A. Description of Services PrimeTRUST Advisors, LLC. ("PrimeTRUST", "Advisor" or the "Firm") is a registered investment adviser with the U.S. Securities and Exchange Commission ("SEC"). The Advisor is based in Greenville, South Carolina. The Firm is organized as a limited liability company under the laws of the State of South Carolina. PrimeTRUST has been providing investment advisory services since 2006. Julian Grice (Chip) Hunt, Jr. is the Firm's principal owner.
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by PrimeTRUST. The words "you", "your" and "Client", as used in this brochure, refer to you as either a Client or prospective Client of PrimeTRUST. Also, you may see the term "Associated Person(s)" throughout this brochure. Associated Persons are the Firm's officers, employees, and all individuals providing investment advice on behalf of the Firm.
B. Advisory Services Offered – Institutional Clients PrimeTRUST Advisors offers fee-based investment advisory services and consulting services to Institutional Clients sponsoring tax-qualified defined-benefit pension and defined contribution retirement plans (each referred to as "Retirement Plan") for their employees.
Investment Management Services PrimeTRUST offers investment advisory services to those institutions sponsoring various types of Retirement Plans, including defined benefit plans, cash balance pension plans, profit sharing plans, employee stock ownership plans, 401(k) plans, and 403(b) plans. The Firm's services are designed to guide institutional plan sponsors to support their fiduciary obligations under the Employee Retirement Income Security Act ("ERISA").
The Firm works with Institutional Clients to establish the Retirement Plan's investment needs, goals, and objectives. PrimeTRUST then prepares a written investment policy statement to memorialize the goals, the investment performance standards and criteria under which the investment fund options are to be initially selected and then measured, monitored, and evaluated on a recurring basis.
PrimeTRUST will primarily recommend mutual funds or ETFs for the Institutional Clients' Retirement Plan according to the selection guidelines within the Investment Policy Statement.
For defined benefit pension plans, PrimeTRUST will work with the institution's duly appointed retirement committee to establish the asset allocation that best aligns with the institution's financial parameters including considerations such as their financial risk objectives, funded status, and desired contribution levels.
Under the Firm's non-discretionary investment advisory services arrangement, the definitive decision- making authority for the selection of the Retirement Plan's investment options belongs exclusively to the Institutional Client upon consideration of the advisory services provided by the Advisor.
In addition to the non-discretionary investment advisory services, in certain circumstances, PrimeTRUST may accept the responsibility to manage plan assets with discretion as a fiduciary. In performing fiduciary services, the Firms is acting as a discretionary fiduciary of the Retirement Plan as defined in Section 3(38) under ERISA. In these cases, the terms and conditions for such an engagement are included in the investment advisory services agreement.
4 As part of the Firm's investment advisory services, PrimeTRUST may recommend that you use the services of a third-party investment adviser ("TPA") to manage a portion of the Retirement Plan investment portfolio. Factors that the Firm takes into consideration when making the recommendation(s) include the following: the TPA's performance and experience, methods of investment analysis, fees, your financial needs, investment goals, risk tolerance, and investment objectives. The Advisor will periodically monitor the TPA(s)' performance to ensure its management and investment style remains aligned with your investment goals and objectives.
Consulting Services PrimeTRUST provides fee-based consulting services for Institutional Clients that sponsor a Retirement Plan. The Firm gathers extensive information on each plan at the commencement of an engagement to determine which of the Firm's services can benefit the Plan Sponsor. PrimeTRUST outlines a recommended scope of work for the consulting project for approval by the Plan Sponsor. The specific details of any engagement to provide consulting services are agreed upon in writing prior to the commencement of the project and are subject to the terms and conditions of a Consulting Agreement.
These services, some of which are discussed below, may be provided separately or in combination with one another, depending on the needs of the Plan Sponsor.

•Plan Service Provider Evaluation and Plan Fees Review This process helps fiduciaries to satisfy one of their primary fiduciary duties -- to assure that plan fees and expenses are fair and reasonable within the context of the services provided.
PrimeTRUST can be engaged on a one-time basis to evaluate your Retirement Plan service provider. The Firm does this by taking an inventory of the services offered to your Retirement Plan, evaluating the multitude of service functions, assigning a "value" score for each of the major service components, and rendering an overall evaluation score of your existing service provider and comparing that score to a peer group of service providers. As part of the project, PrimeTRUST reviews and evaluates your existing plan fee and expense arrangements, including trustee/custodial fees, record keeping fees, administration and investment related fees.
The centerpiece of the study is the Firm's proprietary cost/benefit analysis which enables fiduciaries to better determine the value proposition of their existing services provider(s). The Firm's analysis will be based on information supplied by you, your service provider(s), and third- party databases.
•Defined Benefit Pension Plan Management PrimeTRUST provides a process-oriented consulting service for Plan Sponsors who need assistance managing their pension plan throughout the wind-down phase to the plan's eventual termination or restoration to its fully funded status. This includes determining plan sponsors goals, then designing and implementing a multi-year project management plan incorporating establishing the plan's funding policy, investment policy, benefit design management, supervising asset liability studies, developing liability driven investment strategies, and coordinating the steps for formal plan termination process.
PrimeTRUST helps fiduciaries by coordinating, guiding and monitoring the activities of the plan's actuary, attorney, accountant, corporate finance executive team, investment manager, and the administration and recordkeeping firm. The Firm's proprietary Quarterly Plan Performance Monitoring Reports track the project plan's progress using metrics key to the plan's successful outcome; including reporting on sources of change to the plan's funded status, funding schedules for the plan year and calendar year, summary trust report statement 5 of contributions and distributions, and investment performance reviews to customized relevant pension plan benchmarks.
•Plan Service Provider Search and Recommendation PrimeTRUST will work with the Plan Sponsor, named fiduciary or investment committee (hereafter, referred to as the "Responsible Plan Fiduciary") to establish selection criteria for conducting a search of retirement plan service providers based upon the plan's service requirements and benefit resource needs. The Advisor will identify and screen potential service providers, benchmarking each according to the agreed upon selection criteria and score them accordingly. The Advisor will then make a recommendation to Responsible Plan Fiduciary for their consideration in making a final decision.
•Employee Education For pension, profit sharing and 401(k) plan Clients designed to allow individual plan participants to exercise control over assets in their own account ("self-directed plans"), PrimeTRUST may also provide periodic educational support and investment workshops designed for the plan participants. The nature of the topics to be covered will be determined by PrimeTRUST and the Client but will be limited to those activities that are educational in nature.
•Fiduciary Education and Training PrimeTRUST can provide fiduciary education and training to the fiduciaries of the plan. Such training will include comprehensive discussion and supplementary handout materials pertaining to topical fiduciary issues including: identification of fiduciaries, discussion of fiduciary duties, responsibilities and liabilities under ERISA, presentation of a "blue print" for procedural prudence, fiduciary risk management strategies and approaches to delegating responsibility to a prudent expert. C. Advisory Services Offered – Individual Clients PrimeTRUST Advisors offers fee-based investment advisory and consulting services to Individual Clients in need of financial planning or investment advisory services.
Financial Planning Services PrimeTRUST offers financial planning services which typically involve providing a variety of advisory services to Clients regarding the management of their financial resources based upon an analysis of their individual needs.

These services can range from broad-based financial planning to consultative or single subject planning.
Financial planning is a process that focuses on ascertaining a Client's financial goals and then developing a written plan to help the Client achieve those goals. A written financial plan is created by the Firm to carry an individual Client from his or her present financial position to the attainment of financial goals. Since no two Clients are alike, the plan must be designed for the individual, with the Advisor's recommended strategies tailored to each particular Client's needs, abilities, and financial goals.
Financial plans will vary based on the information provided by the Client. If you retain PrimeTRUST for financial planning services, the Firm will meet with you to gather information about your financial circumstances and objectives. PrimeTRUST may also use financial planning software to determine your current financial position and to define and quantify your long-term goals and objectives. Once your specified long-term objectives (both financial and non-financial) are identified, the Firm will develop shorter-term, targeted objectives. PrimeTRUST will deliver a written plan to you, designed to help you achieve your stated financial goals and objectives.
6 Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Similarly, a recommendation to purchase an insurance product for which the Firm receives a commission would pose a conflict. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effect transaction through the Advisor.
Investment Management Services PrimeTRUST offers discretionary investment advisory and asset allocation services tailored to meet the Firm's individual Clients' needs and investment objectives primarily using mutual funds and exchange-traded funds.
The Firm provides advice in connection with one or more of the following items as needed:
•Selection and establishment of investment account arrangements,
•Organization on the use and purposes of various financial accounts,
•Manage rollovers, transfers, or distributions to/from accounts,
•The investment of assets that are rolled over or otherwise transferred or distributed to accounts,
•Acquiring, holding, disposing of investment assets within investment accounts,
•Management of the investments, including strategies and portfolio composition If you participate in the Firm's discretionary portfolio management services, PrimeTRUST requires you to grant the Firm discretionary authority to manage your account. Discretionary authorization will allow the Firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with the Firm and the appropriate trading authorization forms. You may limit the Firm's discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing PrimeTRUST with your restrictions and guidelines in writing.
PrimeTRUST may also offer non-discretionary portfolio management services. If you enter non- discretionary arrangements with PrimeTRUST, the Firm must obtain your approval prior to executing any transactions on behalf of your account. You have an unrestricted right to decline to implement any advice provided by the Advisor on a non-discretionary basis.
As part of the Firm's investment management services, in addition to other types of investments, PrimeTRUST may invest your assets according to one or more model portfolios developed by PrimeTRUST. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. Clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model.
D. IRA Rollover Recommendations For purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, PrimeTRUST provides the following acknowledgment to Individual Clients.
When PrimeTRUST provides investment advice to Clients regarding their retirement plan account or individual retirement account, PrimeTRUST is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable. These are laws and 7 regulations governing retirement accounts. The way in which PrimeTRUST generates its income (gathering assets under the Firm's management) creates some conflicts of interest with Clients who are holding assets in IRAs and 401(k)-type account that are not under the Firm's management. To mitigate this conflict, PrimeTRUST operates under special rules that requires the Firm to act in a Client's best interest when making recommendations for 401(k)/IRA Rollovers and not put PrimeTRUST's interest ahead of the Client. Under this special rule's provisions, the Firm must:
•Meet a professional standard of care when making investment recommendations (give prudent advice),
•Never put the Firm's financial interests ahead of a Client's when making recommendations (give loyal advice),
•Avoid misleading statements about conflicts of interest, fees, and investments,
•Follow policies and procedures designed to ensure that the advice given is in a Client's best interest,
•Charge no more than is reasonable for the Firm's services; and
•Provide Clients with basic information about conflicts of interest. PrimeTRUST benefits financially from the rollover of Client assets from a retirement account to an account that the Firm manages or provides investment advice, because the assets increase the Firm's assets under management and, in turn, the Firm's advisory fees. As a fiduciary, PrimeTRUST recommends a rollover only when the Firm believes it is in a Client's best interest.
E. Client Account Management Prior to engaging PrimeTRUST to provide investment advisory, consulting or financial planning services, each Client is required to enter into one or more agreements with the Firm and the Client.
These advisory services may include:
•Investment Management Services for Institutional Clients
•Investment Management Services for Individual Clients
•Consulting Engagements
•Financial Planning Services F. Types of Investments PrimeTRUST primarily offers advisory services on mutual fund and exchange-traded fund products.
A mutual fund is a financial vehicle that pools assets from individual investors to invest in securities like stocks, bonds, money market instruments, and other assets. Mutual funds give small individual investors access to professionally managed portfolios of equities, bonds, and other securities. Each investor, therefore, participates proportionally in the gains or losses of the fund.
Mutual funds are operated by professional money managers, who allocate the fund's assets and attempt to produce capital gains or income for the fund's investors. A mutual fund's portfolio is structured and maintained to match the investment objectives stated in its prospectus.
An exchange-traded fund (ETF) is a type of pooled investment security that operates much like a mutual fund. Typically, ETFs will track a particular index, sector, commodity, or other asset, but unlike mutual funds, ETFs can be purchased or sold on a stock exchange the same way that a regular stock can.
8 An ETF can be structured to track anything from the price of an individual commodity to a large and diverse collection of securities. ETFs can even be structured to track specific investment strategies.
Additionally, PrimeTRUST may advise you on any type of investment that the Advisor deems appropriate based on your stated goals and objectives. The Advisor may also provide advice on any type of investment (including individual securities) held in your portfolio at the inception of your advisory relationship with PrimeTRUST.
You may request that the Advisor refrain from recommending particular securities or certain types of securities for investment. You must provide these restrictions to the Firm in writing.
G. Wrap Fee Programs PrimeTRUST does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by PrimeTRUST.
H. Assets Under Management As of December 31, 2023, PrimeTRUST provides continuous management services for $15,562,029 in Client assets on a discretionary basis, and $283,438,977 in Client assets on a non-discretionary basis. PrimeTRUST provides investment advice to defined benefit pension, 401(k) profit sharing and 403(b) plans with respect to assets having an aggregate value of approximately $299 million.