Pinnacle was formed as a Washington limited liability company on December 17, 2018. The owners of Pinnacle are Leo Backer and Jeff Feinstein. The Adviser’s principal place of business is in Seattle, Washington. Pinnacle was established by real estate professionals, entrepreneurs and finance experts to invest in qualified equity investments in census tracts that have been designated as Qualified Opportunity Zones (“QOZs”) as defined by Tax Cuts and Jobs Act of 2017 through the Pinnacle Funds (as defined below). Although Pinnacle managed real estate holdings since inception, Pinnacle has determined that the flexibility to invest in securities was preferable for future offerings and, potentially, past offerings. In light of that change, Pinnacle registered with the SEC as an investment adviser in the fourth quarter of 2023. Nature of Advisory Services. Pinnacle’s investment advice has historically focused on real estate holdings rather than traditional securities investments, and going forward, may come to focus on securities investments. As an investment adviser with respect to securities, Pinnacle identifies investment opportunities and participates in the acquisition, origination, management, monitoring and disposition of investments on a discretionary basis to private pooled investment vehicles, with a primary focus on real estate-related securities as well as direct holdings of real estate (each, a “Pinnacle Fund” and collectively, the “Pinnacle Funds”). The Pinnacle Funds are intended for eligible investors (each, an “Investor” and collectively, the “Investors”). These Investors must meet certain minimum financial requirements, among other requirements, to be eligible to participate in the Pinnacle Funds, which are structured as private pooled vehicles that are not required to register as investment companies under the Investment Company Act of 1940, as amended (the “Investment Company Act”). Pinnacle considers some but not all of the Pinnacle Funds to be “private funds” as defined by the SEC, generally in reliance on Section 3(c)(1) of the Investment Company Act, and others as falling outside of the definition of “private funds,” generally in reliance on Section 3(c)(5)(C) of the Investment Company Act, or otherwise excluded from the Investment Company Act’s definition of “investment company.” Pinnacle and its affiliates (each a “Pinnacle Affiliate”) generally provide their investment management and operational services to the Pinnacle Funds pursuant to a limited liability company operating agreement and/or a limited partnership agreement with the applicable Pinnacle Fund’s members or partners (each an “LLC Operating Agreement” or “LP Agreement”). Each LLC Operating Agreement or LP Agreement sets forth the terms of the investment advisory services Pinnacle or its affiliates provides to the Pinnacle Funds, including specific investment guidelines. Investment guidelines for each Pinnacle Fund, if any, are generally established in such Pinnacle Fund’s organizational or offering documents, operating agreements, private placement memoranda and/or side letter agreements (together, the “Offering Documents”) negotiated with its Investors. Pinnacle provides investment advice directly to the Pinnacle Funds, and not individually to the Investors in the Pinnacle

Funds. As described more fully in Item 11 below, Pinnacle and its related entities may enter into side letter agreements with certain Investors in the Pinnacle Funds providing such investors with customized terms, which often results in preferential treatment. Each prospective Investor is required to complete a subscription agreement and provide information and representations and warranties that certify that the Investor is eligible to invest in the applicable Pinnacle Fund. Pinnacle—through the Pinnacle Affiliates or Pinnacle itself—is the named investment manager of the Pinnacle Funds. Pinnacle—or one of the Pinnacle Affiliates—serves as the general partner, manager or managing member of each Pinnacle Fund (each such entity, a “General Partner”). Pinnacle Affiliates are subject to Pinnacle regulatory oversight, including, without limitation, Pinnacle’s compliance policies and procedures. As used in this Brochure, the term “Clients” refers to the Pinnacle Funds; in each case, except where the context otherwise requires. Pinnacle is paid certain fees and performance-based compensation for its advisory services by the Pinnacle Funds, as further described in Item 5 below (“Fees and Compensation”). Pinnacle does not participate in wrap fee programs. Investment Strategies and Types of Investments A QOZ, defined under Section 1400Z‐1 of the Internal Revenue Code of 1986 (the “Code”), and added by the Tax Cuts and Jobs Act of 2017 (“TCJA”), is an economically distressed community where new investments, under certain conditions, may be eligible for preferential tax treatment. Localities qualify as QOZs if they (i) have been nominated for that designation by a state, the District of Columbia, or a U.S. territory and (ii) that nomination has been certified by the Secretary of the U.S. Department of the Treasury via their delegation of authority to the Internal Revenue Service (“IRS”). QOZs were established by the TCJA in order to facilitate investments by private investors into low- and middle-income (“LMI”) neighborhoods. These investments must be made by Qualified Opportunity Zone Funds (“OZ Funds”), as defined in Section 1400Z‐2(d)(1) of the Code. OZ Funds enable a broad array of investors to pool their resources to increase economic activity and improve physical property within QOZs while seeking to generate return on their capital. The investment strategy of the Pinnacle Funds generally is to invest in selected ground‐up and adaptive reuse projects in QOZs that offer attractive risk‐adjusted returns in what Pinnacle considers to be growth markets throughout the United States. Pinnacle created the Pinnacle Funds to invest in QOZs seeking to generate risk- adjusted returns on a longer time horizon for certain qualified U.S. investors. It is expected that the majority of investments held by the Pinnacle Funds will consist of real property projects held by the Pinnacle Funds either directly through single purpose vehicles or through co-investment or joint venture entities with operating partners and other investors (who may be OZ Funds) and that each of the Pinnacle Funds qualifies as an OZ Fund. Pinnacle is not prohibited from forming or managing a non-OZ Fund. Assets Under Management As of December 31, 2023, Pinnacle managed approximately $223,618,000 of Client assets on a discretionary basis. The Adviser does not manage assets on a non-discretionary basis.