Founded in 1984, Pinnacle offers investment advisory services to individuals and families, institutional investors, and other financial institutions. As of December 31, 2023, Pinnacle had approximately $8,132,363,120 in discretionary assets under management. In addition to the above discretionary assets under management, as of December 31, 2023, there were approximately $152,000,000 in additional assets managed on a non-discretionary basis and among the UMA Programs (as defined below in Section 4) for which Pinnacle acts as a model manager. Institutional Investment Management Services The firm provides discretionary investment management services to various institutional clients. These institutions primarily engage Pinnacle to manage their assets utilizing one or more of Pinnacle's investment strategies including, but not limited to:
• Small Cap Equity
• Small/Mid Cap Equity
• All Cap Equity
• Large Cap Equity
• Balanced
• International Small Cap
• International ADR
• Global Equity Pinnacle generally employs a fundamental, bottom-up analysis coupled with a valuation sensitive approach aimed at generating alpha. The firm's institutional strategies are primarily comprised of individual equity ("stocks") securities. Both institutional and individual clients may engage Pinnacle to manage their assets using one of the firms above strategies. Investment Management Services for Individuals and Families The firm also provides discretionary investment management services to non-institutional, individual investors and their families, trusts, businesses, and related entities. In these types of relationships, the investment process begins with identifying a client’s return objectives, time horizon, risk tolerance and near and long-term liquidity needs. Additional consideration is also given to client-specific special circumstances (i.e., existing portfolio positions). Once this information is gathered and analyzed, Pinnacle determines an appropriate allocation among the traditional asset classes and implements an investment strategy. In these types of relationships, Pinnacle primarily allocates client assets among various stocks and debt (“bonds”) securities. In addition, the firm may utilize exchange-traded funds (“ETFs”) and mutual funds in accordance with the client’s designated investment objectives. Pinnacle may also provide advice on any other type of position held in a client’s portfolio to meet their particular investment needs. Client portfolios are then monitored and adjusted with respect to changing market conditions and investor circumstances, as appropriate. Investment Objectives and Restrictions As stated above, institutional clients generally engage Pinnacle specifically for one or more of its equity investment strategies, and institutional assets are allocated directly into those strategies. It is not uncommon for institutional clients to have separate investment professionals (i.e., third-party investment consultants or in-house investment committees) make a determination regarding the suitability of Pinnacle’s strategies prior to the client engaging the firm for services. For non- institutional, individual client relationships, the firm will more specifically tailor its advisory services to meet the needs associated with these types of clients including diversification and related factors. All clients may impose reasonable restrictions on the management of their portfolios if Pinnacle determines, in its sole discretion, that the conditions would not materially impact the performance of an investment strategy or prove overly burdensome to the firm’s management efforts. For example, Pinnacle offers socially responsible strategies for clients seeking a more customized investment experience. In performing its services, Pinnacle is not required to verify any information received from a client or from the client’s other professionals (e.g., attorneys, accountants, investment consultants or other professional advisors, etc.), and is expressly authorized to rely on such information. Clients are advised to promptly notify Pinnacle if there are any changes to their investment objectives, financial situation or if they wish to place any limitations on the management of their accounts. Financial Planning Services Pinnacle may provide financial planning services to its investment management clients, including the creation of a goals-based financial plan. Any financial planning services will generally be included as part of the firm’s overall investment management fee (as described further in Item 5), unless otherwise agreed upon with the client. In addition, to the extent requested by the client, Pinnacle may recommend the services of other professionals such as attorneys, accountants, and insurance agents for certain implementation purposes. The client is under

no obligation to engage the services of any such recommended professional. Wrap Fee Programs / Unified Managed Account Programs Pinnacle serves as a portfolio manager to a limited number of unaffiliated wrap fee programs. These wrap programs are generally provided for a single fee, which give participants the ability to trade in certain investment products without incurring separate brokerage commissions and transaction charges. Pinnacle is not the sponsor of these various programs, and generally does not have a personal relationship with the end-client. Each program sponsor is required to prepare and deliver to participants a separate wrap fee brochure, which contains detailed information about the program, including fees and services. Program participants should carefully review the wrap fee brochure provided to them by each sponsor. In these arrangements, the program sponsor typically collects the management fee and pays Pinnacle a portion of the total wrap fee for the portfolio management services it provides. Pinnacle will generally be unable to negotiate commissions and/or transaction costs for these programs. Participation in a wrap program may cost the participant more than purchasing such services separately. Pinnacle also offers its strategies to a limited number of unaffiliated unified managed account (“UMA”) programs. Pinnacle does not have a direct relationship with the end-clients in these programs. In these programs, Pinnacle provides its model trades to the program sponsor who is then responsible for executing the trades for the underlying accounts. In limited cases, a program participant has a dual agreement, one agreement with the program sponsor and one with Pinnacle. In these situations, Pinnacle will generally execute transactions for the dual contract accounts through the sponsor. Transactions executed in this manner may be less favorable in some respects than Pinnacle’s other clients whose trades are not executed through the sponsor. This is due to the fact that Pinnacle may not have the ability to negotiate price or take advantage of aggregated orders or volume discounts, and the firm may be limited in obtaining best execution by sending trades through the sponsor. Sub-Adviser Pinnacle may be engaged by other financial advisors (e.g., other registered investment advisers, etc.) to offer its strategies in a sub-advisory capacity. In these arrangements, the primary financial advisor generally maintains the direct relationship with the end-client, and utilizes Pinnacle’s strategies to assist in managing their own clients’ accounts. Private Funds Pinnacle currently serves as the general partner and investment manager for various private pooled investment vehicles (collectively, the “Private Funds”). The Private Funds are exempt from registration under the Investment Company Act of 1940, and membership interests are privately offered pursuant to Regulation D under the Securities Act of 1933. Participation in the Private Funds is generally restricted to investors meeting the requirements of an “accredited investor,” as defined by Rule 501 under the Securities Act of 1933 (as amended). To the extent that certain of Pinnacle’s advisory clients qualify, the firm may recommend that they consider allocating a portion of their investment assets to the Private Funds. All relevant terms and conditions about the Private Funds including, but not limited to, management fees, withdrawal rights, minimums, conflicts of interest, fund expenses and risk factors, are set forth in the Private Funds’ confidential private offering memorandums, subscription agreements and/or limited partnership agreements (collectively, “Offering Documents”), which each investor is required to execute prior to acceptance as an investor in a fund. Pinnacle does not charge a separate performance/incentive-based fee to participate as an investor in a Private Fund. As general partner, however, Pinnacle will be entitled to receive a quarterly management fee. Due to the fact that Pinnacle may earn compensation from the Private Funds that may exceed the fee that the firm would earn under its standard advisory fee schedule (detailed in Item 5 below), the recommendation that a client become an investor in a Private Fund presents a conflict of interest. Clients are absolutely under no obligation to become an investor in any Private Fund. Pinnacle will devote its best efforts with respect to its management of both the Private Funds and its separately managed client accounts. The firm may give advice or take action with respect to the Private Funds that differs from that for other accounts that it manages. To the extent that a particular investment is suitable for both the Private Fund(s) and certain separately managed accounts, such investments will be allocated between the Private Fund(s) and the other accounts in a fair and equitable manner.