A. Description of the Advisory Firm Pine Valley Investments (hereinafter “PVI”) is a Limited Liability Company organized in the State of New Jersey. The firm was formed in October 2014, and the Managing Member is Harry Morad. Harry Morad, Joseph Duncan, and Michael Modica are founding partners at Pine Valley Planning, PV Capital, LLC, and Pine Valley Consulting. PV Capital, LLC is the manager to PV Opportunity Fund Series I, LLC, a private investment fund. PV Capital, LLC may serve as manager to one or more private investment funds in the future. PV Capital, LLC is owned by Harry Morad, Joseph Duncan, Michael Modica, and others. Pine Valley Planning is a licensed insurance producer through which Pine Valley Investments investment adviser representatives may be licensed to sell insurance. B. Types of Advisory Services Portfolio Management Services - (PVI-introduced clients) PVI renders investment advice to clients through its investment adviser representatives. PVI often refers to these clients as “PVI-introduced clients”. For these clients, PVI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. PVI uses information collected from clients in its Client Profile Sheet (which is an exhibit to its Investment Advisory Contract), which outlines the client’s current situation (income, net worth, investment experience, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following:  Investment Strategy  Asset Allocation  Risk Tolerance  Performance Reporting  Asset Selection  Regular Portfolio Monitoring PVI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. In its Investment Advisory Contract, PVI requests discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are determined by a questionnaire which is given to each client, along with on-going correspondence. Investment Management Services through Tri-Party Agreements (Referred Clients) PVI may also enter into Tri-Party Agreements with other investment advisers and their clients. PVI refers to these clients as “Referred Clients”. These Tri-Party agreements delegate services between the other investment adviser (referred to in the Tri-Party Agreement as an “Adviser” and PVI (referred to in the Tri-Party Agreement as the “Manager”)). The Adviser is engaged by the Referred Client to assist the Referred Client with the day-to-day interactions related to the management of the Referred Client’s investment assets. Among other responsibilities, the Adviser is responsible for (1) assisting the Referred Client with completing a Client Profile Sheet, (2) developing the referred Client’s investment objectives, (3) serving as the Referred Client’s primary contact with respect to their

account, (4) assisting the Referred Client with the selection of an investment strategy, and (5) communicating any restrictions to PVI. PVI is responsible for the investing activities of each Referred Client’s account. Pension Consulting Services PVI offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. Subadvisor Services PVI may also act as a subadvisor to advisers unaffiliated with PVI. These third-party advisers would outsource portfolio management services to PVI. This relationship will be memorialized in each contract between PVI and the third-party advisor. Selection of Other Advisers PVI has discretion to choose third-party investment advisers to manage all or a portion of the client's assets. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third-party adviser on behalf of PVI's client. PVI may also allocate among one or more private equity funds or private equity fund advisers. PVI will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Selection of another adviser may come at the request of the client. C. Client Tailored Services and Client Imposed Restrictions For PVI-introduced clients, PVI will tailor a program for each individual client. This will include necessary communication to get to know the client’s specific needs and requirements as well as a plan that will be executed by PVI on behalf of the client. PVI may use “model portfolios” together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent PVI from properly servicing the client account, or if the restrictions would require PVI to deviate from its standard suite of services, PVI reserves the right to end the relationship. For Referred Clients, PVI generally manages the Referred Client’s account according to the investment strategy or model portfolio selected by the Referred Client and their Adviser. Referred Clients may impose restrictions on investing in certain securities or types of securities, subject to PVI’s acceptance. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. PVI does not currently participate in any wrap fee programs. E. Assets Under Management PVI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 1,742,507,212 $ 0 December 31, 2023 PVI has the following assets under advisement: AUA: $ 118,341,908