Firm Description Pacific Income Advisers, Inc. (“PIA”), a Delaware Corporation, is federally registered as an investment adviser with the Securities and Exchange Commission (“SEC”) and has been in business since 1986. PIA is an independent, employee-owned investment advisory firm, with approximately $1,962,896,000 in regulatory assets under management, in fixed income and equities. For more information on the types of clients we serve, please see the Types of Clients section of this brochure. Principal Owners Lloyd McAdams, President, Director and Portfolio Manager, through the Lloyd McAdams Family Trust, and Heather U. Baines, Chairman, through the Heather U. Baines Family Trust, are the principal owners of PIA. Austin Rutledge, Joseph E. McAdams, Adilberto Torres and Timothy Tarpening individually own minority interests in PIA. Types of Advisory Services PIA offers fixed income and equity strategies to those clients described in the Types of Clients section, through four distinct platforms consisting of institutional separately managed accounts (Institutional SMA), retail separately managed wrap-fee program accounts (Retail Wrap-Fee Programs), mutual funds, and model delivery programs. For more information on each of these investment strategies, please see the Methods of Analysis, Investment Strategies and Risk of Loss section of this brochure. Institutional SMA PIA invests in the following portfolio styles for its Institutional SMA clientele: Equities
• Small Cap – Core;
• Small Cap – Value;
• Small Cap – Growth; Fixed Income
• Core Plus;
• Corporate;
• High Yield;
• Intermediate Core Plus;
• Limited Duration;
• Market Duration;
• Moderate Duration;
• Short-Term;
• Ultra Short-Term;
• Shares in the PIA BBB Bond Fund, Managed Account Completion Shares (“MACS”), PIA High Yield (MACS) Fund and/or the PIA MBS Bond Fund, MACS;
• Shares in the PIA Short-Term Securities Fund and/or the PIA High Yield Fund, Institutional Class (see “PIA Mutual Funds” below). Retail Wrap-Fee Programs PIA currently participates in approximately 30 Retail Wrap-Fee Programs as a sub-adviser or under a dual contract arrangement. PIA does not sponsor any wrap-fee program. PIA offers the following managed account portfolio styles:
• Core Plus MACS;
• Corporate MACS;
• Intermediate Core Plus MACS;
• Limited Duration ETF-MACS;
• Limited Duration MACS;
• Limited Duration SMA;
• Limited Duration SMA Enhanced;
• Market Duration ETF-MACS;
• Market Duration MACS;
• Market Duration SMA;
• Market Duration SMA Enhanced;
• Moderate Duration ETF-MACS;
• Moderate Duration MACS;
• Small Cap Core;
• Shares in the PIA BBB Bond Fund, MACS, PIA High Yield (MACS) Fund and/or the PIA MBS Bond Fund, MACS; and
• Shares in the PIA Short-Term Securities Fund and/or the PIA High Yield Fund, Institutional Class (see “PIA Mutual Funds” below). PIA Mutual Funds PIA serves as sub-adviser to the PIA Mutual Funds, a family of open-end registered mutual funds. PIA offers five funds:
• PIA BBB Bond Fund, MACS;
• PIA High Yield Fund, Institutional Class;
• PIA High Yield (MACS) Fund;
• PIA MBS Bond Fund, MACS; and
• PIA Short-Term Securities Fund. PIA Model Delivery Program PIA provides model portfolios to unaffiliated investment advisers (“Sponsors”) who may utilize such model portfolios in connection with the management of their client accounts. Model portfolios may relate to the same investment strategies that are also offered to PIA’s discretionary accounts. As a model portfolio provider, PIA designs, monitors and updates the model portfolio but has no responsibility for implementing its recommendations or placing trades on behalf of participating accounts. PIA does not enter into a direct advisory relationship with the clients of these Sponsors and the model portfolios are not tailored to the specific needs or circumstances of the Sponsor’s clients. The Sponsors are solely responsible for initiating all trading and rebalancing activity recommended

by the model portfolio(s). Depending on the structure of the Sponsor’s program, Sponsors may choose not to implement certain changes made to our model portfolio or may delay the timing of trading in response to changes made to our model. As a result, the investment performance of a particular Sponsor’s client may differ from the investment performance of PIA’s Client Accounts that have elected to follow a similar investment strategy. PIA provides the model portfolios to the Sponsors at an agreed upon, periodic basis which varies depending upon the particular terms of the agreement between PIA and the Sponsor. Changes to the model portfolio will not be communicated to model program Sponsors until completion of aggregated trading for PIA’s discretionary clients. As a result, it is possible that, depending on the particular circumstances surrounding an order, PIA’s discretionary clients may receive prices that are more favorable than those received by a client of a program Sponsor or vice versa. In addition, Client Accounts following the PIA model portfolio may be positively or negatively impacted if companies included in the model portfolio(s) release important or material information prior to the time trading orders for a particular security have been completed by the Sponsor. Please refer to Item 12 for more information regarding the communication and delivery of a model portfolio to program Sponsors.
For more information on each of these investment strategies, please see the Methods of Analysis, Investment Strategies and Risk of Loss section of this brochure. Tailored Relationships Although most client relationships are discretionary and accounts are managed in accordance with the methods and investment strategies as explained in the Methods of Analysis, Investment Strategies and Risk of Loss section of this brochure, clients may still impose investment limitations and restrictions on certain securities or types of securities. Such restrictions must be submitted to PIA in writing, if not already addressed in the investment management agreement. Where PIA delivers its model portfolios to unaffiliated investment advisers, these portfolios are not tailored to the specific needs or circumstances of those advisers’ clients. Investment Management Agreement Institutional SMA All clients desiring to open an Institutional Separately Managed Account with PIA must enter into PIA’s investment management agreement and provide an investment policy statement. PIA relies upon the contents of the client’s completed investment policy statement when evaluating the most suitable types of investment products for the client. Retail Wrap-Fee Programs Under Retail Wrap-Fee Programs, advisory clients pay a specified fee for investment advisory services and the execution of transactions. Advisory services include portfolio management and/or advice concerning selection of other advisers; and the fee is not based directly upon transactions in the client’s account. PIA receives a portion of the wrap fee for services rendered. Retail Wrap-Fee Programs are managed similarly to Institutional SMAs with the following exceptions:
• Corporate bond position sizes are normally 3% per issuer for Retail Wrap-Fee Programs and 0.5- 1.5% for Institutional SMA.
• The bonds in the Retail Wrap-Fee Program are typically more liquid. Although the ultimate responsibility of analyzing suitability of investments rests solely with the program sponsor, PIA requests from the program sponsor detailed client information, including client profiles, account restrictions and other material documents in order to review the investment portfolio(s), guidelines and restrictions (where applicable) selected by the client prior to investment. Mutual Funds Investors wishing to invest in any of PIA’s mutual funds have the option of completing a new account form, or entering into a PIA Investment Management Agreement (“IMA”) and submitting an Investment Policy Statement (“IPS”), which allows for the purchase of the fund. Assets Under Management As of December 31, 2023, PIA managed $ 1,962,896,000 in regulatory assets under management, all on a discretionary basis.