Pinnacle Capital Management, LLC (“PCM”) was founded in August 2006 and is controlled by Pinnacle Holding Company, LLC. PCM is organized as a Delaware limited liability company. PCM’s main office is located in East Syracuse, New York. PCM may provide investment supervisory services and offer advice on: - equity securities (exchange-listed securities, securities traded over-the-counter, foreign issuers), - corporate debt securities, - commercial paper, - certificates of deposit, - municipal securities, - investment company securities (mutual fund shares), - private funds - United States government securities, - options contracts on securities, - interests in partnerships investing in real estate, - asset backed securities (ABS) including but not limited to residential real estate mortgage backed securities (MBSs), collateralized loan obligations (CLOs), commercial mortgage backed securities (CMBSs), and ABS backed by credit card receivables, auto loans, and equipment leases, - private placement debt securities. PCM offers advisory services and sub-advisory services, where appropriate, to individuals, pension and profit sharing plans, trusts, estates, charitable and non-profit organizations, investment companies, private funds, corporations, insurance companies and other business entities. PCM provides continuous advice to clients regarding investment of assets based on the individual needs of the client. Client investment objectives, risk tolerances and time horizon are established at the beginning of each client relationship and are routinely monitored throughout the relationship. If desired, PCM will assist clients in developing a customized investment policy and create and manage a portfolio based on that policy. PCM will manage advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the stated objectives of each client. PCM will create a portfolio, or advise on the creation of a portfolio, consisting primarily of individual equities, exchange traded funds, mutual funds, private funds, fixed income securities and cash equivalents (e.g. money market funds). PCM will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. The mutual funds, private funds and exchange traded funds will be selected on the basis of any or all of the following criteria: the fund's performance history; the industry or geographic sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. Portfolio weighting between funds and market sectors will be determined by the investment style selected based on each client's individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. Clients will retain individual ownership of all securities. As appropriate, PCM may engage in margin transactions or option writing for client accounts. As these strategies involve additional risks, they will only be recommended when consistent with the client’s stated risk tolerance. PCM provides portfolio management services in the Pinnacle Investments’ Pinnacle Capital Management Separately Managed Account Program ("PCM SMAP"). PCM SMAP is a sub-advisory program under which Pinnacle Investments, LLC ("PI"), a dually registered firm affiliated with PCM through common ownership and control, acts as adviser. PCM is the sub-adviser responsible

for portfolio management services within the program. As part of its portfolio management services, depending on the version of the PCM SMAP agreement, PCM may vote proxies on behalf of participants. PCM is compensated by PI for providing portfolio management services for clients. The participants in PCM SMAP are clients of PI and not advisory clients of PCM. PI is responsible for assisting clients in understanding the program in light of the client’s investment objectives and financial situation – initially and on an ongoing basis. PI is also responsible for client communication, portfolio reviews, client services, account maintenance and communicating client portfolio strategy changes to PCM. PCM manages client portfolios in accordance with the portfolio strategy selected on the PCM Managed Account Instruction Form with full trading discretion, subject to reasonable written restrictions, and does not act in any other capacity. These clients should refer to PI’s disclosure document for additional information on the program. In March 2023 PCM’s sister company Confidential Planning I, LLC (“CPI”) was merged into PCM. Both companies were previously wholly owned by Pinnacle Holding Company, LLC (“PHC”). CPI was a registered investment advisory firm focused on bringing single provider 403(b) retirement plans to educators and employees of schools, hospitals and not-for-profit (501c) organizations. The advisory services previously provided by CPI will continue to under PCM. Retirement Services Program The Retirement Services program offer IARs two options of assisting Plan Sponsors with some or all of the following; customized investment advisory services, diversified investment menus, consulting and reporting, and participant educational programs. Investment Advisory Services PCM (formerly CPI) has a relationship with Benefit Plans Administrators in Utica, NY and PenServ Plan Services in West Columbia, SC, to provide recordkeeping services and third-party-administration services. Through the SmartChoice and MultiChoice programs, the IAR provides investment advisory service and assists Plan Sponsors with developing a customized investment plan to fit the needs of individual plan participants. PCM (formerly CPI) and the IAR may use a variety of mutual fund company shares (including no-load and load-waived mutual funds). Each plan will consist of a diversified mix of investment options to assist plan participants of the plan in meeting their individual needs. The mix and weightings of investments will be based on the available plan options and each plan participant’s risk profile, investment objectives, and individual preferences. Each plan and plan participants will have the opportunity to meet with the IAR at periodic educational sessions and the plan will have the opportunity to review the assets in the plan periodically with the IAR. Plan participants will have the ability to either generate online account statements through the TPA’s website, or receive account statements from the recordkeeping agent, showing account activity, positions, and asset values held in the account no less frequently than quarterly. Additionally, participants can make changes to their investment allocation on an ad-hoc basis, in accordance with the terms of the respective plan documents. The assets of each plan account will be held at a qualified custodian. Minimum Account Size There is no minimum account size requirement. As of March 31, 2024 PCM managed approximately $200 Million on a discretionary basis and oversaw approximately $53 Million in non-discretionary 403(b) assets.