People Make the Difference, Inc. doing business under the name PMD Advisory (“hereinafter “PMD Advisory” or “we”) is an investment adviser registered with the Securities and Exchange Commission. The investment adviser was previously registered with the State of Alabama since December 15, 2011 under the name Pryor McCormick, Inc. until August 2014. We are a corporation formed under the laws of the State of Alabama. April 2014 a company was created under the name People Make the Difference, Inc. The investment advisory business was transferred from Pryor McCormick, Inc. to People Make the Difference, Inc. doing business under the name PMD Advisory in August 2014. People Make the Difference, Inc. is owned by Melanie S. Dickinson. Details of her education and business background are provided in the supplement to this Disclosure Brochure. General Description of Primary Advisory Services Financial Planning & Consulting Services PMD Advisory provides financial planning services, which includes preparing a written financial plan covering specific or multiple topics. Our full written financial plans can include, but are not limited to, the following topics: investment planning, retirement planning, insurance planning, tax planning, education planning, portfolio reviews, asset allocation and real estate planning. Under this program, the role of your investment adviser representative (hereinafter “representative”) as a financial planner is to find ways to help you understand your overall financial situation and help you set financial objectives. We also provide modular written financial plans which only cover those specific areas of concern mutually agreed upon by you and PMD Advisory. A modular written financial plan is limited or segmented and does not involve the creation of a full written financial plan. You should be aware that other important issues are not be taken into consideration when your representative develops his or her analysis and recommendations under a modular written financial plan. PMD Advisory also provides consultations in order to discuss financial planning issues when you do not need a written financial plan. These consultations can cover any areas or topics of concern to you and can be a one-time event or involve multiple meetings. To begin the financial planning process, our representatives meet with you to gather information and documentation needed to perform an analysis and review of your situation as well your objectives and goals. One or more meetings are required in order to gather all needed information and determine the services best suited to help meet your needs. We rely on the information provided by you. Therefore, it is very important that the information you provide is complete and accurate. We are not responsible for verifying the information you supply. Our services do not include legal or tax advice. You are urged to work closely with your attorney, accountant or other professionals regarding your financial and personal situation. Limited Consultations If you do not need a written financial plan, you may contract with us for limited consultation services. These consultations can cover any topics or areas of interest or concern to you and can be a single event or involve multiple meetings. Advisement Consultations We also offer advisement consultations to participants in retirement plans (e.g., 401(k) plans, profit sharing plans, etc.). When providing these services, we review your financial situation, goals and objectives as well as the investment options available in the retirement plan. Although we do not make judgments on the quality or value of the specific investment choices available to you, we do make recommendations regarding asset allocation and investment selections for the investment portfolio in the plan. You have sole discretion whether or not to contract for advisement services available from us. In addition, you have sole discretion about whether or not to implement our recommendations or advice. We do not have trading authority over portfolios within your plans. You are responsible for executing transactions. We do not act as custodian for any assets in your plans. We do not provide management services for advisement accounts. General Information At your request, we will engage or consult with an outside professional (i.e., attorney, independent investment adviser or accountant) while providing financial planning and consulting services to you. You are responsible for payment of the outside professional’s fees. In no event will the services of an outside professional be engaged without your express approval. Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole responsibility for determining whether to implement our financial planning and consulting recommendations. If you want to implement any of our investment recommendations through PMD Advisory or retain PMD Advisory to actively monitor and manage your investments, you must execute a separate written agreement for our asset management services. IRA Rollover Considerations As part of our consulting and advisory services, we provide you with recommendations and advice concerning your employer retirement plan or other qualified retirement account. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as described above under Item 5. This practice presents a conflict of interest because persons providing investment advice on your behalf have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Furthermore, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by us. It is important for you to understand that many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically have four options: 1. Leave the funds in your employer's (former employer's) plan. 2. Move the funds to a new employer's retirement plan. 3. Cash out and take a taxable distribution from the plan. 4. Roll the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage it is important you understand the following: 1. Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. a. Employer retirement plans generally have a more limited investment menu than IRAs. b. Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. 2. Your current plan may have lower fees than our fees. a. If you are interested in investing only in mutual funds, you should understand the cost structure of the share classes available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. b. You should understand the various products and services you might take advantage of at an IRA provider and the potential costs of those products and services. c. It is likely you will not be charged a management fee and will not receive ongoing asset management services unless you elect to have such services. In the event your plan offers asset management or model management, there may be a fee associated with the services that is more or less than our asset management fee. 3. Our strategy may have higher risk than the option(s) provided to you in your plan. 4. Your current plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost. 5. If you keep your assets titled in a 401k or retirement account, you could potentially delay your required minimum distribution beyond age 73 (70 ½ before January 1, 2020). 6. Your 401k may offer more liability protection than a rollover IRA; each state may vary. a. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult an attorney if you are concerned about protecting your retirement plan assets from creditors. 7. You may be able to take out a loan on your 401k, but not from an IRA. 8. IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. 9. If you own company stock in your plan, you may be able to liquidate those shares at a lower capital gains tax rate. 10. Your plan may allow you to hire us as the manager and keep the assets titled in the plan name. It is important that you understand the differences between these types of accounts and to decide whether a rollover is best for you. Prior to proceeding, if you have questions contact your investment adviser representative, or call our main number as listed on the cover page of this brochure. 401(K) Advisory and Retirement Plan Consulting Services PMD Advisory offers retirement consulting, fiduciary, and participant services to employee retirement plans as defined by ERISA. The services are engaged

by the plan sponsor (the “Company”) in meeting its management and fiduciary obligations to the plan under ERISA. PMD offers the following services: i. 401k Consulting Services a. PMD Advisory consults with Plan Sponsor on plan objectives and design to improve employer and employee savings. b. PMD Advisory performs an annual benchmarking analysis that assesses service providers, fees, expenses and investment performance in relation to its peers. c. PMD Advisory provides a fiduciary governance system that establishes a prudent process for monitoring expenses and investment performance. d. PMD Advisory creates an audit document lock box for organization of fiduciary files. ii. Plan Sponsor Fiduciary Services a. PMD Advisory can serve as an ERISA 3(38) Investment Manager which includes the following services: i. Develop and execute an Investment Policy Statement ii. Select investment options consistent with ERISA section 404(c) iii. Select and monitor the investment lineup for the plan iv. Determine a Qualified Default Investment Alternative (QDIA) b. PMD Advisory can serve as an ERISA 3(21) Non-Discretionary Investment Advisor which includes the following services: i. Assist in the development of an Investment Policy Statement ii. Assist with investment options consistent with ERISA section 404(c) iii. Non-Discretionary recommendations for selection of investment line-up iv. Non-Discretionary investment advice for selection of Qualified Default Investment Alternative (QDIA) iii. Participant Services a. PMD Advisory can serve as a Non-Discretionary 3(21) Investment Advisor to provide participants with advice. b. PMD Advisory can establish an adaptable service calendar and provide investment education services that focus on retirement readiness by spending time with employees. The Company may also engage us to provide a review of executive benefits, for separate compensation. PMD Advisory will determine with the Company in advance the scope of services to be performed and the fees for all requested services. Prior to engaging us to provide pension consulting services, the Company will be required to enter into a written agreement with us setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the relevant fees and fee-paying arrangements. The services outlined above that we provide are explained in more detail in the written agreement. We will also provide additional disclosures about our services and fees, where required by ERISA. PMD Advisory will not be required to verify the accuracy or consistency of any information received from the Company. PMD Advisory and its supervised persons will serve in a nondiscretionary ERISA fiduciary capacity with respect to some but not all of the services that we provide, which will be further explained in the written agreement we sign with the Company. The Company is always free to seek independent advice about the appropriateness of any recommendations made by PMD Advisory. IRA Rollover Recommendations We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Seminars and Workshops PMD Advisory occasionally provides seminars, webcasts and workshops in areas such as financial planning, retirement planning, and estate planning and charitable planning. Presentations are made on an impersonal basis and do not focus on the individual needs of the participants. Third Party Money Manager Referral Services PMD Advisory refers clients to third party money managers offering asset management and other investment advisory services. The third-party managers are responsible for continuously managing client accounts and making trades in client accounts when necessary. As a result of the referral, we are paid a portion of the fee (in the form of promoter fees) charged and collected by the third party money managers as further described below under Item 5. Under this program, we assist you in identifying your risk tolerance and investment objectives. We recommend outside money managers in relation to your stated investment objectives and risk tolerance, and you may select a recommended third party money manager or model portfolio based upon your needs. You must enter into an agreement directly with the third-party money manager who provides your designated account with asset management services. Your PMD Advisory Representative is available to answer questions you may have regarding your account, and we act as the communication conduit between you and the third party money manager. The third party money managers take discretionary authority to determine the securities to be purchased and sold for you. We do not have any trading authority with respect to your designated account managed by the outside money manager. Third party managed programs generally have account minimum requirements, and these minimum requirements vary from investment advisor to investment advisor. Account minimums are generally higher on fixed income accounts than equity-based accounts. A complete description of the third party investment advisor’s services, fee schedules and account minimums are disclosed in the third party investment advisor’s Disclosure Brochure that is provided to you at the time you sign an agreement for services and establish an account. Third Party Asset Management Programs PMD Advisory offers clients access to third party management programs where PMD selects from various managers and select one or more managers or model managed accounts. Your PMD Advisory representative will select and design a management program based on your individual investment objectives and goals. PMD Advisory will act as a co-adviser and your representative will periodically meet with you and review your account. Your representative will determine any changes to the allocation or the individual asset managers and implement changes deemed appropriate. PMD Advisory Asset Management Program PMD Advisory provides asset management services involving continual and on-going supervision over your accounts based on your individual investment goals and objectives and risk tolerance. Unless otherwise expressly requested by you, PMD Advisory will manage the accounts and will make changes to the allocation as deemed appropriate by PMD Advisory. PMD Advisory will determine the securities to be purchased and sold in the account and will alter the securities holdings from time to time, without prior consultation with you. Discretionary authority will be granted by you to PMD Advisory by execution of the asset management agreement. If you elect to have your accounts managed on a non-discretionary basis, no changes will be made to the allocation of your account without prior consultation with you and your expressed agreement. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, exercise or delegate proxy voting and receive transaction confirmations) of the Account. At no time does PMD Advisory have custody of your account, with the exception of deduction of PMD Advisory’s advisory fee from your account if authorization is provided in the asset management agreement or some standing letters of authorization. The qualified account custodian maintains custody of your funds and securities. We do not act as custodian and will not have direct access to your funds and securities except to have advisory fees deducted from your account with your prior written authorization. Account reallocations and rebalancing trigger a taxable event for non-qualified accounts. The Account is managed by PMD Advisory based on your financial situation, investment objectives and risk tolerance. PMD Advisory offers investment models from which to select or a managed account can be customized to your individual needs. Limits Advice to Certain Types of Investments PMD Advisory primarily uses open-ended mutual funds and uses no-load and load waived or mutual funds purchased at net asset value (NAV) and exchange traded funds (“ETFs”). However, managed accounts are not exclusively limited to mutual funds and ETFs. PMD Advisory provides investment advice on the following types of investments:
• Mutual Funds
• Exchange-listed Securities
• Securities Traded Over-the-Counter
• Corporate Debt Securities
• Certificates of Deposit
• Municipal Securities
• Variable Annuities
• US Government Securities
• Options Contracts on Securities Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that are suitable for your specific circumstances, needs, goals and objectives. It is not PMD Advisory’s typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles or special tax situations. Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information. Tailor Advisory Services to Individual Needs of Clients PMD Advisory’s services are always provided based on your individual needs. You may impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. Client Assets Managed by PMD Advisory As of our last fiscal year end, December 29, 2023, we had $126,355,608 in assets under discretionary management and $12,978,484 in assets under non-discretionary management.