PIC is a fee-based registered investment adviser with its principal place of business located in Lake Mary, Florida. We have been in business since 2001. The principal owners of PIC as of July 2022, are Peter Market Platt is the President and Chief Compliance Officer, and The Mary F. Platt Living Trust. Portfolio Management Services Our firm provides portfolio management services to clients using model asset allocation portfolios. The model portfolio is designed to meet a particular investment goal. We will manage these advisory accounts on a discretionary basis only. We offer this service to individuals, trusts, estates or charitable organizations and corporations or other business entities. Discretionary assets under our firm’s management were $113,452,831.00 as of 12/31/2022. Through extensive, personal discussions with the client in which the client's goals and objectives are established, we will determine if the model portfolio is suitable to the client's circumstances. Once the suitability of the portfolio has been determined, the portfolio will be managed based on the portfolio's goal, rather than on each client's individual needs. Even so, we will regularly communicate with clients throughout the year to discuss market conditions and portfolio strategy in order to establish that the model portfolio continues to be a suitable investment choice. Clients will have the opportunity to place reasonable restrictions on the types of investments to be held in the client's account and account supervision will be guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income). Clients will retain individual ownership of all securities. We believe that the most important decision an investor can make is how to distribute assets between stocks, bonds and reserves at any given time. Our investment approach is to maximize absolute and relative total return during a market cycle while taking prudent market risk. We attempt to take advantage of varying valuations and momentum of stocks and bonds during the cycle. The cycle is typically defined as being between four and seven years. The next decision facing

investors is how to properly allocate between different types of stocks and bonds and establish adequate diversification in each category. In our opinion, the most efficient way to cover these objectives and to have the flexibility to change asset allocation is to invest in “no load” mutual funds and exchange traded funds ("ETFs"). Therefore, our investment recommendations will typically be limited to these instruments, with some individual equity and debt securities possible only as client legacy holdings. In order to ensure that our initial determination of an appropriate portfolio continues to be suitable and that the client's account continues to be managed in a manner suitable to the client's financial circumstances, we will maintain client suitability information in the client's file. We will contact clients at least annually to determine whether there have been any changes in the client's financial situation and whether the client wishes to impose investment restrictions or modify existing restrictions. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest.