Pittenger & Anderson, Inc. (herein referred to as P&A in this document) is a SEC-registered investment adviser with its principal place of business located in Lincoln, Nebraska. Pittenger & Anderson, Inc. began conducting business in 1995. P&A is a Registered Investment Advisor offering investment management services as well as financial planning. Registered Investment Advisors are regulated under the Investment Advisers Act of 1940 and are governed by the Securities and Exchange Commission (SEC). P&A is held to the fiduciary standard of care, which requires us to act in our Clients’ best interests at all times. Our business model is fee-only and fully transparent. We are not compensated through commissions, sales charges, 12b-1 fees, management fees, or revenue sharing. Managing investment portfolios and providing unbiased advice is the largest part of our business. Clients hire us with an assortment of goals and objectives. Risk tolerances are personal and have to be reflected in each asset allocation. Therefore, we manage for client results first and performance second. Listed below are the firm's principal shareholders (i.e. those individuals and/or entities controlling 25% or more of this company):  James Skaggs Pittenger, Jr., Chairman/CEO  Daniel Lynn Anderson, President Jim and Dan both began their careers at bank investment departments, where they were responsible for government and municipal bond trading, underwriting and institutional sales. Their duties expanded to include equities, corporate bonds, and mutual funds at Dean Witter. The investment strategies employed by P&A are an extension of the lessons schooled by the banks and the brokerage industry. The two principals have been friends since 1975. Pittenger & Anderson, Inc. offers the following advisory services to our clients: Individual Portfolio Management P&A provides continuous advice to clients regarding the investment of funds based on individual needs. These accounts are individual, joint, IRAs, trusts, partnerships, corporations, etc. The kinds of accounts necessary to run family assets, businesses and public monies. As compensation for these services each portfolio is charged an Individual Portfolio Management Fee (IPMF) based on assets under management. All portfolio styles have their own set of virtues but are subject to differential pricing as described in item 5. P&A makes every effort to minimize conflicts of interest created by these price differences. It is our policy to be completely transparent and forth coming. We encourage all clients to vet these situations thoroughly and familiarize themselves with style differences. To that end P&A will offer unbiased counsel. All clients have their own set of priorities, cost is not always number one. Our contract provides a basic investment policy statement for each client which is continuously amended and updated using our CRM software. Each client relationship is cultivated through a data-gathering process that identifies and updates goals, objectives, time horizons, risk tolerance and liquidity requirements. As appropriate, we review and discuss a client's prior investment history, as well as family composition and background. This process never stops. All of our client accounts are structured using a core and satellite format. The equity portion of each account is constructed using large cap stocks and funds which tend to be more passive than the satellite holdings. The equity satellite stocks and funds are more esoteric and address market sectors that are a bit more difficult to gain exposure to: mid cap, small cap, foreign, alternative assets, etc. The fixed income portion of our accounts follow a similar structure with the core holdings consisting of fairly passive investment grade bonds. The fixed income satellites are again, more esoteric: high yield, foreign, mortgage-backed, etc. As both equity and fixed income portfolios grow, the satellites can acquire satellites of their own. Our core and satellite structure is indigenous and the product of parallel discovery. The P&A investment management and financial planning contract allows us to address all of our account responsibilities with full discretion. P&A does not manage real estate, collectables or natural resources. Stock and bond portfolio management:  Custom Equity: The most aggressive, personalized and client centric of our management styles, Custom Equity portfolios emphasize growth, but don't avoid income…..100% equity/0% fixed. These portfolios are dominated by common stocks with market caps of $4 billion or greater and by design generate more volatility than our mutual fund and ETF styles. To achieve portfolio completion, risk management, reduce concentration risks or address esoteric sectors, we will employ mutual funds or ETFs. Fixed income investments will appear in these accounts at the discretion of the investment committee. These accounts are subject to our Equity & Balanced Account IPMF schedule.  Fixed Income: The most conservative of our management styles, Fixed Income portfolios emphasize income and preservation of principal….0% equity/100% fixed. All securities employed are investment grade or equivalent in the eyes of the principals. Again, mutual funds may be employed. Our client's tax profile dictates the use of taxable or tax-free bonds. These portfolios are generally constructed with laddered maturities, but may employ a dumbbell structure as their size increases. Fixed income accounts are subject to our Equity & Balanced account IPMF schedule.  Balanced: Our most popular style, Balanced Accounts are a combination of our Custom Equity accounts and Fixed Income portfolios….client % equity/client % fixed. The aggressiveness of these accounts is determined by an asset allocation tailored to each client. Taxable or tax-free bonds are used depending on the client's specific tax profile. These accounts are subject to our Equity & Balanced account IPMF schedule. Mutual fund portfolio management: The advent of self-directed retirement accounts has spawned a generation of investors who have learned to trust and prefer mutual funds as an investment vehicle. This asset class has an appeal to smaller accounts, rapidly growing accounts, accounts seeking passive management, accounts seeking diversification by management style and those investors seeking to extend their money management skills learned as 401k participants. Accounts with at least 75% of their equity assets invested in mutual funds are eligible for the Mutual Funds/ETF IPMF schedule. P&A offers two different styles of model portfolio management which are further broken down by size and asset allocation. Our model portfolios combine state-of-the-art technology with a hands on approach that allows our clients to fulfill their investment needs using the mutual funds and ETFs they have learned to trust. The “Fireball” model offers no load mutual fund exposure while “Cannonball” portfolios are comprised of exchange traded funds (ETFs.) Both employ licensed software products that allow our investment committee to build and continually rebalance economical and scalable portfolios. Although all “Fireball” and “Cannonball” portfolios are reviewed and rebalanced no less than semi- annually, one of the strongest attributes of these models is their ability to accept contributions and generate distributions of any size and frequency on demand….while being rebalanced at every event, maintaining P&A pro forma.  100% Equity, $1,000-$50,000: Generally contains a blend of domestic large-cap, mid-cap, small-cap and foreign mutual funds and/or ETFs.
 100% Equity, $50,000+: Generally contains a blend of domestic large-cap, mid-cap, small cap, foreign and specialty mutual funds and/or ETFs.
 75% Equity/25% Fixed, $1,000-$67,000: Generally contains a blend of domestic large-cap, mid-cap, small-cap, foreign and fixed income mutual funds and/or ETFs. May contain  75% Equity/25% Fixed, $67,000+: Generally contains a blend of domestic large-cap, mid- cap, small-cap, foreign, specialty, and fixed income mutual funds and/or ETFs. May contain  60% Equity/40% Fixed, $1,000-$83,000: Generally contains a blend of domestic large-cap, mid-cap, small-cap, foreign, and fixed income mutual funds and/or ETFs. May contain  60% Equity/40% Fixed, $83,000+: Generally contains a blend of domestic large-cap, mid- cap, small-cap, foreign, specialty, and fixed income mutual funds and/or ETFs. May contain Diversification in these accounts is achieved by using P&A researched mutual funds and/or ETFs. It is common for research vendors in our industry to disagree on the classification of growth, value and balanced funds. We have learned to be content with our own opinions. Bandwidths on these types of accounts may differ per Client request. Qualified Plans P&A is in the business of managing qualified plans. These accounts are very esoteric and require expertise

as well as ancillary services in order to fulfill their roles as described in Section 401(a) of the tax code. To that end, it is common for P&A to partner with Third-Party Plan Administrators (TPAs), such as The Standard, who are hired by the plan sponsors (typically employers) to provide for many of the plan’s day-to-day responsibilities. These functions include but are not limited to, preparation of benefit statements, processing distributions, testing for non-discrimination compliance, monitoring participant contribution limits, allocating employer contributions, forfeitures and calculating vesting. TPAs also provide administrative services, including notices and enrollment materials and can be engaged to assume the plans’ ERISA 3(16) Delegated Administrative Fiduciary Services. All TPA fees are paid by and disclosed to the plan. When acting as investment manager to the plan, P&A provides TPA, actuarial and accounting collaboration, meetings with company owners, education sessions, counsel on core fund line up and monitoring. For these services and others negotiated P&A is paid a level percentage Qualified Plan Management Fee (QPMF.) When hired as an independent portfolio manager by any of the participants, the QPMF is integrated with the appropriate P&A management fee schedule. Donor Advised Funds P&A is in the business of managing the assets of certain Donor Advised Funds (DAF.) The qualifications of the manager and the minimum size of the accounts is determined and monitored by the DAF custodian, currently Schwab and Fidelity. When hired as an independent portfolio manager by a DAF participant, the assets are managed to client asset allocations and subject to the Mutual Fund/ ETF fee schedule, in addition to the custodian’s fee. Charities, Foundations and Public Funds P&A uses the techniques and tools described in Individual Portfolio Management to build portfolios for this category of client. Charities and foundations are rarely homogeneous and tend to have health related, scientific, educational, cultural, social, or other charitable purposes. Most hold 501c 3 tax exemptions and are managed by appointed or elected boards with a specific mission statement. The public funds category is typified by reserve funds, surplus accounts and defined purpose assets owned by political subdivisions. Examples include but are not limited to cemeteries, fire protection districts, natural resource districts, etc. Once again, these are tax exempt entities. All 3 of these entities typically solicit portfolio managers using a Request for Proposal format (RFP.) P&A is asked to submit proposals like this from time to time. Most typically after being referred by a client, board member or board members of other entities where we are currently employed. These accounts are not full service, they do not expect financial planning, philanthropic council, educational planning, lending council, etc. Tenure with these accounts is often mitigated by a reoccurring RFP cycle, most often 5 years. P&A generally considers servicing accounts in this category to be a method of “giving back”…. serving the public good. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients requesting this service receive a written report which provides the client with a detailed financial plan designed to assist the client to achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas: Retirement Planning, Investment Planning, Insurance Consulting, Education Planning, and Estate Planning. However, there may be instances where matters are beyond the scope of P&A's area of expertise. P&A reserves the right to decline to provide advice to Client about issues and topics outside its area of expertise. At Client's request, P&A may provide recommendations to Client as to other sources of professional advice to address such matters. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically the financial plan is presented to the client within a month of the engagement date, provided that all information needed to prepare the financial plan has been promptly provided. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All recommendations are of a generic nature. General Information Regarding Our Advisory Business Through personal discussions with the client, financial goals and objectives are established. These interviews along with the IPS in our contract are used to determine a suitable management style to recommend for the client's circumstances. P&A allows clients the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. Our investment recommendations are not limited to any specific product or service offered by a broker dealer or insurance company and will generally include advice regarding the following securities:  Exchange-listed securities  Securities traded over-the-counter  Foreign issuers  Warrants  Corporate debt securities (other than commercial paper)  Commercial paper  Certificates of deposit  Municipal securities  Mutual fund shares  United States governmental securities  Interests in partnerships investing in real estate  Interests in partnerships investing in oil and gas interests  Other - P&A may offer advice on other investments such as mortgage-backed securities, unit investment trusts or investments offered by insurance companies. We will from time to time use indexed derivatives and tracking stocks.
 Interests in partnerships investing in illiquids - This reference allows us the flexibility of counseling on the advisability of maintaining or liquidating assets not easily converted to cash. P&A's advice would be appropriate for client goals and objectives given our knowledge, portfolio management expertise and financial planning experience. We generally do not recommend initiating positions in these types of securities.
Because some types of investments involve additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity, and suitability. To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: 1. be guided by the Client's Investment Policy Statement that is accepted and signed by both Pittenger & Anderson, Inc. and the Client. P&A is granted full discretion when managing investment accounts. We will adjust asset allocations within the +/- 10% asset allocation variance described in our contract, based on known and projected changes in risk tolerance as well as goals and objectives. These events will be discussed directly with the client or by written portfolio reviews, based on client preferences. P&A often uses a negative response format to expedite the flow of information. Clients will be responsible for reviewing any changes for correctness and have agreed by contract that communication is a shared responsibility. Periodic reports will also provide updates to our current investment management styles.
2. at least annually, contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; 3. be reasonably available to consult with the client; and 4. maintain client suitability information in each client's file.
AMOUNT OF MANAGED ASSETS As of 11/30/2023, we were actively managing $2,479,436,893 of client assets on a discretionary basis.