, “Prime Capital Investment Advisors” or “we” throughout this document) is an investment adviser registered with the United States Securities and Exchange Commission. PCIA is a limited liability company (“LLC”) formed in May 2017 under the laws of the state of Kansas. PCIA offers investment advisory and investment management services including asset management (wrap fee management program) and allocation services, qualified retirement plan sponsor and trustee services, financial planning services, business planning services, and consulting services. PCIA has been registered as an investment adviser since June 23, 2017. Our Principal Owners Prime Capital Investment Advisors, LLC (“Firm” “PCIA”) is 100% owned by CHHSZ Holdings, LLC. CHHSZ Holdings, LLC is a limited liability company “LLC” formed in October 2019 under the laws of the state of Delaware. The major decisions of a strategic and administrative nature for the Firm are made by Scott Colangelo – Chairman, Brian Dillbeck – Chief Financial and Operations Officer (“CFO”, “COO”), Scott Duba – Chief Investment Officer (“CIO”), Tim Hakes – Vice Chairman and President, Glenn Spencer – Chief Executive Officer (“CEO”), and Anthony Woodard – Chief Risk and Compliance Officer (“CRO”, “CCO”). Client Assets Managed by Adviser The amount of clients’ assets managed by Adviser (PCIA) totaled $16,687,174,483 as of December 31, 2022 of which $7,880,967,915 was managed on a discretionary basis and $8,806,206,568 was managed on a non‐ discretionary basis. The total assets under management (“AUM”) for PCIA and all affiliates under common control with PCIA was $18,467,623,683 as of December 31, 2022. This figure includes the aforementioned amount of clients’ assets managed by PCIA. Advisory and Investment Management Services Offered Asset Management Services (“Wrap Fee Management Program”) PCIA offers asset management services to advisory clients through wrap fee management programs. In our wrap fee management programs, the fee for advisory services (including asset management) and transaction costs (including ticket charges and commissions on purchase and sales of stocks, bonds, exchange‐traded funds and options) are “wrapped” into one fee. Such Asset Management Services are considered a wrap fee program. Whenever a fee is charged for such services, we will receive all or a portion of the fee charged. Participants in our wrap fee management programs will receive a separate Wrap Fee Brochure for Asset Management Services. PCIA offers asset management services to advisory clients, which involves PCIA providing clients with continuous and ongoing supervision over their accounts. In providing asset management services, PCIA will continuously monitor a client’s account and make trades in his (her) accounts when necessary. PCIA will assist clients in determining their objective(s), investment strategy, and investment suitability, prior and subsequent to opening an Asset Management account. Through personal discussions and other means in which goals and objectives based on a client's particular circumstances are established and after the client provides PCIA with specific details concerning his or her current financial situation, investment objectives, and risk tolerance, PCIA develops a client's Investment Policy Statement “IPS” or other such investment objectives. A client’s account will be managed by PCIA based on this policy and his (her) financial situation, investment objectives and risk tolerance. Clients may impose restrictions on investing in certain securities or types of securities. Clients must contact us to notify of any changes in their investment objective(s), restriction(s), and/or financial situation. PCIA will actively monitor a client’s account and will make management recommendations and decisions regarding buying, selling, reinvesting or holding securities, cash or other investments. PCIA provides this service to individuals, trusts, estates, charitable organizations, corporations, qualified and non‐qualified retirement programs and deferred compensation programs. When making the determination of whether one of the advisory programs available through PCIA is appropriate for a client’s needs, client should bear in mind that fee‐based accounts, when compared with commission‐based accounts, often result in lower costs during periods when trading activity is heavier, such as the year an account is established. However, during periods when trading activity is lower, the fee‐based account arrangements may result in a higher annual cost for transactions. Thus, depending on a number of factors, the total cost for transactions under a fee account versus a commission account can vary significantly. Factors which affect the total cost include account size, amount of turnover, type and quantities of securities purchased or sold, commission rates and your tax situation. It should also be noted that lower fees for comparable service may be available from other sources. The exact fees and other terms will be outlined in the agreement between the client and PCIA. Clients should discuss the advantages and disadvantages of fee‐based and commission‐based accounts with their investment adviser representative (“IAR”) and clients should also read the Wrap Fee Disclosure Brochure carefully as it explains, in detail, our Asset Management Services. PCIA requires that wrap‐fee clients establish brokerage accounts with a PCIA‐approved registered broker‐dealer or qualified custodian (together “qualified custodian”), such as Fidelity, Goldman Sachs, Schwab Advisor Services or TD Ameritrade, Inc., both divisions of Charles Schwab & Co., Inc. (together "Schwab"), all registered broker‐dealers, members SIPC, to maintain custody of clients’ assets and to effect trades for their accounts participating in this Program. The qualified custodian is the custodian for accounts established through our Asset Management Services Program. The client will appoint PCIA as his (her) investment adviser of record on specified accounts. The client’s account will consist only of separate account(s) held by said qualified custodian under his (her) name. PCIA does not act as custodian and does not have direct access to client funds and securities except to have advisory fees deducted from client’s account with the client’s prior written authorization. The qualified custodian will maintain physical custody of all funds and securities of a client’s account, and client will retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) for his (her) account. PCIA provides such services subject to the limitations and restrictions imposed by the custodial platform chosen by the client. Other advisers may provide such advisory services to clients through programs, platforms, and custodians not available to PCIA. The client will authorize PCIA to have trading authorization on his (her) account and we will provide asset management services. The client will authorize either discretionary or non‐discretionary management in his (her) agreement for our Asset Management Services. If the client has authorized us to provide asset management services on a discretionary basis, we will make all decisions to buy, sell or hold securities, cash or other investments in the client’s managed account in our sole discretion without consulting with the client before making any transactions. The client must provide us with written authorization to exercise this discretionary authority, and he (she) can place reasonable restrictions and limitations on our discretionary authority. The investment recommendations and any decisions of PCIA on behalf of participants in any strategy, allocation, or portfolio offered by PCIA are subject to various market, currency, economic, political and business risks, and will not necessarily be profitable or meet the needs of the client. There are risks and loss of principal is one of those risks. The following strategies, allocations, and portfolios are available through and are pursuant to the Firm’s Wrap Fee Management Program Wealth Management Client Agreement: Core Portfolios Elements Series – Passive, index‐based strategies designed and intended for advisory accounts with an initial investment amount, or an ongoing balance, below $2,500. Genesis Series – Passive, index‐based strategies. Generations Series – Passive, index‐based strategies offering a more focused equity component across specific sub‐asset classes. Ambassador Series – Actively managed risk‐based strategies. Diversified Income Strategy Satellite Strategies Sector Rotation Strategy Focused Equity Strategy Tactical U.S. Equity Strategy Tactical International Equity Strategy Focused Yield Strategy Select Alternative Strategy – Liquid Total Stock Portfolio (Core‐Focused) Covered Calls Strategy Custom Strategies and Rep‐managed Accounts Focused Yield PLUS Strategy Alternative Investments Private Offerings (available to clients who meet the definition of an “accredited investor” as defined in Rule 501(a) of Regulation D under the Securities Act of 1933 and a "qualified client" under Advisers Act Rule 205‐3) Custom IPS Custom IPS PLUS Rep‐managed Accounts The following strategies are pursuant to the Firm’s Performance‐Based Advisory Services Agreement and is only available to natural individual clients meeting the SEC's definition of "qualified clients" under Advisers Act Rule 205‐3. Absolute Return Strategy Opportunistic Growth Strategy Further descriptions of the above programs are provided in the Firm’s Wrap Fee Brochure for Asset Management Services. Strategy availability can and does change, at the sole discretion of PCIA. Asset Management Services (using Transaction‐based Pricing Custodial Platforms) PCIA also offers asset management services to advisory clients through “transaction‐based pricing custodial platforms”. Such clients do not participate in the Firm’s aforementioned Wrap Fee Programs and therefore will also pay transaction costs (including ticket charges and commissions on purchase and sales of stocks, bonds, exchange‐traded funds and options) in addition to PCIA advisory fees. PCIA recognizes that each client has unique investment objectives, tax considerations, income and liquidity needs, and investment preferences. With that in mind, PCIA manages the investment process with each client by jointly developing or utilizing a tailored investment plan or IPS that addresses those issues. The portfolios for the client are individually invested and administered according to the client's specific plan. Clients may impose restrictions on investing in certain securities or types of securities. Such Managed Account Services are offered through platforms made available by PCIA‐approved custodians and mutual funds (including mutual fund’(s) transfer agent), and certain PCIA‐approved annuity providers (insurance companies). PCIA provides such services subject to the limitations and restrictions imposed by the custodial platform chosen by the client. Other advisers may provide such advisory services to clients through platforms and custodians not available to PCIA. The following strategies, allocations, and portfolios are currently available through and are pursuant to the Firm’s transaction‐based‐pricing Wealth Management Client Agreement: Core Portfolios Elements Series – Passive, index‐based strategies. This Series is designed and intended for advisory accounts with an initial investment amount, or an ongoing balance, below $2,500. These strategies use a mix of exchange‐traded funds (ETFs) and/or mutual funds. Genesis Series – Passive, index‐based strategies. These strategies use a mix of exchange‐traded funds (ETFs) and/or mutual funds. Generations Series – Passive, index‐based strategies offering a more focused equity component across specific sub‐asset classes. These strategies use a mix of exchange‐traded funds (ETFs) and/or mutual funds. Ambassador Series – Actively managed risk‐based strategies. These strategies use a mix of mutual funds and/or ETFs. PCIA offers two subsets of Ambassador asset allocations, Standard and Tax‐aware. Standard Ambassador asset allocations are generally recommended for qualified accounts, such as IRAs. Tax‐aware Ambassador asset allocations seek to achieve greater tax efficiency and are generally recommended for non‐qualified or “taxable” accounts. Diversified Income Strategy PCIA has developed the Diversified Income Strategy to provide clients with a tailored allocation specifically designed for the “distribution or decumulation phase” of their retirement. The strategy seeks to provide client with both access to the required current income and the opportunity to meet their long‐term financial objectives through retirement. The Diversified Income Strategy is intended for investors who need to both pay for financial goals in the near term and who seek capital appreciation in their investments yet are reluctant to risk substantial short‐term losses. The Diversified Income Strategy seeks to generate above‐average current income using a blend of mutual funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset classes. Asset classes may include dividend paying common equity, preferred stock, publicly traded Real Estate Investment Trusts “REIT”, master limited partnerships “MLP”, and various types of bonds. Total equity exposure, including REITs and MLPs but excluding preferred stock, will generally target a range of 40‐50%. Total fixed income exposure, including preferred stock and cash, will generally target a range of 50‐60%. Account supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and risk tolerance of the client. Satellite Strategies Sector Rotation Strategy The Sector Rotation strategy is a sector‐based price momentum allocation that seeks to capitalize on the continuance of existing trends in the market. The Strategy utilizes sector‐based mutual funds and models offered by Guggenheim Partners, LLC ("Guggenheim"). The underlying mutual funds are focused on the following eighteen (18) sectors as defined by Guggenheim: Banking, Basic Materials, Biotechnology, Consumer Products, Electronics, Energy, Energy Services, Financial Services, Health Care, Internet, Leisure, Precious Metals, Real Estate, Retailing, Technology, Telecommunications, Transportation, and Utilities. PCIA evaluates the aforementioned mutual funds on a quarterly basis using a Six (6)‐Month Lookback and a Three (3)‐Month Holding Period. The Strategy is reallocated quarterly as needed across the three (3) mutual funds that represent the top three (3) performing sectors as defined and determined by Guggenheim based upon the aforementioned Lookback and Holding Periods. PCIA and Guggenheim are not affiliated. Account supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and risk tolerance of the client. Tactical U.S. Equity Strategy The Tactical U.S. Equity strategy is an aggressive domestic equity strategy with a tactical, flexible mandate that seeks to identify U.S. equity market segments most likely to outperform in the short to intermediate terms using a “top‐down approach” consisting of a blend of mutual funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset classes comprises of U.S. equities. While this strategy generally utilizes a top‐down approach, it may also employ “thematic investing.” Asset classes may include dividend paying common equity, U.S. domestic equity ranging across all market capitalizations, publicly traded Real Estate Investment Trusts “REIT”, master limited partnerships “MLP”, preferred stock, and fixed income. Total U.S. equity exposure, including REITs, MLPs, and thematic investments will generally target a 99% allocation. Given the strategy’s objective to achieve capital appreciation, total fixed income, including preferred stock and cash, will generally target a 1% allocation weighting, with the ability to hold up to 25% during times of extreme volatility or rapidly declining market environments. The strategy is reviewed on a frequent basis (no less than monthly) with a shorter‐term (3‐6‐month forward looking) tactical allocation outlook perspective. Tactical International Equity Strategy The Tactical International Equity strategy is an aggressive foreign equity strategy with a tactical, flexible mandate that seeks to identify foreign equity market segments most likely to outperform in the short to intermediate terms using a “top‐down approach” consisting of a blend of mutual funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset classes comprises of non‐U.S. equities. While this strategy generally utilizes a top‐down approach, it may also employ “thematic investing.” Asset classes may include dividend paying common equity, foreign equity ranging across all market capitalizations, publicly traded Real Estate Investment Trusts “REIT”, master limited partnerships “MLP”, preferred stock, and fixed income. Total foreign equity exposure, including REITs, MLPs, and thematic investments will generally target a 99% allocation. Given the fund’s objective to achieve capital appreciation, total fixed income, including preferred stock and cash, will generally target a 1% allocation weighting, with the ability to hold up to 25% during times of extreme volatility or rapidly declining market environments. The strategy is reviewed on a frequent basis (no less than monthly) basis with a shorter‐term (3‐6‐month forward looking) tactical allocation outlook perspective. Focused Equity Strategy Focused Equity is an aggressive equity strategy with a flexible mandate that seeks to identify market segments most likely to outperform in the short to intermediate term using a “top‐down approach” consisting of a blend of mutual funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset classes. While this strategy generally utilizes a top‐down approach, it may also employ “thematic investing”. Asset classes may include dividend paying common equity, U.S. domestic equity ranging across all market capitalizations, international equity, publicly traded Real Estate Investment Trusts “REIT”, Master Limited Partnerships “MLP”, preferred stock, and fixed income. Total equity exposure, including REITs, MLPs, will generally target a 99% allocation weighting. Given the strategy’s objective to outperform the S&P 500 TR, total fixed income, including preferred stock and cash, will generally target a 1% allocation weighting, with the ability to increase to a 25% weighting during times of extreme volatility or rapidly declining market environments. This strategy is reviewed on a monthly basis and has a shorter‐term (6‐month forward looking) tactical outlook. Account supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and risk tolerance of the client. Focused Yield Strategy The Focused Yield strategy is designed to aggressively pursue a high level of current income using a blend of mutual funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset classes. Asset classes may include dividend paying common equity, U.S. domestic equity ranging across all market capitalizations, international equity, publicly traded Real Estate Investment Trusts “REIT”, Master Limited Partnerships “MLP”, preferred stock, fixed income, and alternative investments. Generally, the strategy will seek globally geographic and asset type diversification, but given the fund’s objective to produce a high level of current income with a minimum target of 6%, the strategy typically will have a larger allocation to fixed income instruments. Account supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and risk tolerance of the client. Select Alternative Strategy – Liquid The Select Alternative Strategy ‐ Liquid is designed to generate capital appreciation and capital preservation in all market conditions, with low volatility and low correlation to the U.S. domestic equity markets (reference S&P 500 Total Return “TR”). This strategy utilizes a blend of mutual funds, closed‐end funds, and exchange‐traded funds “ETF” covering a diverse group of asset classes. This strategy primarily invests in the non‐Traditional or alternative asset classes as listed below. This strategy may also invest a portion of assets in traditional fixed income. While the portfolio is reviewed periodically, in general 60% of the portfolio will remain relatively static, with either negative or very low correlation to the S&P 500 TR. The remaining 40% will be more opportunistic, focusing on a relatively short‐term market outlook of six (6) to nine (9) months. Account supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and risk tolerance of the client. Total Stock Portfolio (Core‐Focused) A Core‐Focused Total Stock Portfolio is designed to generate returns greater than the S&P 500 Total Return “TR” using a blend of stocks (common and preferred) covering a diverse group of asset classes. A Core‐Focused Total Stock Portfolio generally utilizes a “top‐down approach” and may also employ a “bottom‐up approach” and “thematic investing”. Asset classes may include common equity, U.S. domestic equity ranging across all market capitalizations, international equity, publicly traded Real Estate Investment Trusts “REIT”, Master Limited Partnerships “MLP”, and preferred stock. A Core‐Focused Total Stock Portfolio is generally reviewed on a quarterly basis and has a shorter‐term (12‐month forward looking) tactical outlook. A Core‐Focused Total Stock Portfolio is generally to be diversified or invested across a minimum of three (3) different Sectors as defined by GICS. A Core‐Focused Total Stock Portfolio is generally required to hold a minimum of fifteen (15) separate positions wherein a single position should not account for more than twelve‐percent (12%) of the overall Portfolio allocation. The “universe” of companies whose stock is available for inclusion in a Core‐Focused Total Stock Portfolio is subject to the following parameters:  Minimum of 50% from S&P 500*  Maximum of 20% from S&P Mid‐Cap 400*  Maximum of 15% from S&P Small‐Cap 600*  Maximum of 15% from MSCI EAFE* * Index references a respective iShares Exchange Traded Fund (“ETF”) as defined and determined by BlackRock, Inc. Differences in the underlying constituents/components of an actual current index as constructed by Standard & Poor’s Financial Services LLC (“S&P”) or MSCI Inc. (“MSCI”) and an iShares ETF are possible. PCIA and BlackRock, Inc. (iShares) are not affiliated. A Core‐Focused Total Stock Portfolio will generally invest in a balanced blend of “Value” stocks, “Blend/Core” stocks, and “Growth” stocks, as defined and classified by Morningstar. As such, this Strategy will generally target an overall “Value to Growth” ratio of 1:1 (+/‐ 10%) as determined by Morningstar. For purposes of this Strategy, stocks that are classified by Morningstar as “Blend/Core” will generally be considered to have a “Value to Growth” ratio of 1:1. Given the Strategy’s objective to outperform the S&P 500 TR, cash/money market will generally maintain an allocation weighting of less than 5%, with the ability to increase to a 25% weighting during times of extreme volatility or rapidly declining market environments. Account supervision is guided by the stated objectives (Investment Policy Statement “IPS”) and risk tolerance of the client. PCIA and Morningstar are not affiliated. Custom Strategies Alternative Investments From time to time, PCIA makes certain alternative investments available to clients who want to (1) have exposure to non‐correlated asset classes and/or (2) aggressively pursue growth or a high level of current income through access to non‐traditional asset classes. Alternative investments include certain open‐end and closed‐end mutual funds, interval funds, Master Limited Partnership (“MLP”) shares and non‐traded securities (i.e., Real Estate Investment Trusts “REITS” and Business Development Companies “BDC”). PCIA may recommend alternative investments as part of a custom portfolio (see below) or as a “stand‐alone” sleeve or account. Investments by a client in an alternative investment may be on a non‐discretionary basis. In these situations, clients must affirmatively subscribe for any such investment. Investors in such alternative investments must meet specific suitability and investor eligibility requirements in order to invest and specific opportunities may require higher levels of investment. PCIA recommends that investment into alternative investments and other such asset classes/types that are not readily (daily) liquid, in aggregate, encompass no more than 20% of an investor’s total investable net worth (INW). Furthermore, the alternative investment component of a custom portfolio managed by PCIA will comprise no more than 40% of the portfolio’s overall allocation, with no more than 20% allocated to a single offering. The solicitation or allocation of alternative investments across client portfolios is on a “client‐by‐client” basis and is generally not accomplished or executed on a pro rata basis as a number of factors will determine whether the alternative investment is appropriate or suitable for a client. Factors which impact the solicitation or allocation of such investments, include but are not limited to, account size, liquidity, investor qualification, and risk tolerance. Investing in alternative investments is aggressive, involves a high degree of financial risk, and therefore should always be considered a long‐term investment, many times with an indeterminate holding period and with no or very limited liquidity. Interests in non‐traded securities are generally not transferable or assignable. Any repurchase features detailed in offering documents are not a guarantee that any of your non‐traded shares will be repurchased at your request and should such repurchase take place, there likely will be an early redemption penalty. There are risks associated with alternative investments and entire loss of principal is one of those risks. PCIA believes alternative investments are generally best‐suited for investors who have either a Balanced, Growth, or an Aggressive risk profile as indicated by the Risk Tolerance Survey Questionnaire, but may be utilized in combination with less aggressive investment strategies to further increase diversification. However, investors who choose to participate in alternative investments and whom have a risk profile that differs from the recommended profile(s) listed above should understand that they will be subject to a different degree of risk exposure. Private Offerings From time to time, PCIA makes certain private offerings available to clients who (1) meet the definition of an “Accredited Investor” as such term is defined in Rule 501(a) of Regulation D under the Securities Act of 1933, (2) meet the definition of a "Qualified Client" under Investment Advisers Act of 1940 Rule 205‐3, and (3) want to aggressively pursue growth or a high level of current income through access to private markets. To be considered a qualified client, the client must have, or we must have reasonable belief that the client has, a net worth of more than $2,200,000 (excluding the client’s primary residence) at the time the investment advisory agreement is executed. Sponsors of private offerings may impose additional, more restrictive standards for eligibility. A private offering or placement is an offering of unregistered securities to a limited pool of investors. In a private offering, a company sells shares of stock in the company or other interest in the company, such as warrants, limited partnerships interests, or bonds, in exchange for cash. Hedge funds and other private funds also engage in private offerings. Such offerings are not and will not be registered under the Securities Act of 1933, state securities laws, or the securities laws of any other jurisdiction. PCIA may recommend private offerings as part of a custom portfolio (see below) or as a “stand‐alone” sleeve or account. Investments by a client in a private offering will be on a non‐discretionary basis. As a result, clients must affirmatively subscribe for any such investment. Investors in such private offerings must meet specific suitability and investor eligibility requirements in order to invest and specific opportunities may require higher levels of investment. PCIA generally recommends an investment amount of no more than 20% of total investable net worth (in aggregate) in private offerings and other such asset classes/types that are not readily (daily) liquid. Furthermore, the private offering component of a custom portfolio managed by PCIA will comprise no more than 40% of the portfolio’s overall allocation, with no more than 20% allocated to a single private offering. PCIA also generally recommends that investment into private offerings that are classified as, or primarily act as, “venture capital”, in aggregate, encompass 5%, or less, (maximum of 10% in certain circumstances) of a client’s total investable net worth, due to the higher level of inherent risk. Should client desire PCIA to manage the portion of his or her investment into a private offering (“committed capital”) that is considered “uncalled capital”, PCIA recommends that such portion remain invested into the following standard mutual fund and exchange‐traded fund allocation: 1/9 "Short‐Term" Treasury Bond Fund (i.e. remaining maturities 1 to 3 years) + 1/9 "Intermediate‐Term" Treasury Bond Fund (i.e. remaining maturities 3 to 7 years) + 1/9 "Intermediate‐Term" Treasury Bond Fund (i.e. remaining maturities 7 to 10 years) + 6/9 “2/3” into the Firm’s Genesis Conservative, Genesis Balanced, or Genesis Aggressive allocation. Clients also have the option to manage or self‐direct their uncalled capital. Please note that investing uncalled capital into a separate allocation that involves asset types other than money market funds, adds additional layers of risk, including loss of principal, and that any such loss will require client to commit additional assets or monies in order to fulfill his or her private offering obligations and commitments. The solicitation or allocation of these offerings across qualified client portfolios is on a “client‐by‐client” basis and is generally not accomplished or executed on a pro rata basis as a number of factors will determine whether the private offering is appropriate or suitable for a client. Factors which impact the solicitation or allocation of such offerings, include but are not limited to, account size, liquidity, investor qualification, and risk tolerance. Please see the section below titled “Additional Compensation, Economic and Non‐ Economic Benefits” under Item 4 of this Brochure for a description of our conflict(s) of interest associated with certain Private Offerings. Investing in private offerings is speculative, involves a high degree of financial risk, and therefore should always be considered a long‐term investment, with an indeterminate holding period and with no or very limited liquidity. Interests in such offerings are generally not transferable or assignable. Any repurchase features detailed in an offering memorandum are not a guarantee that any of your private offering shares will be repurchased at your request and should such repurchase take place, there likely will be an early redemption penalty. There are risks associated with private offerings and entire loss of principal is one of those risks. PCIA believes private offerings are generally best‐suited for investors who have either a Growth or an Aggressive risk profile as indicated by the Risk Tolerance Survey Questionnaire, but may be utilized in combination with less aggressive investment strategies to further increase diversification. However, investors who choose to participate in private offerings and whom have a risk profile that differs from the recommended profile(s) listed above should understand that they will be subject to a different degree of risk exposure. Custom IPS, Custom IPS PLUS, and Rep‐managed Accounts Portfolio Corridors Most portfolios by nature have a basic “Equity to Fixed Income” composition. “Equity” asset types generally include stocks and equity‐based mutual funds or exchange‐traded funds “ETF”. “Fixed Income” asset types generally include bonds, bond mutual funds or exchange‐traded funds/notes “ETF”/ “ETN”, and cash equivalents, such as money market instruments. Therefore, your PCIA Custom IPS, Custom IPS PLUS, or Rep‐ managed Account portfolio will generally adhere to one of the following Portfolio Corridors and their corresponding base “Equity to Fixed Income” guidelines. Conservative (1) Conservative portfolios will adhere to a base 25/75 “Equity to Fixed Income” guideline with a tolerance of (+/‐ 10). Moderately Conservative (2) Moderately Conservative portfolios will adhere to a base 40/60 “Equity to Fixed Income” guideline with a tolerance of (+/‐ 10). Balanced (3) Balanced portfolios will adhere to a base 60/40 “Equity to Fixed Income” guideline with a tolerance of (+/‐ 10). Growth (4) Growth portfolios will adhere to a base 75/25 “Equity to Fixed Income” guideline with a tolerance of (+/‐ 10). Aggressive (5) Aggressive portfolios will adhere to a base 90/10 “Equity to Fixed Income” guideline with a tolerance of (+/‐ 10). As a reminder, the private offering or alternative investment component of a custom portfolio managed by PCIA will generally comprise no more than 40% of the portfolio’s overall allocation, with no more than 20% allocated to a single private offering or alternative investment. Rep‐managed Accounts Your PCIA rep‐advisor provides discretionary asset management services to your advisory account(s) and asset(s), including solely selecting and trading the specific securities that make up your investment allocation(s) or portfolio(s). Note: Core Portfolios and Satellite Strategies are only available on or through a brokerage custodian. Such items cannot be used with annuities or direct‐held mutual funds. Strategy availability can and does change, at the sole discretion of PCIA. Asset Management Services (Discretionary) through Pontera (formerly FeeX) Certain client accounts receiving PCIA’s asset management services through transaction‐based pricing custodial platforms may be held at a custodian that is not directly accessible to our firm (“Held Away Accounts”). We can manage these Held Away Accounts using a third‐party platform called Pontera Order Management System (“Pontera”) (formerly FeeX). Specifically, PCIA uses Pontera to implement ongoing tax‐efficient asset allocation and opportunistic

rebalancing strategies for held away assets such as defined contribution plan participant accounts (e.g., 401(k) accounts) and HSAs, with discretion. All clients engaging in Asset Management Services for Held Away Assets must either engage in Comprehensive Financial Planning with discretionary investment (asset) management (as described in this Brochure) or meet a $100,000 minimum of assets under management. Pontera allows PCIA to avoid being considered to have custody of Client funds since we do not have direct access to Client log‐in credentials to affect trades or withdraw funds. We are not affiliated with Pontera in any way and receive no compensation from Pontera for using its platform. A link will be provided to clients allowing them to connect their account(s) to the platform. Once client account(s) are connected to the platform, PCIA will review the current account allocations. When deemed necessary, our firm will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. No guarantees expressed or implied. Managed Account Allocations for Plan Participants PCIA also offers its discretionary investment advisory services to 401(k), 403(b), Employee Stock Ownership Plans (ESOP), profit sharing, defined benefit pension and deferred compensation plans and their participants. These services are currently offered through platforms made available by firms that include, but are not limited to Ascensus, Empower Retirement, Fidelity, Newport Group, OneAmerica, Principal Financial, Prudential, TIAA‐CREF, Transamerica Retirement Solutions, and through other Plan administrator firms, custodians, and record keepers that clear through Fidelity, Matrix Financial Solutions, Inc., Mid Atlantic Trust Company, Reliance Trust Company, Schwab, State Street, and Wilmington Trust. In some instances, PCIA will work with a designated subadvisor or co‐fiduciary to provide these services. PCIA provides such qualified retirement plan services subject to the limitations and restrictions imposed by the applicable platform chosen by the client. Other advisers may provide such advisory services to retirement plans through platforms and custodians not available to PCIA. By electing these investment advisory services, Plan(s) and Plan participants are offered either risk based managed account allocations (Conservative Income/Conservative, Income/Moderately Conservative, Conservative Growth/Balanced, Growth and Aggressive/Aggressive Growth) or goals‐based managed account allocations. Goals‐based managed account allocations are based primarily on a plan participant's years until retirement and desired retirement income, but can be further personalized based on a plan participant's individual circumstances. These allocations are comprised of investment options made available through and custodied by the applicable platform provider. As part of its Qualified Plan Investment Advisory recommendations, PCIA may from time‐to‐time cover expenses incurred by Qualified Plan participants as part of any investment option change, transfer or rebalance which triggers a charge, adjustment or fee to the participant. The facts and circumstances of any type of expense coverage by PCIA will be fully disclosed to the applicable Qualified Plan Sponsor and Qualified Plan participant(s) prior to payment by PCIA and crediting to the respective participant account. Qualified Retirement Plan Sponsor and Trustee Services PCIA, doing business as, Qualified Plan Advisors (“QPA”), also offers Qualified Retirement Plan services to Plan Sponsors and/or Plan Trustees. These services include design, implementation, monitoring and reporting of a Plan's Investment Policy Statement; analysis, monitoring and reporting of investment options made available to Plan participants; ERISA Section 3(38) investment manager services; Pension consulting; Plan design consulting; Form 5500 review; Plan trustee fiduciary communication and training; Plan benchmarking reporting; Plan Participant enrollments and education; Plan Health; a stream‐lined ERISA Section 3(38) plan‐level fiduciary service engagement named Fiduciary Complete. Such services do not constitute accounting or legal advice. PCIA does not custody plan assets and is not a recordkeeper or third‐party administrator. PCIA provides qualified retirement plan advisory, plan sponsor and trustee services subject to the limitations and restrictions imposed by the applicable platform chosen by the client. Other advisers may provide such advisory services to retirement plans through platforms and custodians not available to PCIA. Collective Investment Funds Services A collective investment fund also known as a collective investment trust is a bank‐maintained fund that is exempt from registration as a mutual fund under the Investment Company Act of 1940 and only available to qualified retirement plans. PCIA offers investment advisory services by serving as an investment adviser to the Fiduciary Investment Trust (including Core Series) funds (also referred to as the Funds throughout this brochure). The Funds are organized as collective investment trusts. Comerica Bank & Trust, National Association (“Comerica”) serves as the Funds’ trustee and administrator, hires and fires the investment adviser of the Funds and selects the qualified custodian. Comerica has established accounts for the Funds at its bank, which serves as the qualified custodian. UMB Fund Services provides the Funds with fund administration and accounting, omnibus transfer agency and sales support. As investment adviser PCIA provides investment advice and management services to the Funds. The Funds are available only to retirement plans as an investment option: Aggressive; Growth; Balanced; Moderately Conservative; Conservative; and Core Series: Large Cap; Mid Cap; Small Cap; International Equity; Bond; Opportunistic Global Yield. Some retirement plans investing in the Funds could also be clients of PCIA. Where such a plan is otherwise a client of PCIA, PCIA may perform Fiduciary Consulting Services, except for selecting, monitoring or recommending any Funds, in which case it will receive a fee for such plan‐ level service. The plan sponsor is responsible for selecting and monitoring Funds. The investment management fee paid by the Funds to PCIA may be at a rate that is higher than the fee PCIA typically receives from the plan for the plan‐level Fiduciary Consulting Services. Please refer to Item 5 of this Brochure for a description of our fees. Increases in Funds assets will result in increases in total management fees paid to PCIA. In recognition of that incentive and to avoid any potential conflict of interest, any retirement plan utilizing PCIA’s Fiduciary Consulting Services will need to make its own independent investigation and evaluation of the Funds. The Funds currently compose the sole collective investment fund client advised by PCIA. PCIA maintains limited power of attorney to act on a discretionary basis when managing the investments of the Funds. PCIA is responsible for investment selection, asset allocation, and asset management decisions regarding the Funds. PCIA does not have authority to disburse assets or securities from the Funds. Financial Planning Services PCIA also offers financial planning services for individuals, families, estates, and businesses including investment advice. An agreement is executed by the client and PCIA outlining the terms and fees associated with developing a client's financial plan. The purpose of this service is solely to create a financial plan for the client. The planning process focuses on such areas as developing a comprehensive financial plan, portfolio evaluation, cash flow analysis, education planning, retirement account investment analysis, retirement planning, tax projections and planning, risk management, including a review of insurance coverage (which will exclude property and casualty insurance), estate analysis and planning, planning for special needs family members, negotiation of the purchase of substantial assets, and budgeting. This service may or may not grant discretionary power to PCIA or IAR. Fees for financial planning services may be charged when assets are not under management of PCIA and depend on the nature and complexity of the client's circumstances and needs. Clients may also elect to receive certain financial planning services on a monthly subscription basis. The exact fees and other terms (including discretion) will be outlined in the agreement between you and PCIA. A client’s IAR may be a Registered Representative of Private Client Services (“Broker‐Dealer”), which is a Broker‐Dealer registered with the Securities Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority (“FINRA”). PCIA and Private Client Services are not affiliated. A client’s IAR as a Registered Representative is capable of effecting on the client’s behalf transactions in various securities products, including stocks, bonds, mutual funds, variable annuities, and variable life insurance. However, a client is always free to execute securities transactions and purchase insurance products through someone other than his or her PCIA IAR. If a client chooses to purchase securities products through his or her PCIA IAR in the capacity as a Registered Representative, then all such transactions will be placed through Private Client Services. Broker‐Dealers are required to supervise the securities trading of their representatives. In this event, Private Client Services and Client’s Registered Representative will receive compensation, including commissions and possible 12b‐1 fees normally paid in connection with the sale of securities products. If a client elects to purchase insurance products through his or her PCIA IAR, IAR will receive commissions normally paid in connection with these products in a separate capacity as a licensed insurance agent. The aforementioned compensation will be in addition to the fees a client will pay for “Financial Planning Services”. Please see Item 14 of this Brochure for more information about the conflicts of interest associated with this arrangement. PCIA provides the following types of financial planning services: Custom Financial Planning Services Available Financial Planning Services  Retirement Planning  College/Education Saving  Major Purchases  Budget/Cash‐flow Analysis  Investment Management  Tax Planning, Projection  Risk/Insurance Analysis  Estate Review & Analysis  Caring for parents / special needs planning  Charitable Giving  Business valuations and buy/sell planning (for business owners) Special Notice regarding Estate Planning and Tax Planning Services Since PCIA does not practice law or accountancy, this work will generally be done in coordination with lawyers and accountants separately selected and employed by the client. Business Planning Services and Consulting Services Business planning services include working with a client's legal and accounting professionals to gather and analyze the client's current circumstances, to help define the client's cash flow management, company financing, business valuation, succession planning, qualified corporate risk management and choice of entity. Consulting services provided by PCIA include but are not limited to monitoring and performance reporting, investment manager review and selection, documentation review and analysis of general financial markets, public security markets and sector industries, and financial education and/or coaching. In addition, consulting services could include review and analysis of qualified and non‐qualified retirement program design, operations, fee and/or expense structure and investment options. Since PCIA does not practice law or accountancy, this work will generally be done in coordination with lawyers and accountants separately selected and employed by the client. These services may or may not grant discretionary power to PCIA or IAR. Fees for business planning services or consulting services may be charged when assets are not under management of PCIA and depend on the nature and complexity of the client's circumstances and needs. The exact fees and other terms (including discretion) will be outlined in the agreement between you and PCIA. A client’s IAR may be a Registered Representative of Private Client Services (“Broker‐Dealer”), which is a Broker‐Dealer registered with the Securities Exchange Commission (“SEC”) and a member of the Financial Industry Regulatory Authority (“FINRA”). PCIA and Private Client Services are not affiliated. A client’s IAR as a Registered Representative is capable of effecting on the client’s behalf transactions in various securities products, including stocks, bonds, mutual funds, variable annuities, and variable life insurance. However, a client is always free to execute securities transactions and purchase insurance products through someone other than his or her PCIA IAR. If a client chooses to purchase securities products through his or her PCIA IAR in the capacity as a Registered Representative, then all such transactions will be placed through Private Client Services. Broker‐Dealers are required to supervise the securities trading of their representatives. In this event, Private Client Services and Client’s Registered Representative will receive compensation, including commissions and possible 12b‐1 fees normally paid in connection with the sale of securities products. If a client elects to purchase insurance products through his or her PCIA IAR, IAR will receive commissions normally paid in connection with these products in a separate capacity as a licensed insurance agent. The aforementioned compensation will be in addition to the fees a client will pay for “Business Planning Services” or “Consulting Services”. Please see Item 14 of this Brochure for more information about the conflicts of interest associated with this arrangement. Consulting services to an Exchange Traded Fund (ETF) PCIA established and maintains a consulting arrangement with the sponsor company of, and related advisory firm for, B.A.D. ETF (“Fund Sponsor”). Certain PCIA employees and representatives, including members of PCIA’s ownership and leadership, also acquired and maintain an ownership stake in the Fund Sponsor. Please see Item 14 of this Brochure for more information about the conflicts of interest associated with this arrangement. Seminar(s) for Fee(s) Please note that this section refers to educational seminars for individuals and does not refer to retirement plan sponsor/participant education. The intent of an educational seminar is to provide the attendee with various educational topics that are general in nature. The educational seminar will be impersonal and not take into account the individual circumstances of the attendee. As such, the educational seminar should not be considered a comprehensive review, analysis or customized advice in regards to the attendee’s individual situation. The educational seminar is not a substitute for or the same as a consultation with an investment adviser in a one‐on‐one context whereby all the facts of the attendee’s situation can be considered in their entirety and the investment adviser can provide individualized investment advice or a customized financial plan. It is important the attendee understands that the services of PCIA under this type of agreement do not include any financial planning, investment management, or supervision with respect to the attendee’s assets. In the event that attendee desires such financial planning, investment management, or supervision services, attendee will be required to execute a separate agreement and pay fees in addition to the fees paid by attendee to PCIA for a seminar. PCIA requires a written Seminar Attendee Agreement to be completed for each seminar attendee before a seminar fee may be charged. This agreement is intended to be used for public seminars and not for client events. Again, public seminars are those seminars that are educational in nature and provided to the general public. Conversely, a Seminar Attendee Agreement is not required when a seminar fee is not being charged. Third‐Party Asset Management Services PCIA engages in the selection of third‐party money managers. Specifically, the Firm generally offers clients access to professional third‐party money managers (“TPMM”) by means of “turnkey asset management programs”, or TAMPs. A TAMP is a program sponsored by a third‐party that provides a wide range of services for a program fee. Services vary depending on the program and may include one or more of the following:  Asset allocation models  Money manager due diligence  Market and manager analysis  Client proposals and risk tolerance tools  Account administration  Performance reporting  Training and education support Under such programs, we assist you with identifying your risk tolerance and investment objectives. Clients who participate in a TAMP typically will complete a program questionnaire that helps to identify their investment needs and tolerance for risk. Based on the responses to the questionnaire, client assets will be invested in a portfolio of securities that is designed to meet their investment objectives. Clients who wish to participate in a TAMP or use a TPMM will receive additional material about it that is prepared by the sponsor of the TAMP (“TAMP Sponsor”) or TPMM. The additional material must be reviewed by a client before a TAMP or TPMM account can be opened. You must enter into an agreement directly with the TAMP Sponsor or TPMM who provides your designated account with asset management services. In general, sponsors of TAMP programs and TPMMs are given the authority to place trades on behalf of clients, a practice known as “discretion.” But some programs permit clients to impose reasonable restrictions on the management of their accounts. For example, the client may be able to specify that the client’s assets not be invested in certain types of securities, such as securities issued by tobacco companies. The TAMP Sponsor or the TPMM determines the reasonableness of the restrictions. TAMP Sponsors and TPMMs are responsible for continuously monitoring client accounts and making trades in client accounts when necessary. Some TAMP Sponsors and TPMMs will not open an account unless a specified minimum amount of money will be invested, but they usually reserve the right to waive the requirement, and often do so. The Firm’s involvement in third‐party asset management services is generally limited to acting as either a (1) “promoter” (formerly solicitor) or (2) “co‐advisor” for third‐party program sponsors. The Firm’s obligations will vary to some extent depending on the nature of its role, and also will vary from one TAMP to another or from one TPMM to another. When the Firm acts as a promoter, it refers clients to unaffiliated investment advisers who are TAMP Sponsors or TPMMs that offer asset management and other investment advisory services or sponsor so‐called wrap fee programs. As a result of the referral, we are paid a portion of the fee charged and collected by the TAMP Sponsor or TPMM in the form of promoter fees. Each solicitation arrangement is performed pursuant to a written agreement and is in compliance with SEC Rule 206(4)‐1 and applicable state securities rules and regulations. Clients referred by the Firm enter into an investment advisory agreement directly with the TAMP Sponsor or TPMM, which typically may be terminated by either party upon written notice. PCIA is not a party to this agreement and does not have investment management responsibility for the provision of TAMP or TPMM services. Rather, the Firm’s role is limited to referring clients to the TAMP or TPMM and performing limited advisory services, assisting with certain administrative functions, and acting as a liaison between the client and the TAMP Sponsor or TPMM. Again, we do not have any trading authority with respect to your designated account managed by the TAMP Sponsor or TPMM. The Firm’s rep‐advisor will provide the client with a copy of the TAMP Sponsor’s or TPMM’s brochure describing the program, as well as appropriate disclosure, including with regards to compensation and conflicts of interest, as applicable. The TAMP Sponsor’s or TPMM’s brochure and investment advisory agreement should describe its responsibilities and PCIA’s responsibilities, and should be reviewed carefully before investing in the program. Under a typical co‐advisory arrangement, the joint client “client” enters into an agreement with both the Firm and the TAMP Sponsor or TPMM, which may be terminated by any party upon written notice. PCIA’s rep‐advisor performs non‐discretionary advisory tasks in addition to the ministerial or other tasks provided in some referral or promoter arrangements, including assisting the client with determining the appropriate asset allocation model, reviewing the client’s account activity, and reviewing the account with the client at least annually to identify any changes in the client’s information, financial situation, investment objectives or restrictions placed on the account. Under a co‐ advisory arrangement, PCIA and its rep‐advisors are responsible for recommending TAMP or TPMM model allocations to clients and for determining if such recommendations are suitable for and in the best interest of clients. To the extent the client is a “Retirement Client”, PCIA acknowledges that it is a “fiduciary” (as defined by Employee Retirement Income Security Act of 1974 (“ERISA”) with respect to such Account, Securities, or other Investment Property that are subject to ERISA. As a result of the co‐ advisory arrangement, we are paid a portion of the fee charged and collected by the TAMP Sponsor or TPMM in the form of advisory fees. For all clients with TAMP or TPMM accounts, the Firm’s rep‐advisors will, at least once per year, contact the client to review and update the client’s investment objectives and account restrictions, investment programs or asset allocation models based on changes in the client’s goals, objectives and/or financial situation. For more information about such programs, the fees applicable to them, and other matters of interest, please review Item 5 of this Brochure and the investment advisory or wrap program disclosure document of the relevant program sponsor, which will be provided to you before an account is opened. AssetMark, Inc. PCIA, as a Promoter, may offer advisory services to Clients by selecting the AssetMark Platform. For more information regarding the AssetMark Platform, refer to AssetMark Platform Disclosure Brochure. The minimum investment required on the AssetMark Platform depends upon the Investment Solution chosen for a Client’s account and is generally $10,000] for Mutual Fund and $25,000 for ETF Accounts, and from $25,000 to $1,000,000 for Privately Managed and Unified Managed Accounts, depending on the investment strategy selected for the account. These minimums are described in more detail in the Fees & Minimums Page in the AssetMark Platform Disclosure Brochure. Accounts below the stated minimums may be accepted on an individual basis at the discretion of AssetMark. Although we review the performance of numerous third‐party investment adviser firms, we enter into only a select number of relationships with third‐party investment adviser firms that have agreed to pay us a portion of the overall fee charged to our clients. Therefore, PCIA has a conflict of interest in that it will only recommend third‐party investment advisors that will agree to compensate us for referrals of our clients. Clients are advised that there may be other third‐party managed programs not recommended by our firm, that are suitable for the client and that may be more or less costly than arrangements recommended by our firm. No guarantees can be made that a client’s financial goals or objectives will be achieved by a third‐party investment adviser recommended by our firm. Further, no guarantees of performance can ever be offered by our firm (Please refer to Item 8 of this Brochure for more details.) Investment Advisory Services for Sub‐Advisory Relationships PCIA may appoint a sub‐advisor to manage the assets of a client’s advisory account(s) on a discretionary basis. After review of the information provided regarding a client’s account(s), the appointed sub‐advisor may accept or reject its appointment by PCIA to provide investment advisory (sub‐advisory) services to the client. Upon acceptance of its appointment by PCIA, the sub‐advisor will agree to manage the client’s account(s) with discretion and to invest all securities and cash that a client may deposit into his or her account(s) without prior consultation with PCIA, subject only to the investment objectives and restrictions imposed by written notice to sub‐advisor by PCIA. A client’s PCIA rep‐advisor will assist the client with identifying his or her risk tolerance and investment objectives. PCIA’s and its rep‐advisor(s)’ recommendation to have a sub‐advisor manage a client’s account is based on the client’s financial situation, level of financial sophistication, investment experience, and financial goals, and PCIA’s and its rep‐advisor(s)’ reasonable due diligence of such items and of the sub‐advisor. A PCIA rep‐advisor is also responsible for reviewing a client’s applicable account activity, and for reviewing the client’s account(s) with the client, at least annually, to identify any changes in the client’s information, financial situation, investment objectives or restrictions placed on the account, and for communicating such changes to the sub‐advisor. PCIA may exercise its fiduciary duties as required or requested by a client regarding participation in the accounts managed by a sub‐advisor and the strategy chosen by the client. PCIA also retains the right to terminate the aforementioned sub‐advisory relationship at its sole discretion, as PCIA deems prudent. PCIA and a client’s PCIA rep‐advisor are also responsible for tracking and managing a client’s cash held in his or her account(s), including deposits, contributions, withdrawals, and distributions, and for communicating such requests to the sub‐advisor. Other Services Limited Advisory Services (also called Limited Scope Advisory Services) The PCIA Limited Advisory Services or Limited Scope Advisory Services Program is a wrap fee program. Neither PCIA nor any person associated with PCIA shall provide continuous ongoing supervision and management for your account. PCIA will not monitor specific securities or general portfolios within your account. You have the exclusive responsibility for the making investment decisions and monitoring of all securities that are held in or purchased or sold for your account. Participants in this wrap fee program will receive a separate Wrap Fee Brochure for Limited Advisory Services. PCIA will not make any investment recommendations for your account except PCIA may provide investment recommendation for your account in response to a specific request made by you. You understand that it will be incumbent upon you to make such request, and PCIA may decline, at its discretion, to provide any recommendation for your account. The Account receiving Limited Advisory Services is expressly excluded from receiving other advisory services of PCIA, unless otherwise agreed to in writing by you and PCIA. Further description of the above program is provided in the Firm’s Wrap Fee Brochure for Limited Advisory Services. Momentum PCIA, doing business as, Qualified Plan Advisors (“QPA”), together with Empower Retirement, offers Momentum, a service program designed for small to mid‐sized retirement plans. QPA and Empower Retirement are not affiliated. QPA does not custody plan assets and is not a recordkeeper or third‐party administrator. As an ERISA 3(38) Investment Manager, QPA’s services provided in connection with Momentum include Investment Selection, Plan Design, and Fund Monitoring and Oversight. QPA also provides Employee Education. Please see Item 4 Qualified Retirement Plan Sponsor and Trustee Services and Item 5 Qualified Retirement Plan Investment Advisory, Plan Sponsor and/or Trustee Services Fees for more information about QPA’s retirement plan services. Prime Clarity and tenclient PCIA offers Prime Clarity and tenclient. Both are enhanced service programs provided by a team of rep‐ advisors at no additional cost to applicable high net‐worth individuals and companies who qualify for more intensive and specialized services. Managed Account Services (for legacy Advisory clients) Special notice regarding former advisory clients of Longer Investments, Inc. PCIA acquired the assets of Longer Investments, Inc. (“LII”), a federally registered adviser. Former advisory clients of LII who become clients of PCIA (i.e., legacy Advisory clients) may have advisory accounts that continue to be subject to prior contract terms, custodial arrangements, and fee structures in order to facilitate continuity in both service and investment management. Such terms, arrangements, and fee structures are not otherwise available to other clients of PCIA. These accounts will continue to utilize “transaction‐based pricing” and will not participate in the Firm’s aforementioned Wrap Fee Programs. Instead, PCIA offers investment planning and discretionary asset management (“Managed Account Services”) to such clients. PCIA recognizes that each client has unique investment objectives, tax considerations, income and liquidity needs, and investment preferences. With that in mind, PCIA manages the investment process with each client by jointly developing or utilizing a tailored investment plan or IPS that addresses those issues. The portfolios for the client are individually invested and administered according to the client's specific plan. Clients may impose restrictions on investing in certain securities or types of securities. Such Managed Account Services are offered through platforms made available by Schwab and Northern Trust Corporation. Special notice regarding former advisory clients of Sphere, LLC. PCIA recently acquired the assets of Sphere, LLC. (“Sphere”), a state registered adviser. Former advisory clients of Sphere who become clients of PCIA (i.e., legacy Advisory clients) may have advisory accounts that continue to be subject to prior contract terms, custodial arrangements, and fee structures in order to facilitate continuity in both service and investment management. Such terms, arrangements, and fee structures are not otherwise available to other clients of PCIA. These accounts will continue to utilize “transaction‐based pricing” and will not participate in the Firm’s aforementioned Wrap Fee Programs. Instead, PCIA offers investment planning and discretionary asset management (“Managed Account Services”) to such clients. PCIA recognizes that each client has unique investment objectives, tax considerations, income and liquidity needs, and investment preferences. With that in mind, PCIA manages the investment process with each client by jointly developing or utilizing a tailored investment plan or IPS that addresses those issues. The portfolios for the client are individually invested and administered according to the client's specific plan. Clients may impose restrictions on investing in certain securities or types of securities. Such Managed Account Services are offered through platforms made available by Schwab and TD Ameritrade. Advisory Services for Non‐Discretionary Assets The scope of such services is limited to making investment recommendations with respect to the assets, providing regular and periodic (no less than annual) supervision of the assets, implementing trades at the client’s direction, and to otherwise perform as described in PCIA’s disclosure documents and in the client’s specific agreement with PCIA. Limits Its Advice to Certain Types of Investments PCIA may provide investment advice on the following types of investments:  Certificates of deposit  Closed‐end fund shares  Collective Investment Trusts (“CIT”s)  Corporate debt securities (other than commercial paper)  Direct Participation Programs (“DPP”s)  Exchange‐listed securities  Exchange‐traded fund shares or units (“ETF”s)  Exchange‐traded notes (“ETN”s)  Foreign issues  Interests in Partnerships  Interval fund shares  Master Limited Partnerships (“MLP”s)  Municipal securities  Mutual fund shares (including money market mutual funds)  Open‐end fund shares  Options contracts on securities  Private Offerings or Placements  Real Estate Investment Trusts (“REIT”s)  Securities traded over‐the‐counter  Separate account shares  Stable value products (including guaranteed income funds)  Structured products (including structured notes)  Unit Investment Trusts (“UIT”s)  United States government securities  Variable annuities  Variable life insurance Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. Advisory Services Tailored to Individual Needs of Clients PCIA’s advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one‐on‐one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. For plan participants whose accounts are serviced under the Managed Account Allocation Program, the accounts are managed according to the selected strategy (Conservative Income, Income, Conservative Growth, Growth, and Aggressive/Aggressive Growth), or the strategy assigned by the goals‐based managed account methodology, and the restrictions PCIA can reasonably accommodate are more limited. For Qualified Retirement Plan Sponsor and Trustee Services, Financial Planning Services, Business Planning Services, and Consulting Services, the services are generally delivered upon client engagement for such services. For these services, issues may be prioritized and addressed all at one time, for example, with delivery of a financial plan, or alternatively, the services can be delivered over a specified duration of time, for example, if periodic monitoring is included in the services provided to a qualified retirement plan. For advisory service programs that are not of a limited duration, clients will have a scheduled conference with their investment adviser representative at least annually to review any changes to the client’s goals and objectives and for clients in the Asset Management Services Program, the Investment Policy Statement.