Page |3 General PAI a corporation formed in the State of Florida on or about May 2014 and registered to conduct business as a SEC Registered Investment Adviser. PAI is wholly owned by Seth Grubman, who also serves as the Adviser’s President and Chief Compliance Officer. Description of Advisory Services PAI provides asset management, research, and other financial advice to individuals and corporations. PAI’s investment advisory services are provided through various types of non- discretionary accounts (the “Accounts”) in accordance with each client’s investment objectives and pursuant to the terms outlined in its investment advisory agreement. PAI does not provide advisory services on a discretionary basis. The Adviser’s non-discretionary investment management services include the design, structure, and implementation of investment strategies. Investment activities focus on investments in various kinds of assets and securities in a variety of markets that are intended to fit within the client’s objectives, strategies and risk profile as described by each client. The overall advisory services offered by PAI fall within the following categories:  Non-Discretionary Advisory Services Adviser provides non-discretionary advisory services to all types of clients in accordance with a non-discretionary advisory agreement between Adviser and the client. Each agreement typically defines the services to be provided and if a fee is charged, which is outlined in the advisory agreement. Adviser also provides recommendations and research regarding the investment of securities and cash in a client’s account. These services are individually tailored to each client’s needs and such advice may be provided to accounts with assets maintained

at various third parties.  Family Office Services The Adviser offers family office investment advisory services. Such services include, but are not limited to furnishing advice to clients on matters not involving securities, such as financial planning matters, retirement planning, real estate planning, trust services that often include estate planning and educational services. The Adviser’s services also include providing personalized confidential financial planning, investment management and financial advisory, as well as family office services to individuals, corporations, trusts and charitable organizations worldwide. Advice is provided through Page |4 consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, insurance review, investment management, education funding, retirement planning, estate planning, real estate analysis and educational services.  Other Services Adviser may provide additional services for clients from time to time as agreed between the client and the Adviser. Regulatory Assets Under Management As of December 31, 2023, PAI maintained approximately $839,222,058 in assets under management on a non-discretionary basis. Additional General Information Other professionals (i.e., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the client in the event they should occur. PAI’s investment advisory agreements may not be assigned without client consent. PAI does not currently participate in any Wrap Fee Programs.