Pennsylvania Capital Management, Inc. (“PCM” or “the Firm”) is a SEC-registered investment adviser that was founded 1995. The principal owner of the Firm is Irvin G. Schorsch, III, President, and the Firm’s main office is located in Huntingdon Valley, Pennsylvania. PCM offers a wide range of services to its clients. In particular, clients look to PCM for guidance in the following areas:
• Investment Policy Formulation
• Asset Allocation Design and Analysis
• Investment Program Planning
• Investment Manager Analysis and Selection and/or Performance Analysis and Review
• Client Meetings and Reporting After PCM is able to assess the client’s financial situation, PCM will recommend to the client an implementation package that matches the client’s investment objectives with the investment objectives, style, and strengths of one or more independent money managers, publicly managed funds (i.e., mutual funds), or PCM will manage the client’s assets in-house. Investment Consulting Services Should the client choose independent money managers and/or public investment companies (mutual funds) for management of his/her assets, PCM will provide services on an investment consulting services basis (“Consulting Services”). The client will be charged a Consulting Services fee by PCM for the selection and monitoring services provided to the client. Fees will vary among clients and will be determined by such factors as portfolio manager mix, fees being paid by the client to the independent manager(s), the coordination of assets required, the frequency with which the client requests performance reports and meetings with PCM, the size of the account, and additional compensation anticipated to be received by PCM or its related persons related to the management of the account. A growing portion of PCM’s Consulting Services is providing investment consulting or education for companies and employees of companies offering pension plans such as 401(k) and 403(b) plans. PCM will receive a fee for the design, communication and assistance in the establishment of the administration services to be rendered to participants in these pension plans. Fees will be determined based upon such factors as the number of participants and the number of investment alternatives made available to the participants. PCM will not have discretion with respect to assets managed by an independent portfolio manager, however, on occasion, PCM may communicate on the client’s behalf with the independent portfolio manager regarding such matters as portfolio performance and stated account objectives. The client is not obligated to accept the recommendations of PCM. Should the client choose not to accept any of the recommendations of PCM, then the client will be billed on an hourly basis for the time expended by PCM in developing and formulating the recommended Investment Program. Investment Management Services PCM provides individualized investment advice to clients based upon the client's specific needs. Through personal consultations, PCM gathers specific financial data to develop a client’s personalized profile, which includes a client’s investment objectives, current financial position, risk profile, investment time horizon, tax situation and liquidity needs. PCM reviews the client's personalized profile and based upon this review, determines an appropriate asset allocation for the client. Such allocation takes into account the client's existing investments, liquidity needs, portfolio goals, tax objectives and risk tolerance. PCM then recommends any necessary re-positioning of a client’s investments or makes recommendations for new investments to implement the client's recommended asset allocation. This Investment Management Service is typically available for those who prefer the personal touch and the in-house capabilities of PCM staff members. Assets will be monitored on a continuous and ongoing basis and may be managed on a discretionary or non-discretionary basis, at the client’s option. Separately Managed Account Programs PCM may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated Separately Managed Account programs including those offered by Coho Partners, an unaffiliated investment adviser firm, in accordance with the client’s designated investment objective(s). In such situations, the Separately Managed Account Manager shall have day-to-day responsibility for the active discretionary management of the allocated assets. PCM shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which PCM shall consider in recommending Separately Managed Account programs include the client’s designated investment objective(s) as applied to the Separately Managed Account program: management style, performance, reputation, financial strength, reporting, pricing, and research. Tactical Asset Management In some cases, PCM and a client may determine that all or a portion of the client’s assets would be best managed pursuant to a discretionary tactical allocation strategy for fixed income securities or other appropriate investment products. In these cases, PCM will utilize the services of a third-party investment adviser who will provide buy and sell signals to PCM based on a technical methodology for trading high-yield bond mutual funds or other investment products. PCM will manage these accounts on a discretionary basis, and will use the information provided by the third-party adviser to determine an appropriate investment and trading strategy for a client’s investments. PCM will select the investment products that will be included in the trading strategy and will receive advice from a third-party manager as to the timing of buy and sell strategies. PCM will not be obligated to act upon the advice of the third-party manager for any given client account, nor will PCM be obligated to manage client’s assets in a manner consistent with the methodology or technical signals provided by the third-party investment adviser. PCM will compensate the third-party adviser for the technical advice given to PCM; therefore, tactical asset management may cost a client more than traditional asset management services provided by PCM. PCM has engaged Brian Carruthers & Associates, an unaffiliated registered investment adviser (“Carruthers”), to provide trading signals in connection with PCM’s Tactical Asset Management Services, as described above. Carruthers is not responsible for the trading of PCM clients’ assets. Instead, PCM may choose whether or not any guidance provided by Carruthers will be acted upon. Financial Planning and Other Services PCM may also provide to its clients financial, strategic, or tactical planning services which would be outside of the customary investment management services. These services may or may not include matters relating to securities and will be performed at a negotiated fixed fee or an hourly rate. A fixed fee will be determined after a preliminary review of Client's financial situation, and will be calculated based on such factors as the complexity of the services required by PCM in order to provide services to client, the number of client meetings anticipated, PCM staff involvement to provide services to client, and an estimation of the time to be expended on behalf of the client in meetings with client’s other advisors, such as accountants and attorneys. Private Investment Funds PCM may provide investment advice regarding unaffiliated private investment funds, including offerings managed by Norwich Partners of Florida, LLC (“Norwich Partners Offerings”). PCM’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of PCM calculating its investment advisory fee. PCM’s clients are under absolutely no obligation to consider or make an investment in any private investment fund(s), including Norwich Partners Offerings. Alternative Fees: Clients who elect to participate in Norwich Partners Offerings may enter into separate advisory agreements with PCM for each offering in which they agree to pay an alternative advisory fee. Private Fund Risk Factors: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that they are qualified for investment in the fund, and acknowledge and accept the various risk factors that are associated with such an investment. Private Fund Valuation: In the event that PCM references private investment funds owned by the client on any supplemental account reports prepared by PCM, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. The current value of any private investment fund could be significantly more or less than the original purchase price or the price reflected in any supplemental account report. General Information Regarding Investment Advice For any of the investment advisory services offered by PCM, the Firm does not limit its investment recommendations to any specific type of product or security. A client’s individual needs and objectives are analyzed to determine appropriate investments and products for the client. Since different types of investments typically involve different types of risk, the Firm conducts a risk analysis of the client and his/her overall portfolio, before recommending a certain investment or strategy. PCM manages assets on either a non-discretionary or discretionary basis. Either way, the client is always free to place restrictions on the types of investments the Firm recommends for the client’s portfolio. For non-discretionary investment management, the client may also decline to implement any of the recommendations made by the Firm. In general, the Firm utilizes equity investments in individual stocks, mutual funds, and exchange traded funds. PCM also provides recommendations on fixed income investments, including individual bond positions, bond mutual funds, certificates of deposit, and fixed income exchange traded funds. In addition, PCM provides advice related to real estate, leasing, or oil & gas limited partnerships, and may also provide advice on other products as appropriate for the specific client, including non-securities products. PCM may also provide clients with advice regarding covered options or other investment assets, such as art, antiques, real estate or other investment holdings. PCM may also recommend that clients purchase shares of private offerings of common stock, or may occasionally provide advice on Real Estate Investment Trusts (REITs). As part of its comprehensive approach to investment advisory services, PCM may refer clients to unaffiliated third-party service providers for specific areas for which a client may need advice. Examples of these referrals may include local CPAs or attorneys. PCM offers this referral service as a convenience to clients only, and any decision to engage a third-party service provider lies solely with the client. PCM is not responsible or liable for any of the services provided by these unaffiliated third-parties. PCM Automated Strategies To a limited extent, PCM may recommend that clients engage PCM to provide investment management services utilizing the Institutional Intelligent Portfolios™ Program, relative to investment accounts with market values of at least $5,000 under the PCM Automated Strategies (“PCMAS”). Institutional Intelligent Portfolios™, is an automated, online investment management platform for use by independent investment advisors offered by software provider Schwab Performance Technologies (“SPT”). Through PCMAS, we offer clients a range of investment strategies we have constructed and manage. The client’s portfolio is held in a brokerage account opened by the client at SPT’s affiliate, Charles Schwab & Co., Inc. (“CS&Co”). PCM is independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co or their affiliates (together, “Schwab”). PCM, and not Schwab, is the client’s investment advisor and primary point of contact with respect to PCMAS. PCM is solely responsible, and Schwab is not responsible, for determining the appropriateness of PCMAS for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. PCM has contracted with SPT to provide us with the technology platform and related trading and account management services for PCMAS. This platform enables us to make PCMAS available to clients online and includes a system that automates certain key parts of our investment process (the “System”). The System includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. PCM will work in concert with the client to develop the appropriate risk profile, time horizon and any relevant client priorities to determine the appropriate allocation utilizing the institutional intelligent portfolio program. The System also includes an automated investment engine through which PCM manages the client’s portfolio on an ongoing basis through automatic rebalancing and tax- loss harvesting (if the client is eligible and elects). PCM does not receive a portion of a wrap fee for our services to clients through PCMAS. Clients do not pay fees to SPT in connection with PCMAS, but PCM charges clients a fee for our services as described below under Item 5. PCM’s fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co as part of PCMAS. Schwab does receive other revenues in connection with PCMAS, which are described in the “Compensation to Schwab Under PCMAS” section below. PCM does not pay SPT fees for the Platform so long as it maintains $100 million in client assets in accounts at CS&Co that are not enrolled in PCMAS. If PCM does not meet this condition, then it must pay SPT an annual licensing fee of 0.10% of the value of its clients’ assets in PCMAS. This arrangement presents a conflict of interest, as it provides an incentive for PCM to recommend that clients maintain their accounts at CS&Co. Notwithstanding, PCM may generally recommend to its clients that they maintain investment management accounts at CS&Co. based on the considerations discussed in Item 12 below, which mitigates but does not eliminate this conflict of interest. Clients enrolled in PCMAS are limited in the universe of investment options available to them. For example, the investment options available are limited to ETFs or mutual funds; whereas, PCM recommends various other types of securities in its other services. PCMAS are designed to provide guidance and professional assistance to individuals who are beginning the process of accumulating wealth. Clients will have access to their accounts and a financial interface online but will also have the opportunity to confer with PCM on an ongoing basis with respect to their account. Rebalancing The System will rebalance a client’s account periodically by generating instructions to CS&Co. to buy and sell shares of funds and deposit or withdraw funds through the “Sweep Program”, considering the asset allocation for the client’s investment strategy. Rebalancing trade instructions can be generated by the System when (i) the percentage allocation of an asset class varies by a set parameter established by PCM, (ii) PCM decides to change asset allocation percentages for an investment strategy or (iii) PCM decides to change a client’s investment strategy, which could occur, for example, when a client makes changes to their investment profile or imposes or modifies restrictions on the management of their account. Sweep Program Each investment strategy involves a cash allocation (“Cash Allocation”) that will be held in a sweep program at Charles Schwab Bank (the “Sweep Program”). The Cash Allocation will be a minimum of 4% of an account’s value to be held in cash, and may be higher, depending on the investment strategy chosen for a client. The Cash Allocation will be accomplished through enrollment in the Sweep Program, a program sponsored by CS&Co. By enrolling in PCMAS, clients consent to having the free credit balances in their brokerage accounts at CS&Co. swept into deposit accounts (“Deposit Accounts”) at Charles Schwab Bank (“Schwab Bank”) through the Sweep Program. Schwab Bank is an FDIC-insured

depository institution that is a Schwab affiliate. The Sweep Program is a required feature of PCMAS. If the Deposit Account balances exceed the Cash Allocation for a client’s investment strategy, the excess over the rebalancing parameter will be used to purchase securities as part of rebalancing. If clients request cash withdrawals from their accounts, this likely will require the sale of fund positions in their accounts to bring their Cash Allocation in line with the target allocation for their chosen investment strategy. If those clients have taxable accounts, those sales may generate capital gains (or losses) for tax purposes. In accordance with an agreement with CS&Co., Schwab Bank has agreed to pay an interest rate to depositors participating in the Sweep Program that will be determined by reference to an index. Miscellaneous Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. As indicated above, to the extent requested by a client, PCM may provide financial planning and related consulting services. Neither PCM nor its investment adviser representatives assist clients with the implementation of any financial plan, unless they have agreed to do so in writing. PCM does not monitor a client’s financial plan unless engaged to do so, and it is the client’s responsibility to revisit the financial plan with PCM, if desired. Furthermore, although PCM may provide recommendations regarding non-investment related matters, such as estate planning, tax planning and insurance, PCM does not serve as an attorney or accountant, and no portion of its services should be construed as legal or accounting services. Accordingly, PCM does not prepare estate planning documents or tax returns. To the extent requested by a client, PCM may recommend the services of other professionals for certain non-investment implementation purpose (i.e., attorneys, accountants, insurance agents, etc.), including representatives of PCM in their separate individual capacities as licensed insurance agents. The client is under no obligation to engage the services of any such recommended professional and the client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from PCM and/or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not PCM, shall be responsible for the quality and competency of the services provided. Retirement Plan Rollovers – No Obligation / Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If PCM recommends that a client roll over their retirement plan assets into an account to be managed by PCM, such a recommendation creates a conflict of interest if PCM will earn new (or increase its current) compensation as a result of the rollover. If PCM provides a recommendation as to whether a client should engage in a rollover or not, PCM is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. No client is under any obligation to roll over retirement plan assets to an account managed by PCM, whether it is from an employer’s plan or an existing IRA. Non-Discretionary Service Limitations: Clients that determine to engage PCM on a non- discretionary investment advisory basis must be willing to accept that PCM cannot effect any account transactions without obtaining prior consent to any such transaction(s) from the client. Therefore, in the event that PCM would like to make a transaction for a client’s account, and client is unavailable, PCM will be unable to effect the account transaction (as it would for its discretionary clients) without first obtaining the client’s consent. Use of Mutual Funds / Exchange Traded Funds: While PCM may recommend allocating investment assets to mutual funds that are not available directly to the public, PCM may also recommend that clients allocate investment assets to publicly-available mutual funds and exchange traded funds that the client could obtain without engaging PCM as an investment adviser. However, if a client or prospective client determines to allocate investment assets to publicly-available mutual funds or exchange traded funds without engaging PCM as an investment advisor, the client or prospective client would not receive the benefit of PCM’s initial and ongoing investment advisory services. Interval Funds/Risks and Limitations: Where appropriate, PCM may utilize interval funds. An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Typically, the interval funds are not listed on any securities exchange and are not publicly traded. Therefore, there is no secondary market for the fund’s shares. Because these types of investments involve certain additional risk, these funds will only be utilized when consistent with a client’s investment objectives, individual situation, suitability, tolerance for risk and liquidity needs. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. In light of these enhanced risks, a client may direct PCM, in writing, not to employ any or all such strategies for the client’s account Portfolio Activity. PCM has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, PCM will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when PCM determines that changes to a client’s portfolio are neither necessary nor prudent. Clients nonetheless remain subject to the fees described in Item 5 below during periods of account inactivity. ByAllAccounts and eMoney. PCM, in conjunction with the services provided by ByAllAccounts, Inc. or eMoney Advisor, may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by PCM (the “Excluded Assets”). The client and/or their other advisor(s) that maintain trading authority, and not PCM, shall be exclusively responsible for the investment performance of the Excluded Assets. Unless otherwise specifically agreed to, in writing, PCM’s service relative to the Excluded Assets is limited to reporting only. The sole exception to the above shall be if PCM is specifically engaged to monitor and/or allocate the assets within the client’s 401(k) account maintained away at the custodian directed by the client’s employer. As such, except with respect to the client’s 401(k) account (if applicable), PCM does not maintain any trading authority for the Excluded Assets. Rather, the client and/or the client’s designated other investment professional(s) maintain supervision, monitoring and trading authority for the Excluded Assets. If PCM is asked to make a recommendation as to any Excluded Assets, the client is under absolutely no obligation to accept the recommendation, and PCM shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that PCM provide investment management services for the Excluded Assets, the client may engage PCM to do so pursuant to the terms and conditions of the agreement between PCM and the client. Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by PCM), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. PCM does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, PCM shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Cryptocurrency. For clients who want exposure to cryptocurrencies, including Bitcoin, PCM, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, PCM will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. PCM does not recommend or advocate the purchase of, or investment in, cryptocurrencies. PCM considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Cash Positions. PCM treats cash as an asset class. As such, all cash positions (money markets, etc.) shall be included as part of assets under management for purposes of calculating PCM’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), PCM may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, PCM’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion PCM shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless PCM reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a PCM actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any PCM unmanaged accounts. Client Obligations. In performing its services, PCM shall not be required to verify any information received from the client or from the client’s other designated professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify PCM if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising PCM’s previous recommendations and/or services. Cybersecurity Risk. The information technology systems and networks that PCM and its third-party service providers use to provide services to PCM’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in PCM’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and PCM are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although PCM has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that PCM does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Disclosure Statement: A copy of PCM’s written Brochure and Client Relationship Summary, as set forth on Part 2 of Form ADV and Form CRS respectively, shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. Assets Under Management As of December 31, 2023, PCM was providing regular and continuous Investment Management services for 1,048 accounts, and the total value of assets under management in these accounts was $511,474,625 on a discretionary basis and $167,183,803 on a non- discretionary basis).