A. Pactolus Private Wealth Management, LLC Pactolus Private Wealth Management, LLC dba Pactolus (“Pactolus” and/or the “firm”), is organized as a Delaware limited liability company and is principally owned by Pactolus Holdings, LLC (“PH”). Alan Harter is the Managing Member of Pactolus, which is an investment adviser offering fee-based personalized family office advisory services to a select group of families and individuals, high-net-worth individuals, related trusts, charitable entities, investment companies, corporations, and other business entities. Pactolus has been providing services since January 2011. B. Advisory Services Offered Pactolus’s advisory services may include financial planning, investment strategy, portfolio management, estate planning, financial administration, and project consulting. Pactolus has four primary service offerings, which include: ▪ Financial Planning & Administration ▪ Investment Advisory ▪ Investment-Related Tax Planning ▪ Concierge Financial Planning & Administration Services The client will receive a written or oral report (depending on the client’s preference) that provides a detailed financial plan designed to help achieve the client’s stated financial goals and objectives. Based on the client’s needs, financial planning services may include (but are not limited to) the following: ▪ Preparation of a consolidated assessment of financial condition, which may include:
• annual budgeting
• cash flow monitoring
• account reconciliations
• personal financial statement preparation
• debt management ▪ Establishment of objectives over relevant time frames, which may include:
• retirement objectives
• philanthropy
• estate planning
• wealth transition
• other related issues ▪ Preparation of a recommended asset allocation that serves to diversify the client's portfolio among different categories of investments, such as:
• Stocks, ETFs and Mutual Funds
• Corporate and government fixed income (short-, intermediate-, and long-term maturities)
• Developed international and emerging market securities (i.e., foreign issuers)
• Such other asset categories that are suitable in light of the client's investment goals, objectives, and risk tolerance ▪ Risk analysis stress testing to meet the needs of the client, taking into account family, business, and other financial objectives of the client. ▪ Liability management, which entails creating a portfolio of assets that can be appropriately matched as to liquidity, timing, and safety to retire liabilities at applicable due dates. ▪ In coordination with the client’s team of specialized advisors (estate attorneys, CPAs, etc.), Pactolus may prepare an estate plan to ensure wealth transition, tax, and related issues are met in accordance with the client's wishes. In many instances, Pactolus may need to refer clients to outside counsel if they do not have a relationship with the requisite expert (accountant, attorney, etc.) needed to create a plan and draft documents pertaining to one or more of the following planning services as well as others that may be needed:
• Estate planning
• Estate administration
• Charitable/philanthropic planning
• Advice on wills and trust agreements
• Business succession planning
• Retirement and distribution planning Pactolus gathers required information through in-depth personal interviews. Information gathered includes the client's current financial status, investment objectives, future goals, and attitudes toward risk. Related documents supplied by the client are carefully reviewed, and a report may be prepared covering one or more of the above-mentioned topics as directed by the client. Financial planning and administrative services may be offered on a stand-alone basis. Investment Advisory Services Pactolus provides clients with multi-family office advisory services, which includes holistic balance sheet management when applicable. The investment advisory service provided by Pactolus may include an allocation to traditional investments such as stocks, bonds, mutual funds, exchange traded funds, separately managed accounts, etc., and may include an allocation to alternative investments such as private equity, hard money lending, hedge funds, precious metals, etc. Should Pactolus encounter a client need that is outside the scope of our expertise, we may engage the assistance of outside counsel. For example, if we are reviewing private equity opportunities in commercial real estate, Pactolus may seek additional guidance from experts with experience specific to the market opportunity being reviewed. Resulting from our due diligence review, we may identify situations where our client would benefit from an introduction to other Pactolus clients or outside advisors, which we may facilitate upon receiving permission from the respective parties. Further, Pactolus may encounter situations where specific clients may be interested in participating in “Club Deals.” Pactolus will assist clients in the due diligence process of reviewing and executing specific opportunities that may arise. In addition to providing Pactolus with information regarding their personal financial circumstances, investment objectives and tolerance for risk, clients are required to provide the firm with any reasonable investment restrictions that should be imposed on the management of their portfolio, and to promptly notify the firm of any changes in such restrictions or in the client's personal financial circumstances, investment objectives, goals and tolerance for risk. Pactolus speaks with clients at least annually to discuss the client’s financial situation and determine whether there have been any changes in a client's personal financial circumstances, investment objectives

and tolerance for risk. Tax Planning Services Pactolus will provide assistance and work with clients’ tax specialists in helping structure investment strategies that are designed to maximize after-tax returns and to otherwise ensure optimal tax efficiency. These services may include the following: ▪ Annual tax planning (with tax advisor) ▪ Harvesting investment gains or losses for tax efficiency ▪ Estate and fiduciary tax planning ▪ Tax planning for client’s charitable foundation Concierge Services Pactolus may provide one or more of the following concierge services as mutually agreed upon with the client. Pactolus provides assistance to the client and coordinates the activities enumerated below with the client and any third parties, specialists, or contractors hired by the client. Pactolus may engage a third-party service provider to provide certain services requested by the client, such as bill payment and related services. Other than having custody as the General Partner of a private fund, Pactolus does not act as the client’s agent or take custody of assets. (See Item 5.B. of this Brochure.) The following services will be provided by Pactolus: ▪ Multiple household management
• Occupancy preparation ▪ Management of household inventories & appraisal of valuables ▪ Coordination of property & casualty insurance ▪ Project management ▪ General contractor oversight ▪ Assistance with personal property acquisition/disposition ▪ Other concierge services as mutually agreed upon with the client Structured Products - Loan Recommendation and Due Diligence Services Pactolus may perform initial due diligence and ongoing monitoring services on certain structured products which will primarily consist of loans to residential or commercial real estate developers (“borrower”). Pactolus may recommend to appropriately suited clients that they make short to intermediate term loans to such borrower. Generally, such loans would be used as operating and or development capital by the borrower and would generally remain outstanding for a period of six to twenty-four months. Pactolus does not guarantee repayment of such loans by the borrower. Clients should be aware that Pactolus has an economic incentive to recommend such loans because the fee for monitoring such loans is higher than the Pactolus standard investment advisory fee. Real Estate Services Pactolus may provide real estate services to its advisory clients. Services include the following: ▪ Identify, from time to time, real estate investment opportunities for the client’s consideration, including but not limited to unimproved land suitable for residential and/or commercial development, and income-producing residential and/or commercial properties, whether located in or outside the United States (each, a “property” and collectively, the “properties”). ▪ Perform financial due diligence on each property to assist the client in determining the potential economic opportunity presented by acquiring the property. This financial due diligence includes an analysis of the acquisition cost, taxes, income (current or potential), operating expenses, depreciation, and other items Pactolus in its sole discretion deems appropriate. ▪ Analyze the development potential of each property or, if currently income producing, the viability of current or alternative uses of the property. ▪ Visually inspect each property in connection with the client’s acquisition of a property. The client will bear the reasonable travel and other expenses incurred by Pactolus in performing these inspections. ▪ Retain service providers, which generally will be independent third parties unless otherwise approved by client, to the extent Pactolus deems necessary or appropriate in performing the services hereunder and/or in connection with the acquisition, disposition, or other transaction relating to any property. The cost of such service providers will be borne by the client, unless otherwise agreed to by Pactolus, and will be explained to the client in advance of the services being performed. ▪ Provide the client with periodic reports on each property acquired by the client as Pactolus deems appropriate in its sole discretion, unless the client requests and Pactolus agrees to a specific form or frequency of report. C. Client-Tailored Services and Client-Imposed Restrictions Each client’s account will be managed on the basis of the client’s financial situation and investment objectives, and in accordance with any reasonable restrictions imposed by the client on the management of the account. Unsupervised Accounts In some cases clients may express an intention to exercise sole discretion over transactions in a given account or that the nature of the holdings does not require active management. Because such situations preclude active supervision by Pactolus, these accounts are identified as “unsupervised accounts” and billed only the custodial fee charged by Fidelity Investments. D. Wrap Fee Programs Pactolus provides investment advisory services exclusively on a wrap fee basis as a wrap program sponsor. Under our wrap program, clients will receive investment advisory services and the execution of securities brokerage transactions for a single specified fee. Participation in a wrap program may cost you more or less than purchasing such services separately. We adhere to our fiduciary duty when trading in your accounts. Trades are made only on the basis of the account’s stated investment objectives, and without concern to the firm’s trading costs and firm’s expenses. Please refer to Appendix 1: Pactolus Wrap Fee Program Brochure for information. E. Client Assets Under Management As of December 31, 2023, Pactolus had $100,323,174 of discretionary assets and $85,513,083 of non-discretionary assets under management.