PCM provides discretionary investment advisory services primarily for individuals, corporations, public and private pension plans, endowments, and foundations. Discretionary client portfolios may invest in equities, fixed income, open- or closed-end mutual funds, exchange-traded funds (ETFs) or a combination of the above, depending upon the PCM investment strategy selected by the client. A portion of the client’s portfolio may also be invested in short-term instruments (such as cash equivalents or money market funds) as a result of the normal buying and selling discipline in the portfolio management process (taking into account prevailing market conditions and the PCM investment strategy discipline). Discretionary clients deposit account assets with their selected custodian and then they typically work with their financial consultant to determine an investment strategy based on personal circumstances, objectives, and risk tolerance. Clients choosing PCM to provide investment advisory services sign an investment advisory agreement giving PCM the authorization to effect security transactions on behalf of their portfolio. Portfolio Managers at PCM provide investment advice specific to assets placed under management and the strategy selected. Within the Investment Management Agreement, the client must provide specific financial information as well as their desired investment strategy. PCM permits discretionary clients to impose restrictions on the types of securities purchased for their accounts. The discretionary portfolios are individually managed and monitored based on subjective and objective analysis of fundamental and technical factors. In addition, cyclical analysis is used to determine what may appear to be appropriate investments based upon economic and industry business cycles. Account positions are monitored continuously and portfolio changes are made as deemed appropriate. Because accounts are managed individually, portfolios with the same or similar investment objectives may differ as to securities held and performance achieved. In some cases, PCM has been retained as an investment manager under a so-called "wrap-fee" arrangement for separately managed account programs sponsored by certain unaffiliated broker-dealers (the "Program Sponsors"). Under such wrap-fee arrangements, Program Sponsors may recommend that a client retain PCM as an investment advisor, pay investment advisory fees on behalf of the client (a percentage of which are shared with PCM as compensation for its services), monitor and evaluate PCM’s performance, execute the client's portfolio transaction without commission charge, and provide custodial services for the client's assets, all for a single fee paid by the client to the Program Sponsor. Wrap-fee arrangements generally involve the client entering into an investment advisory agreement with the Program Sponsor while PCM enters into a sub-advisory agreement with the Program Sponsor. The wrap programs and the sponsor in which PCM currently provides services are: Masters Investment Consulting Services (Masters) and Diversified Managed Allocations (DMA) through Wells Fargo Advisors, LLC. For more information regarding

any of the wrap-fee programs offered by any of the Program Sponsors in which PCM participates, please see Schedule D of each Program Sponsor's Form ADV Part 1A as well as Appendix 1 of their Form ADV Part 2A. PCM manages wrap-fee clients in the same manner that it manages non-wrap-fee clients. In addition, PCM has entered into agreements with other financial firms (Model Program Sponsors) to provide model portfolio investment recommendations. These Model Program Sponsors use the information supplied by PCM to provide investment management services to their clients. The Model Program Sponsors retain discretion to accept, modify, or reject PCM’s recommendations and are responsible for executing any trades. The Model Program Sponsors’ clients are not PCM clients. PCM is not responsible for certain functions typically completed by or with a broker-dealer/custodian, (i.e., calculation of required minimum distribution, referring of other financial solutions such as life insurance, annuities, other financial planning, etc., processing of deposits and withdrawals, wiring of funds, custodial address-of-record changes, calculation of breakpoint discounts for mutual fund investments, tax reporting, initial selection of money market funds, asset allocation studies, SIPC or account protection coverage, etc.); this list is in no way meant to be all- encompassing. Clients should review the financial stability and insurance carried by their chosen custodian. PCM carries no liability for any loss resulting from any financial instability, insolvency of the custodian, or acts of the employees of the custodian. Insurance carried by the custodian may or may not provide full protection for losses. Clients should contact their financial consultant with questions regarding their custodian. PCM does not offer or provide tax, legal, or accounting advice, nor is PCM responsible for tax reporting for clients. Dividends, interest, and capital gains generated in a Client's account may be subject to taxation. Implementation of, or a change to the investment strategy may create a taxable event for the client. Cost basis (as provided by the client) information provided in PCM's quarterly reports (as applicable) is provided for information purposes only and should not be used for tax preparation. All tax or legal related inquiries should be directed to a qualified tax professional or legal counsel. Clients should always deposit securities or funds directly with their respective custodians, not with PCM. PCM, formerly Ken Roberts Investment Management, Inc., was founded in 1991 and became registered with the SEC as an investment adviser in 1994, is currently owned by Christopher K. Hicks. As of December 31, 2023, PCM managed approximately $228,612,821 in discretionary assets on behalf of approximately 572 accounts. In addition, the assets that participated in the previously described Model Programs as of December 31, 2023, were approximately $55,490,108 in assets on behalf of approximately 240 accounts. For the Model Programs, PCM only offers investment recommendations and has no control over the implementation of investment decisions or trading authority for these assets.