Pinvest LLC (“PINVEST”, or the “Firm” or the “Adviser”) is an investment advisory firm with its principal place of business located in Coral Gables, Florida, organized as a Florida limited liability company in April 2024. As used in this brochure, the words "we," "our," and "us" refer to PINVEST and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term "associated person" throughout this brochure. As used in this brochure, our associated persons refer to our officers, employees, and all individuals providing investment advice on behalf of our Firm. The sole shareholder of PINVEST is Pichincha Holdings LLC; both companies are part of Grupo Financiero Pichincha, a financial services group with operations in the US, Ecuador, Peru, Colombia, and Spain. Esteban Zorrilla serves as the Firm’s Principal and Chief Compliance Officer (“CCO”). More information about our related persons is found in Item 10, Other Financial Industry Activities and Affiliations. A. SERVICES PINVEST offers discretionary and non-discretionary investment advisory services for domestic and foreign individuals, trusts, family offices and institutions through separately managed accounts (each a “Client” and collectively the “Clients”). Every Client signs an investment advisory agreement (“Agreement”), setting forth the relevant terms and conditions of the advisory relationship with us. Clients may impose reasonable restrictions on investing in certain securities, types of securities or industry sectors. PINVEST customizes the nature and scope of its services based on a particular Client’s current and anticipated financial condition, risk tolerance and goals, and these services may include consulting on portfolio construction, investment opportunities, hedging of existing assets and/or such other advisory services as PINVEST and such Client may agree. Information provided by the Client is also collected during meetings, interviews and/or by completing questionnaires. PINVEST will work with each Client to establish an appropriate investment profile. After defining the Client’s appropriate investment profile, the investment strategy is implemented through a combination of investment products. For non-discretionary Clients, we provide research, advice and recommendations. However, you must provide specific consent prior to each transaction. If we enter into a non-discretionary arrangement with you, you have an unrestricted right

to decline to implement any advice provided by our Firm. Within the discretionary portfolio management, PINVEST will define the Client’s appropriate investment strategy, based on the Client’s investment profile and objectives and delegate the discretionary investment management process to a Third-Party Portfolio Manager. More information about the investment strategies is found in Item 8. In accordance with the Agreement, the Client grants the Adviser full discretionary authority to invest, reinvest and otherwise deal with the allocated assets in their discretion, including without limitation the authority to select, allocate and reallocate the assets in your account, when the Adviser deems it appropriate and without prior consultation with you to buy, sell, convert and otherwise trade in any security for the allocated assets. The Adviser works with a disciplined and systematic investment decision process. The approach is built upon financial market analysis and an economic scenario defined by the Adviser. Fundamental and technical analysis is used to identify investments for recommendations that are suitable and have a reasonable basis for recommendations. The Agreement entered by PINVEST shall be in accordance with the requirements of the Advisers Act and other applicable federal and state law. Additional services may include implementation of investment recommendations, quarterly portfolio evaluations, consultation, and assistance with the implementation of suggested planning strategies. In conjunction with the implementation of your financial plan and/or the management of your portfolio, we may manage your assets on a discretionary basis or non-discretionary basis through our managed account program and/or we may refer you to use the services of unaffiliated, Third Party Money Managers ("TPMMs"), whose services are described in their respective Form ADV Disclosure Brochures (only for US-based advisors registered with the SEC and or the appropriate State(s)). We will determine which programs and strategies are most appropriate for you, based upon your individual circumstances, needs, and investment objectives, and, as described below, may exercise discretion in hiring and firing TPMMs for the management of your account's assets. You will also be provided with the TPMM's Form ADV Disclosure brochure (if applicable). ASSETS UNDER MANAGEMENT As a de-novo investment advisor, PINVEST does not currently have any clients or regulatory assets under management.