Pinnacle Wealth Advisors, Inc., doing business as “Pinnacle Wealth Advisors,” is an independent investment advisor firm registered with the SEC. Our main offices are located in Clackamas, Oregon. We also maintain a branch office in St. Petersburg, Florida. Aaron Christopherson, CFP®, is the President and managing principal of the firm. The information contained in this brochure describes our investment advisory services, practices, and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our services to the needs of our clients. As used throughout this firm brochure, the words “PWA,” “we,” “our,” “firm,” and “us” refer to Pinnacle Wealth Advisors, and the words “you,” “your,” and “client” refer to you as either a client or prospective client of our firm. We offer investment supervisory services to our clients which incorporate ongoing management of client portfolios, financial planning, and consulting advice. For clients where this comprehensive service offering is not a fit or not desired, we offer stand-alone financial planning services. We also provide retirement plan consulting services to qualified retirement plans and their fiduciaries. Our investment advice is always tailored to the unique circumstances, financial goals, and investment profiles of our clients. A description of the individual investment advisory services we offer is set forth below. Investment Supervisory Services. Our investment supervisory services may be engaged on either a “full service” basis or under our “new investor” program. In either arrangement, we will consult with you at the inception of our relationship and periodically thereafter to review your overall financial circumstances, investment objectives and needs, time horizon for investments, tolerance for risk, and other factors we deem relevant to understanding your unique “investor profile.” You may impose reasonable restrictions on our management of your investment accounts (e.g., limiting the specific securities, types of securities, or market sectors in which we may invest your assets) at any time. While we strive to consult with clients frequently, you are encouraged to promptly and proactively advise us of any material changes in your financial circumstances, income, and cash flow needs during our relationship. We will document your investor profile and investment restrictions in our client file, update them from time-to-time based on our periodic communications with you, and use them to guide our ongoing management of your investment accounts. We will recommend an initial investment portfolio and investment strategy which aligns with your investor profile. Once a portfolio solution is agreed upon, we will implement the desired portfolio within your investment accounts, monitor your investments (including any SMAs, defined below) on an ongoing basis, and implement changes or rebalance your portfolio as needed or appropriate, in consideration of current economic conditions, our market opinions and assumptions, and what we believe to be your best interests. Investment allocation and security selection is our responsibility – you will be required to grant our firm discretionary authority to manage your investment accounts. This means that PWA is authorized to direct transactions within your investment accounts without obtaining your consent prior to each specific transaction. Client portfolios are typically constructed utilizing a diversified combination of some or all of the following instruments: individual stocks and bonds, mutual funds, exchange-traded funds (“ETFs”), and variable products (life insurance and annuities). Depending on the client’s financial circumstances, we may also recommend other instruments, including, without limitation, U.S. government and municipal securities, money market accounts, options, and certain alternative investments. In some instances, we may recommend that you engage certain independent third party money managers (“Independent Managers”) to manage all or a portion of your account (each such sub-account, a “Separately Managed Account” or “SMA”), typically on a discretionary basis. Under this arrangement, the Independent Manager shall be responsible for all investment selection and trading decisions with respect to your SMA and shall directly manage it in accordance with your investment objectives and risk profile as communicated by our firm. We will serve in a co-advisory capacity with respect to your SMA(s), responsible for the initial and ongoing determination of the suitability of the Independent Manager’s investment program, monitoring the performance

of your SMA(s) on an ongoing basis, and recommending changes in your SMA allocations as we determine to be in your best interests. The Independent Managers we recommend to you may contract with us directly to provide sub-advisory services to your account, may be accessible via the investment platform of your custodian, or may operate in an entirely independent capacity. In most instances, you will be required to execute a separate written investment advisory agreement and/or discretionary trading authorization in favor of the recommended Independent Manager(s). You will be provided with the Form ADV Part 2A (or equivalent disclosures) for any recommended Independent Managers in advance of engaging their services. We offer and strongly encourage all of our clients to take advantage of our comprehensive web-based financial planning program, which generates an additional set of data points that further helps to guide our long-term investment and planning recommendations for the client’s assets. This comprehensive online planning tool helps take into account the unique nature of each client’s personal financial situation, as opposed to a “one size fits all” approach. In addition to the portfolio management component of our services described above, clients who engage us on a “full service” basis also receive, at their election, a customized written financial plan that is tailored to assist them in the management of their overall financial affairs. Our financial planning recommendations are based on your unique investor profile and will address various topics relevant to your individual financial situation. The topics covered may include, without limitation, retirement planning, insurance review, cash flow management/budgeting, debt management, estate planning, education funding, charitable gift planning, and others. The written financial plan we provide you will reflect an overview of your overall financial circumstances, a summary of your investments, and our investment recommendations. We will review and update your financial plan periodically, as appropriate based on your financial needs and investment objectives, material changes in your financial circumstances, and otherwise, as you may reasonably request. We will also provide “full service” clients with ongoing financial consulting services designed to address common financial topics and issues relevant to the client’s financial plan and affairs. You will make the ultimate investment and implementation decisions with respect to any assets held outside of the accounts over which you have granted us discretionary authority and will be responsible for monitoring of all such “held away” investments for which we provide planning or consulting recommendations. Clients who engage us for investment supervisory services under our “new investor” program do not receive a customized written financial plan or ongoing financial consulting as part of this advisory service. Certain other restrictions and eligibility limitations apply to our new investor program – please see Item 5 for details. Stand-Alone Financial Planning and Consulting. Financial planning and consulting services are also offered to clients on a stand-alone basis. Clients who engage us on this basis do not receive any review or update of their written financial plan following delivery, unless otherwise agreed. Retirement Plan Consulting Services. We offer retirement plan consulting services to qualified retirement plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include a review of an existing plan, formulation of the investment policy statement, assistance selecting and monitoring plan service providers, recommendations regarding investment selection, on-going consulting, portfolio management services, and participant enrollment and investment education services. We do not offer, sponsor, or participate in any wrap fee programs. The types of investments we typically recommend to clients are described above within the description of our investment supervisory services. We may also provide advice regarding investments held in your portfolio at the inception of our advisory relationship and/or other investment types not listed above, at the client’s request. Please see Item 8 of this brochure for a description of the methods of analysis and investment strategies we typically utilize in advising client accounts. As of December 31, 2023, PWA managed approximately $156,499,173 in client assets on a fully discretionary basis, and approximately $45,578,430 of client assets on a non-discretionary basis.