17 Capital Partners, LLC (DBA Pearl Capital Management), offers a variety of advisory services, which include financial planning and investment management services. Prior to 17 Capital Partners, LLC (dba Pearl Capital Management) rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with 17 Capital Partners, LLC (dba Pearl Capital Management) setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). 17 Capital Partners, LLC (dba Pearl Capital Management) has been registered as an investment adviser since February 2016 and is wholly owned by Jenna Biancavilla. As of December 31, 2023, 17 Capital Partners, LLC (dba Pearl Capital Management) had $184,847,473 in assets under management, $175,355,455 of which was managed on a discretionary basis and $9,492,018 of which was managed on a non-discretionary basis. While this brochure generally describes the business of 17 Capital Partners, LLC (dba Pearl Capital Management), certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on 17 Capital Partners, LLC (dba Pearl Capital Management) behalf and is subject to the Firm’s supervision or control. Financial Planning Services 17 Capital Partners, LLC (dba Pearl Capital Management) provides clients a broad range of financial planning services, which may include any or all of the following functions:
• Business Planning
• Cash Flow Forecasting
• Trust and Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Planning
• Retirement Planning
• Risk Management
• Charitable Giving
• Distribution Planning
• Tax Planning
• Manager Due Diligence In performing these services, 17 Capital Partners, LLC (dba Pearl Capital Management) is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. 17 Capital Partners, LLC (dba Pearl Capital Management) recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as mortgage loan originators, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage 17 Capital Partners, LLC (dba Pearl Capital Management) or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the financial planning recommendations made by 17 Capital Partners, LLC (dba Pearl Capital Management). Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising 17 Capital Partners, LLC (dba Pearl Capital Management)’s recommendations and/or services. Investment Management Services 17 Capital Partners, LLC (dba Pearl Capital Management) manages client investment portfolios on a discretionary basis. 17 Capital Partners, LLC (dba Pearl Capital Management) primarily allocates client assets among various mutual funds, exchange traded funds (“ETFs”), individual debt and equity securities, options and independent investment managers (“Independent Managers”) in accordance with their stated investment objectives. In addition, 17 Capital Partners, LLC (dba Pearl Capital Management) also recommends that certain eligible clients invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage 17 Capital Partners, LLC (dba Pearl Capital Management) to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, 17 Capital Partners, LLC (dba Pearl Capital Management) directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the custodian designated by the product’s provider. 17 Capital Partners, LLC (dba Pearl Capital Management) tailors its advisory services to meet the needs of its individual

clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. 17 Capital Partners, LLC (dba Pearl Capital Management) consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify 17 Capital Partners, LLC (dba Pearl Capital Management) if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if 17 Capital Partners, LLC (dba Pearl Capital Management) determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Retirement Plan Management Services 17 Capital Partners, LLC (dba Pearl Capital Management) provides retirement plan consulting services to employer-sponsored retirement plans. These services typically include assistance to plan sponsors in establishing, monitoring, and reviewing their participant-directed retirement plan. These services may also include advice regarding investment options, plan structure, and participant education depending on the needs of the plan sponsor. In the process of providing this service, 17 Capital Partners, LLC (dba Pearl Capital Management) will typically: 1. Work with the plan sponsor to establish an Investment Policy Statement (“IPS”) which summarizes the investment goals and objectives as well as the broad strategies to be employed to meet those goals and objectives. 17 Capital Partners, LLC (dba Pearl Capital Management) will monitor; 2. Monitor the performance of investments in the plan, evaluate the existing investment options, and recommend appropriate changes to investment options; and 3. Develop asset allocation models to be used by plan participants to meet their investment objectives, time horizon, risk tolerance, and financial situation. All retirement plan services shall be in compliance with applicable state and federal laws. This applies to any plans or client accounts subject to the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). 17 Capital Partners, LLC (dba Pearl Capital Management) acknowledges its fiduciary duty as described in ERISA Section 3(21) or 3(38), as applicable in accordance with the services described in the ERISA Fiduciary Investment Advisory Contract. Use of Independent Managers As mentioned above, 17 Capital Partners, LLC (dba Pearl Capital Management) selects certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this brochure, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. 17 Capital Partners, LLC (dba Pearl Capital Management) evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. 17 Capital Partners, LLC (dba Pearl Capital Management) also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. 17 Capital Partners, LLC (dba Pearl Capital Management) continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. 17 Capital Partners, LLC (dba Pearl Capital Management) seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. 17 Capital Partners, LLC (dba Pearl Capital Management) generally utilizes the following Independent Managers: Azimuth Capital Management LLC (“Azimuth”); and Aristotle Capital Management, LLC (“Aristotle”). Educational Seminars 17 Capital Partners DBA Pearl Capital Management may periodically provide educational seminars for its current and potential clients. While the content may be informed by current events and emerging financial planning related issues, these seminars will be educational in nature and will not be tailored to any individual client’s needs but rather give general information.