About the Firm Established in 1995, Pinnacle Investments is registered as a broker-dealer and investment adviser with the Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority, Inc. (“FINRA”) and Securities Investor Protection Corporation (“SIPC”). As of December 31, 2023, Pinnacle Investments had regulatory assets under management of $964,888,091, of which $4,976,913 was managed on a non-discretionary basis and $959,911,178 was managed on a discretionary basis. Pinnacle Investments is 100% owned by Pinnacle Holding Company, LLC which is organized as a limited liability company. There are no individual owners of 25% or more of Pinnacle Holding Company, LLC. FKAPI, Inc., a domestic entity, owns 25% or more of Pinnacle Holding Company, LLC. Pinnacle Investments in conjunction with our Investment Adviser Representatives ("Pinnacle IAR") offers the following advisory services: financial planning, portfolio management both on a discretionary and non-discretionary basis, selection of other advisers, wrap fee programs, investment advisory service, and investment advice through consultation not included in aforementioned services. These services are conducted on a case-by-case basis. Understanding Your Needs Our advisory programs all begin with an initial meeting designed to better understand your unique needs and objectives. Meetings may be done in a number of ways, including, in person, over the phone, by video conferencing or other electronic means. The investment programs that we recommend to you are based largely upon the personal information that you provide to us. In order for us to provide appropriate investment advice, or in the case of discretionary accounts, make appropriate investment decisions, it is important that you provide accurate and complete responses to our questions regarding your financial condition, investment objectives and personal circumstances, along with any reasonable investment restrictions that you may wish to place on the management of your account. Investment advisory services are tailored to meet the individual needs of the client. The Firm offers four managed account platforms as more fully described below: I. AdvisorPro We sponsor the AdvisorPro asset management program. In AdvisorPro, you will work with an Investment Adviser Representative (“IAR”) to discuss your unique investment goals and objectives. Your IAR will discuss different potential strategies to achieve your goals. Your IAR will also recommend various investment products designed to achieve your stated objectives. Your IAR will manage your investments on a discretionary basis, meaning they can select to purchase and/or sell investments without your prior consent. IARs may develop specific investment strategies using a mix of analytic methods. Such strategies ordinarily include long-term and short-term securities purchases and, depending on your objectives and the IAR’s investment philosophy, supplemental covered option writing in addition to the long positions of calls and/or puts. In special circumstances, the strategies may also include margin transactions, other option strategies and trading or short- sale transactions. Due to any number of factors, including timing of deposits, investment selection process or investment needs, certain clients may receive different execution prices and investment results. AdvisorPro is available to Pinnacle Investments’ clients for accounts custodied at First Clearing or Charles Schwab. IARs are able to establish accounts at either custodian. Pinnacle Investments feels First Clearing and Schwab are similar in cost however each custodian has different transaction costs, and as those costs are paid by you, it may be possible that one custodian may be more or less expensive than another custodian given your particular investment strategy or products being purchased or sold. It is important to understand the differences in cost between each custodian. This information can be found in Item 5, fees and compensation. To help mitigate this risk, we review and approve all accounts prior to being established as well as conduct a review of advisory accounts on a periodic basis. Please refer to Item 13, review of accounts for additional information. Pinnacle Investments, LLC - Firm Brochure - 5 - ver.3.29.2024 a. Charles Schwab & Co., Inc. (Schwab): AdvisorPro, mentioned above, is offered to Pinnacle Investments’ clients with accounts custodied at Charles Schwab. In addition to the description below, please see the description of AdvisorPro above. Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like ours. They provide the Firm and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis, at no charge to advisors. Services that Benefit Client Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: - provides access to client account data (such as duplicate trade confirmations and account statements); - facilitates trade execution and allocate aggregated trade orders for multiple client accounts; - provides pricing and other market data; - facilitates payment of our fees from our clients’ accounts; and - assists with back-office functions, recordkeeping and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: - educational conferences and events - technology, compliance, legal, and business consulting; - publications and conferences on practice management and business succession; and - access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through Schwab, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons. b. First Clearing AdvisorPro, mentioned above, is offered to Pinnacle Investments’ clients with accounts custodied at First Clearing. In addition to the description below, please see the description of AdvisorPro above. First Clearing is the trade name used by Wells Fargo Clearing Services, LLC, a registered broker-dealer and non- bank affiliate of Wells Fargo & Company. Services that Benefit the Client First Clearing services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through First Clearing include some to which we Pinnacle Investments, LLC - Firm Brochure - 6 - ver.3.29.2024 might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. The services described in this paragraph generally benefit clients or their account(s). Services that May Not Directly Benefit Clients First Clearing also makes available to us other products and services that benefit us but may not directly benefit the client or their account(s). These products and services assist us in managing and administering our clients’ accounts. They include investment research, both First Clearing’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at First Clearing. In addition to investment research, First Clearing also makes available software and other technology that: - provides access to client account data (such as duplicate trade confirmations and account statements); - facilitates trade execution and allocate aggregated trade orders for multiple client accounts; - provides pricing and other market data; - facilitates payment of our fees from our clients’ accounts; and - assists with back-office functions, recordkeeping and client reporting. Analytical and Portfolio reporting (not available in Schwab) First Clearing also offers other services intended to help us manage and further develop our business enterprise. These services include: - educational conferences and events - technology, compliance, legal, and business consulting; - publications and conferences on practice management and business succession; and - access to employee benefits providers, human capital consultants and insurance providers. First Clearing may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. First Clearing may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Irrespective of direct or indirect benefits to our client through First Clearing, we strive to enhance the client’s experience, help reach their goals and put their interests before that of our firm or its associated persons. II. Pinnacle Capital Management Pinnacle Capital Management, LLC (“PCM") was founded in August 2006 and is a wholly owned subsidiary of Pinnacle Holding Company, LLC. Pinnacle Holding Company, LLC. Is also the parent company of Pinnacle Investments, LLC. PCM is organized as a Delaware limited liability company. Due to both firms being under common control, there is a conflict of interest that exists whenever a PCM program is recommended over other programs. To mitigate this conflict, the Firm’s supervisory personnel review all PCM accounts prior to being established to ensure they meet the stated investment objectives and goals of our clients. PCM provides investment supervisory services and offers advice

on: - equity securities (exchange-listed securities, securities traded over the counter, foreign issuers) - corporate debt securities - commercial paper - certificates of deposit (bank CDs) - municipal securities - investment company securities (mutual fund shares) - hedge funds - United States government securities - options contracts on securities - interests in partnerships investing in real estate - asset backed securities (ABS) including but not limited to residential real estate mortgage-backed securities (MBSs), collateralized loan obligations (CLOs), commercial mortgage-backed securities (CMBSs), and ABS backed by credit card receivables, auto loans, and equipment leases, - private placement equity securities and/or debt securities. Pinnacle Investments, LLC - Firm Brochure - 7 - ver.3.29.2024 PCM offers advisory services and sub-advisory services, where appropriate, to individuals, pension and profit- sharing plans, trusts, estates, charitable organizations, investment companies, hedge funds, corporations, insurance companies and other business entities. PCM provides advice to clients regarding investment of assets based on the individual needs of the client. Client investment objectives, risk tolerances and time horizon are established at the beginning of each client relationship and updated as client needs change. If desired, PCM will assist clients in developing a personal investment policy and create and manage a portfolio based on that policy. PCM will manage advisory accounts on either a discretionary or non-discretionary basis. Account supervision is guided by the stated objectives of each client. PCM will create a portfolio, or advise on the creation of a portfolio, consisting primarily of individual equities, exchange traded funds, mutual funds, hedge funds, fixed income securities and cash equivalents (e.g., money market funds). PCM will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. The mutual funds, hedge funds and exchange traded funds will be selected based upon any or all of the following criteria: the fund's performance history; the industry or geographic sector in which the fund invests; the track record of the fund's manager; the fund's investment objectives; the fund's management style and philosophy; and the fund's management fee structure. Portfolio weighting between funds and market sectors will be determined by the investment style selected based on each client's individual needs and circumstances. Clients will have the opportunity to place reasonable restrictions on the types of investments which will be made on the client's behalf. Clients will retain individual ownership of all securities. As appropriate, PCM may engage in margin transactions or option writing for client accounts. As these strategies involve additional risks, they will only be recommended when consistent with the client’s stated risk tolerance. PCM acts as a portfolio manager for the advisory programs discussed below with trades executed through the sponsor of the program. This form of directed brokerage may result in trading costs and execution services that are not as advantageous to the client as when PCM seeks “best execution.” PCM receives a portion of the advisory fee for its portfolio management services. PCM provides portfolio management services in the Pinnacle Investments’ AdvisorPro Program. PCM AdvisorPro is an advisory program where Pinnacle Investments, a dually registered firm affiliated with PCM through common ownership and control, acts as adviser. PCM is the sub-adviser responsible for portfolio management services within the program. As part of its portfolio management services, depending on the version of the PCM managed account instruction form, PCM may vote proxies on behalf of participants. PCM is compensated by Pinnacle Investments for providing portfolio management services for clients participating in the PCM AdvisorPro program by receiving a portion of the advisory fee collected from the client. Participants in PCM AdvisorPro are clients of Pinnacle Investments and not advisory clients of PCM. Pinnacle Investments is responsible for assisting clients in understanding the PCM AdvisorPro program in light of the client’s investment objectives and financial situation – initially and on an ongoing basis. Pinnacle Investments is also responsible for client communication, portfolio reviews, client services, account maintenance and communicating client portfolio strategy changes to PCM. PCM manages client portfolios in accordance with the portfolio strategy selected on the PCM managed account instruction form subject to written restrictions and does not act in any other capacity. PCM accounts can be custodied with either First Clearing or Schwab. Refer to section on First Clearing and Schwab above for additional information. PCM may have different pricing structures for the portfolios that they manage. While the pricing does not directly impact the total advisory fee that you pay, because of the pricing disparity, your IAR may have a conflict in choosing one manager over another due to the different costs. We mitigate this conflict by reviewing all advisory accounts, including manager selection, when the account is opened. Pinnacle Investments, LLC - Firm Brochure - 8 - ver.3.29.2024 III. Wrap-Fee Programs The Firm offers a wrap fee program to our current and prospective clients. A wrap fee account is an “all inclusive” account that takes all of the investment advice and transaction costs and bundles them together and you therefore only pay one fee for the management of your account. The Firm receives a portion of the wrap fee charged for our services. Depending on the number of transactions that occur in the account, this structure may be more or less financially beneficial to you. The wrap fee programs are described in a separate Wrap Fee Brochure and will be provided to current and prospective clients. IV. Financial Planning Services While there is no statutory definition of financial planning, the Firm has adopted the CFP’s Board definition of financial planning which states: “Financial Planning is an ongoing collaborative process that helps maximize a client’s potential for meeting life goals through Financial Advice that integrates all relevant elements of the Client’s personal and financial circumstances. Pinnacle Investments considers “holistic” Financial Planning to be a separate professional activity from investment advice and portfolio management.” A financial plan aims to provide an overview of a client’s financial well-being. However, a holistic financial plan is tailored to the individual client and their unique needs. While there are common components that may be found in most financial plans, given the uniqueness of each financial plan, some may include more or fewer components. Some of the common elements may include but are not limited to: A. Ongoing collaborative process B. Management of assets & liabilities C. Cash flow management D. Risk identification and management E. Identify and manage the financial effect of health considerations F. Provide for educational needs G. Achieve financial security H. Preserve and/or increase wealth I. Identify tax considerations J. Prepare for retirement K. Project income during retirement years L. Pursue philanthropic interests M. Address estate and legacy matters When creating a financial plan for a client, the Firm and its IARs fulfill our fiduciary responsibilities by putting our clients interest ahead of the Firm and/or IARs. In creating a financial plan, we will use various third-party software tools. These tools allow us to collect certain information about your goals, needs, and objectives and then to create actionable plans to reach your goals. The Firm only allows third party software tools to be used that have been reviewed and approved by the Firm to be used for Financial Planning clients. Pinnacle IARs must be approved by the Firm to offer financial planning services prior to engaging in these services with current or prospective clients. The IAR is also required to successfully complete firm sponsored training. There are two main deliverables in providing financial planning activities: plan delivery and implementation of recommendations. 1. Plan Delivery The delivery of the financial plan is a crucial step in the financial planning process. Upon entering all key variables of a client’s financial situation, and taking into account your specific goals and objectives, a financial planning document will be provided to the client. 2. Implementation of Financial Plan The IAR will discuss the contents of the financial plan with you. Part of that discussion will include discussing any assumptions used in the planning process, potential shortfalls that you may experience in reaching your goals, areas of concern, and recommendations to help you achieve your goals and objectives. Pinnacle Investments, LLC - Firm Brochure - 9 - ver.3.29.2024 Financial Planning Fees – Each financial plan is developed after carefully discussing with you your needs, objectives, and financial goals. Because of the uniqueness of each plan, financial planning fees may range widely. Factors such as scope of services, complexity of financial situation and geographic location all play an important role in determining the financial planning fees. In general, the Firm’s financial planning fees will range from $300 - $5,000. Mutual Funds and Exchange-Traded Funds (“ETF”) in Advisory Programs Mutual fund companies typically offer multiple share classes of each of their mutual funds with varying levels of fees and expenses. Mutual funds or share classes offered through our advisory Programs are not necessarily the least expensive. Investing in mutual funds will generally be more expensive than other investment options available in your advisory account, such as ETFs. In addition to the Program fee, you will also bear a proportionate share of each fund’s expenses, including investment management fees that are paid to the fund’s investment adviser. These expenses are an additional expense to you and not covered by the Program fee; rather, they are embedded in the price of the fund. You should carefully consider these underlying expenses, in addition to the Program fees, when considering any advisory Program and the total compensation we receive. Other funds and share classes may have different charges, fees, and expenses, which may be lower than the charges, fees, and expenses of the funds and share classes made available in the Program. An investor who holds a less expensive share class of a fund will pay lower fees over time – and may earn higher investment returns - than an investor who holds a more expensive share class of the same fund. In accounts held at First Clearing, Pinnacle Investments credits 12b-1 fee payments received back to all Pinnacle Investment AdvisorPro accounts. 12b-1 fees received by Pinnacle Investments will be credited back to client accounts within 95 days unless the position is excluded from advisory billing.