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PORTFOLIO SOLUTIONS STRATEGIST
Pnc Wealth Management (CRD 129052), brochure dated September 8, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Form ADV Part 2A Appendix 1 801‐66195
Disclosure Document for the
Portfolio Solutions Strategist Program
An Investment Advisory Service of
PNC Wealth Management LLC
300 Fifth Avenue
Pittsburgh, Pennsylvania 15222
(800) 622-7086
www.pnc.com
September 8, 2026
This wrap fee program brochure (“Brochure”) provides information about the qualifications and business
practices of PNC Wealth Management, LLC with respect to the Portfolio Solutions Strategist Program (the
“Program”). If you have any questions about the contents of this Brochure, please contact us at (800) 622-7086.
The information in this Brochure has not been approved or verified by the United States Securities and
Exchange Commission (“SEC”) or by any state securities authority.
PNC Wealth Management LLC, a registered investment adviser and broker‐dealer and member of the Financial
Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), is a wholly
owned subsidiary of The PNC Financial Services Group, Inc. Registration does not imply a certain level of skill or
training.
Additional information about PNC Wealth Management LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
• NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY
• NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, PNC BANK, N.A. OR ANY OF ITS AFFILIATES
• SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED
Material Changes
ADV Part 2A dated September 8, 2026
This PNC Wealth Management Portfolio Solutions Strategist Program Brochure is dated September 8,
2026. This section describes the material and/or other changes to the Brochure since the last
amendment dated June 24, 2026:
Page 9 – Custom Suite – The Brochure has been updated to include Custom Suite, an option available within the
Program that provides access to select third-party managers with discretionary authority over client portfolios.
Pages 14 and 16 – Fees and Expenses – The Strategist Fee chart has been updated to add two new model
providers, Capital Wealth Planning Enhanced Dividend Income and Tandem Large Cap Core, including their
applicable annual Strategist Fees.
Table of Contents
Disclosure Document for the Portfolio Solutions Strategist Program .................................................... 1
Material Changes ...................................................................................................................... 2
Table of Contents...................................................................................................................... 3
About PNC Wealth Management LLC ........................................................................................... 4
SERVICES, FEES AND COMPENSATION .......................................................................................... 4
The Portfolio Solutions Strategist Program.............................................................................. 4
Multi-Account Management ................................................................................................. 7
Tax-Overlay Service ............................................................................................................. 8
Envestnet Private Wealth Service .......................................................................................... 8
Custom Suite ...................................................................................................................... 9
Responsible Investing and Values-Based Strategies .................................................................. 9
Account Statements ...........................................................................................................10
Account Termination ..........................................................................................................10
Review of Accounts ............................................................................................................11
Securities Transferred into an Account ..................................................................................11
Withdrawals from an Account..............................................................................................12
Taxes................................................................................................................................12
Fees and Expenses .............................................................................................................12
Calculation of Account Fees .................................................................................................16
Additional Fees for Brokerage Services ..................................................................................17
Deduction of Account Fees ..................................................................................................17
Additional Compensation ....................................................................................................17
Other Expenses..................................................................................................................18
Cash Balances....................................................................................................................20
Financial Advisor Compensation ...........................................................................................21
ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS .......................................................................22
Account Minimums and Types of Clients ...............................................................................22
Collateral Accounts ............................................................................................................22
PORTFOLIO MANAGER SELECTION AND EVALUATION....................................................................23
Model and Strategist Selection and Evaluation .......................................................................23
PNC Wealth Management and Other Service Providers to the Program .....................................24
Risks of Investing in the Portfolio Solutions Strategist Program .................................................24
Trading Practices................................................................................................................25
Proxy Voting......................................................................................................................26
CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ........................................................27
CLIENT CONTACT WITH PORTFOLIO MANAGERS ...........................................................................27
ADDITIONAL INFORMATION ......................................................................................................27
Disciplinary Information ......................................................................................................27
Other Financial Industry Activities and Affiliations...................................................................29
Affiliate Transactions ..........................................................................................................30
PNC TotalRewards Program (Affiliate Banking Program Disclosure) ...........................................30
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading....................30
Client Reports....................................................................................................................31
Client Referrals and Other Compensation ..............................................................................31
Financial Information..........................................................................................................31
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About PNC Wealth Management LLC
PNC Wealth Management LLC (“PNC Wealth Management” or the “Firm”) is an investment adviser and also a
registered broker‐dealer and member of FINRA and SIPC. The Firm offers retail brokerage and investment
advisory services. PNC Wealth Management serves as the sponsor of, and in some cases as a portfolio manager
for, wrap fee investment programs. PNC Wealth Management is a wholly owned subsidiary of PNC Bank,
National Association (“PNC Bank”) and is a part of The PNC Financial Services Group, Inc. (“PNC”) which is a
diversified financial services institution with roots in commercial banking and investment management dating
back to the early 1800s.
Throughout this document, the terms “client,” “you,” and “yours” are used to refer to the
individual(s), institution(s) or organization(s) who contract with us for the services described
here. “PNC Wealth Management,” “we,” “our,” “us” and “the firm” refer to PNC Wealth
Management LLC, together (as applicable) with our affiliates, including but not limited to, PNC
and its agents with respect to any services provided by those agents. Our affiliates include any
entity that is controlled by, controls or is under common control with PNC Wealth Management,
including but not limited to our parent company, The PNC Financial Services Group, Inc. Each
affiliate is a separate legal entity and not responsible for the obligations of any other affiliate.
“Account” means each brokerage and/or advisory account you open with us that is subject to
the Portfolio Solutions Strategist Program investment management agreement (the “Investment
Management Agreement”), including any and all mutual funds, exchange traded funds, money,
securities, financial instruments and/or other property you have funded in such accounts.
“Business Day” means Monday through Friday, excluding New York Stock Exchange holidays.
“Wrap” refers to an Account that charges a quarterly or annual fee based on the average assets
under management, where such fee covers administrative, commission, execution and
management expenses.
SERVICES, FEES AND COMPENSATION
This Brochure is being provided pursuant to Section 204 of the Investment Advisers Act of 1940, as amended,
and deals solely with our Portfolio Solutions Strategist Program. In addition to the Program, PNC Wealth
Management offers a variety of investment advisory services. These include the Capital Directions Program, the
Capital Directions Annuities Program, the Portfolio Solutions Program, the PNC Directions Program, the Guided
Solutions Program, and the Portfolio Solutions Strategist Digital Offering Program. More information about
these programs and services is contained in the applicable PNC Wealth Management brochure and is available
upon request from PNC Wealth Management or through the SEC’s website at https://adviserinfo.sec.gov/. For
more information about these or other services that are available from PNC Wealth Management, please
contact your Financial Advisor. 1 Other advisory services are offered by our affiliates.
The Portfolio Solutions Strategist Program
The Portfolio Solutions Strategist Program is a discretionary investment advisory platform that provides clients
an integrated set of model investment strategies through a single advisory account. We will help you formulate
1 We use the term “Financial Advisor” to refer to PNC Wealth Management’ branch-based and wealth Financial Advisors, as
well as Advisor Direct Financial Advisors and Investment Services Consultants.
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an investment strategy based on many factors including but not limited to your investment objectives, risk and
return considerations and tax status. Your strategy will be implemented through the use of one or more
approved investment models (“Investment Model or Investment Models”) provided by professional asset
managers (“Strategists”) available through the Program. In constructing the Investment Models, the Strategists
may elect to utilize mutual funds and/or exchange traded funds (collectively “Funds”) as well as individual equity
or fixed income securities. PNC Wealth Management, as the investment adviser to the program, will exercise its
discretion to invest your Account in the Investment Model(s) you have selected.
PNC Wealth Management has contracted with Envestnet Asset Management, Inc., an unaffiliated investment
adviser (the “Investment Delegate”) to perform certain duties for the program. PNC Wealth Management will
select for the Program various Investment Models offered by the Strategists from a list of Investment Models
made available to PNC Wealth Management by the Investment Delegate. In managing the Investment Models,
Strategists will use various investment strategies such as tax aware investing, specific investment outcomes,
income generation and Responsible Investing, among others. The Investment Delegate will implement
Strategists’ Investment Models (excluding Strategist Traded Models, as described below) and will facilitate
execution of trades in your Account as instructed by PNC Wealth Management. Strategist Traded Models are
fixed income Investment Models, and trades for those Investment Models are implemented by the Strategist
rather than by PNC Wealth Management or the Investment Delegate. Utilizing a proprietary methodology, the
Investment Delegate will evaluate the risk characteristics of each Investment Model and assign each Investment
Model a risk score (the “Risk Score”). The Risk Score is generally reflective of each Investment Model’s maximum
equity exposure and is evaluated annually and adjusted as needed. PNC Wealth Management reviews each
Investment Model’s Risk Score and may adjust a Risk Score based on its own review of the Investment Model.
Before you open an Account in the Portfolio Solutions Strategist Program, you should carefully review our Client
Relationship Summary (“Form CRS”) and consider whether an advisory relationship is right for your situation and
circumstances. You may discuss any questions you have regarding our Form CRS or whether an advisory account
is right for you with your Financial Advisor. Some things you may wish to consider are your preference for a fee-
based versus a commission based relationship, your preference for on-going support, costs and advice from your
Financial Advisor, and how much trading activity you expect to take place in your account. You should know that
your Financial Advisor benefits when you open a Portfolio Solutions Strategist account, as described in more
detail in the Financial Advisor Compensation section of this Brochure, and has a conflict of interest when
recommending an advisory account to you. Once you decide that the Program is right for you, your Financial
Advisor will help you complete an investor questionnaire (“Client Profile”) that provides us with an
understanding of your financial situation, investment objectives, risk tolerance and investment time horizon.
Based on the information collected in the Client Profile and other information you share with your Financial
Advisor, your Financial Advisor will assist you to select from a variety of approved Investment Models offered by
Strategists, available through the Program. If one Investment Model is selected, the Risk Score of the Investment
Model must match your risk profile as determined by the Client Profile. If more than one Investment Model is
combined to create an allocation model (“Allocation Model”), the weighted average Risk Score of the selected
Investment Models must match your risk profile, as determined by the Client Profile. We will present our
recommendation to you in the form of a proposal (the “Proposal”) for your acceptance and approval.
From time to time, your Financial Advisor may recommend changes to the Investment Model(s) you have
selected. You may also request changes to your selected Investment Model(s), subject to certain restrictions
described in this brochure. We may also, at our discretion, change the account allocation to any Investment
Model available in the Program. Finally, PNC Wealth Management will periodically exercise its discretion to
adjust the risk scoring associated with an Investment Model or remove Investment Models or Strategists from
our approved list. This will result in PNC Wealth Management using its investment discretion to change the
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Investment Models utilized in your account. In all of these circumstances, PNC Wealth Management will update
your account and Investment Models you have selected accordingly and the Investment Delegate will execute
transactions to align your account to these changes. Note that you will not be sent a new Proposal in these
circumstances, unless requested through your Financial Advisor.
PNC Wealth Management retains the authority to limit the availability of any Investment Model offered by a
Strategist, or Fund, and/or to terminate or replace any Investment Model when circumstances are such that PNC
Wealth Management believes a change is in your best interest. If an Investment Model is terminated or
otherwise removed from the Program, PNC Wealth Management will use commercially reasonable efforts to
select a replacement Investment Model that is substantively similar to the Investment Model that has been
removed or, alternatively, assume management of the portion of your Account allocated to the removed
Investment Manager in a manner that PNCWM or its designee believes is consistent with your Client Profile. In
either case, we will sell your holdings in the terminated Investment Model and purchase shares in the
substituted Investment Model or as we, or our designee, have determined is consistent with your Client Profile,
without any prior notice to you.
Certain of these changes will result in an increase/decrease to the fees discussed further herein (see Services,
Fees and Compensation – Fees and Expenses). For example, if PNC Wealth Management removes an Investment
Model from the program, the replacement Investment Model may be more expensive than the replaced
Investment Model. Although you will not be sent an updated Proposal in some circumstances described above,
any changes to the Account’s fees will be reflected on future Account statements summarizing the activity in
your Account.
Before you may establish a Portfolio Solutions Strategist Account, you must establish a brokerage account with
PNC Wealth Management and agree to the terms and conditions of the PNC Wealth Management Brokerage
Account Customer Agreement. By accepting and signing the Investment Management Agreement, you grant
discretion over your Account to PNC Wealth Management and you authorize us to delegate our discretion to the
Investment Delegate in order for the Investment Delegate to invest and reinvest the assets in your Account in
Investment Models. The scope of any investment advisory relationship we have with you is defined in the
Investment Management Agreement. When you are enrolled in the Program, we act as your introducing broker
and we will also act as your investment advisor, but only for your Program Account and not for any other assets
or accounts, unless otherwise separately agreed to by us in writing. As discussed in more detail below, we earn
certain fees and other revenue in connection to our capacity as introducing broker to your Account. This is a
conflict of interest because we would not earn such fees or revenue if we did not serve as your introducing
broker. Our Portfolio Solutions Strategist Program advisory relationship with you begins when we enter into an
Investment Management Agreement with you, which occurs at the later of the date of acceptance of the signed
Investment Management Agreement by PNC Wealth Management or the date on which you have contributed
the required minimum level of assets to your Account. Preliminary discussions or recommendations before we
enter into an Investment Management Agreement with you are not intended as investment advice under the
Investment Advisers Act and should not be relied on as such.
The Portfolio Solutions Strategist Program is designed for investors who wish to give PNC Wealth Management
discretion with respect to the assets in their Account and to have those assets invested by the Investment
Delegate to according to Investment Model(s) selected. Once you are approved for the Program, you will not
have the ability to directly buy or sell individual securities in your Account, or to direct your Financial Advisor ,
the Investment Delegate or any Strategist to buy or sell securities in your Portfolio Solutions Strategist Account.
You will not be able to obtain a margin loan using the securities in your Account as collateral. You will retain,
however, the ability to place reasonable restrictions on the securities that may be purchased for or held in your
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Account, subject to the review and approval of PNC Wealth Management. In general, you may impose individual
security restrictions, including mutual funds, ETFs and specific equity securities or industry restrictions. You may
also have the ability to restrict certain bond characteristics, such as years to maturity, credit quality, or duration.
PNC Wealth Management will determine which specific securities fall within an industry restriction and will
implement any industry restrictions in a manner it determines in its sole discretion from time to time. If an
individual security restriction is reasonable, PNC Wealth Management, the Investment Delegate and/or the
Strategist will generally allocate assets that would have been invested in a restricted security to cash or one or
more substitute securities, which may include ETFs, on a pro rata basis. Any restrictions you impose on individual
securities are subject to the approval of PNC Wealth Management and the Investment Delegate and will not
apply to the underlying holdings of mutual funds or ETFs.
PNC Wealth Management will be responsible for monitoring and maintaining the Investment Models available
through the Portfolio Solutions Strategist Program. PNC Wealth Management has delegated its discretion to buy
and sell securities for your Account in accordance with the selected Investment Model(s) to the Investment
Delegate. Depending on the Investment Model(s) chosen, Investment Delegate will make investments in,
without limitation, equity securities, fixed income securities, cash (and/or short‐term investments including, but
not limited to, money market funds), Funds, and other financial instruments. Investment Delegate will also be
responsible for rebalancing your Account to keep it within the acceptable allocation ranges for the specified
Investment Model. PNC Wealth Management may, at its discretion, remove an Investment Model from the
schedule of available Investment Models and replace it with another Investment Model, without any prior
notice to you.
Multi-Account Management
If you elect to, you may enroll two or more of your related Program Accounts in a multi-account management
relationship (“MAM”). When you enroll two or more of your Program Accounts in MAM (collectively “MAM
Accounts”) PNC Wealth Management will apply a single Allocation Model across all MAM Accounts. All MAM
Accounts will be managed pursuant to a single household-level Allocation Model as shown on your Proposal.
Only accounts that you would like managed pursuant to the Allocation Model should be included in the MAM. If
you have other managed accounts at PNC Wealth Management that have a different time horizon or risk
tolerance, they should not be included in MAM. You will receive a single Quarterly Report for all associated
MAM Accounts. You should be aware that deposits or withdrawals made into a MAM Account will in most cas es
cause substantial trading in both that account as well as other MAM Accounts in order to keep them allocated
pursuant to the Allocation Model in the aggregate. Similarly, adding or removing a Program Account from MAM
will in most cases cause substantial trading in all MAM Accounts. Such trading may also result in you incurring
redemption fees from certain mutual funds and will result in tax consequences in taxable Program Accounts.
MAM is designed to allow flexibility with respect to the placement of assets in different account types for tax
efficiency and to use a tax-aware strategy when making trades in MAM Accounts. If both qualified and non-
qualified accounts are included in MAM, MAM will utilize an asset location preference where Investment
Options are allocated to non-qualified or qualified accounts based on their relative tax inefficiency (calculated
based on the pre-tax and post-tax returns that are reported by Fund companies). Some assets tend to be more
tax efficient, such as equities and equity-based Funds, and generally represent greater investment risk. Taxable
MAM Accounts generally carry a disproportionate amount of the investment risk in a MAM relationship. You
should only combine non-qualified and qualified accounts in a single MAM relationship if you understand this
and are comfortable with this allocation between accounts.
You may choose to discontinue MAM with respect to one or more MAM Accounts. In addition, PNCWM may in
its discretion elect to discontinue offering MAM. In such event or if any MAM Account’s IMA is terminated for
any reason, unless you provide different instructions ahead of the termination, each remaining MAM Account
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will be rebalanced to individually meet the target Allocation Model. This may cause significant tax impacts to any
non-qualified account. You are urged to discuss MAM with your tax professional.
Tax-Overlay Service
You may select an optional tax-overlay service for your non-qualified Program Account (“Tax-Overlay Service”).
When you select the Tax-Overlay Service, your Financial Advisor will work with you to establish short and long-
term tax budgets and the Investment Delegate will attempt to manage your Program Account in such a way as
to prevent realized short and long-term taxable gains from exceeding agreed upon budgets. The Investment
Delegate will do this by timing the purchase and sales of equity securities in such a way as to attempt to
minimize the tax impacts to your Program Account. The Investment Delegate will also actively seek
opportunities to realize taxable losses in your non-qualified Program Account by selling certain securities that
have depreciated in value. These realized losses can be utilized to offset realized gains in your Program Account
or other taxable accounts. Note that the Investment Delegate will actively seek to realize losses only in equity
positions held in Investment Models and will not actively realize losses in Funds held in your Program Account.
Additionally, the Tax-Overlay Service will cause the holdings in your Program Account to deviate from holdings
of other accounts utilizing the same Investment Model. Finally, you should be aware that no strategy, including
the Tax-Overlay Service, will prevent the realization of taxable gains from your investments. The Tax-Overlay
Service seeks to minimize the current impact of taxes on your Program Account but will not eliminate the
eventual realization of imbedded gains from your Program Account. If you elect to terminate the Tax-Overlay
Service for your Program Account, you need to be aware that any unrealized embedded taxable gains will likely
be realized as a result. You should carefully review the unrealized embedded taxable gains in your Program
Account before electing to terminate the Tax-Overlay Service. Withdrawals from your Program Account will
likely force the Investment Delegate to liquidate securities and exceed the short and/or long -term tax budgets.
When you select the Tax-Overlay Service, PNC Wealth Management will review and must approve your Program
Account for the service.
PNC Wealth Management, your Financial Advisor, and the Investment Delegate do not provide tax advice. If you
are considering the Tax-Overlay Service, you should review your tax situation with your independent tax adviser
to fully evaluate how you may benefit from it. The annual fee for the Tax-Overlay Service is 0.15% (the “Tax
Overlay Fee”) which is calculated and charged similarly to the Program Fee, described in detail below. In certain
circumstances, the Tax Overlay Fee may exceed the tax benefit, in any given tax year. You should be aware,
although, the Investment Delegate will actively manage taxes only in the equity positions in your Program
Account, the Tax-Overlay Service fee will apply to the full account balance, including assets held in cash and
other positions that are not being actively managed through the Tax-Overlay Service.
Envestnet Private Wealth Service
Envestnet Private Wealth Service (“PWS”) is an investment consulting and portfolio construction service
provided by Portfolio Management Consultants (“PMC”). PWS allows flexibility to customize a Program Account
through asset allocation consulting, portfolio design, and ongoing portfolio oversight, while allowing for
customization based on your investment objectives, tax considerations, and applicable investment restrictions.
Under this service, your Financial Advisor will work with you and PMC to establish an investment strategy
aligned with your goals, risk tolerance, time horizon, and individual circumstances. PMC provides investment
consulting and portfolio construction services, while your Financial Advisor remains responsible for client
communications and ongoing account servicing.
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PWS includes an assessment of your investment needs, development of an asset allocation strategy, and
ongoing monitoring of invested assets. The service permits additional customization, including security-level,
industry, or sector restrictions, and may include the use of the Tax-Overlay service described above.
Clients utilizing PWS have access to investment strategies that have been reviewed and approved through PMC’s
investment manager due diligence and approval process, which has been reviewed and approved by PNCWM.
The annual fee structure for PWS is outlined below. This fee is in addition to the Program Fee and any Strategist
Fees that may be incurred. PNCWM does not receive any portion of these fees.
PMC can also manage a portion of the assets using a PMC proprietary strategy. This is a conflict because PMC
has an economic incentive to recommend its proprietary strategies. If a portion of your portfolio is invested
in a PMC proprietary strategy, this conflict is mitigated by Envestnet waiving the PWS Fee for any portion of the
Private Wealth Managed account that uses a proprietary PMC strategy.
Envestnet Private Wealth Service Fees
Account Assets
First $10,000,000
Next $15,000,000
Over $25,000,000
Service Portfolio Fee
0.10%
0.08%
0.05%
Private
Wealth Service Fee*
0.15%
0.12%
0.10%
Total Client Fee
0.25%
0.20%
0.15%
*The Private Wealth Consulting Fee is waived for any portion of the Private Wealth Managed account that uses a
proprietary PMC strategy.
Custom Suite
Within the Program, PNC Wealth Management makes available select Third‑Party Managers as an option
through Portfolio Solutions Strategist Custom Suite. This option allows for a wide range of customization based
on a client’s individual investing needs. Clients who choose this option will utilize one manager per account.
Third‑Party Managers included in the Portfolio Solutions Strategist Custom Suite are considered
Manager‑Traded Strategies. The Third‑Party Manager for a Manager‑Traded Strategy assumes full discretionary
portfolio management responsibility for each account invested in the strategy. This responsibility includes
determining which securities are purchased and sold and directly implementing those investment decisions on
behalf of the client.
Depending on the strategy selected, the Third‑Party Manager may invest client assets in a variety of securities,
including, but not limited to, common or preferred stocks, corporate bonds, government bonds or notes,
options, warrants, or rights, unless otherwise restricted by the client. All or a port ion of the account may be held
in cash. For strategies that trade options, a completed options agreement must be on file.
Clients should work with their Financial Advisor to understand any account specific settings, restrictions, or
requirements applicable to the selected Portfolio Solutions Strategist Custom Suite manager and strategy.
Responsible Investing and Values-Based Strategies
You may also select one of several responsible investing models (the “RI Models”) made available by Strategists
and approved by PNCWM (collectively, the “RI Strategists”). In the RI Models, the applicable RI Strategist seeks
to incorporate various responsible investing characteristics as part of the investment selection process.
Responsible investing can be defined very differently by individuals, PNCWM utilizes data from Morningstar to
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assist in assessing the responsible investing characteristics of the RI Models. PNCWM will seek to include RI
Models that are intentionally managed using environmental, social, or governance (“ESG”) screening or other
values-based criteria or based on their scores for ESG Risk or Controversy Level, as measured by Sustainalytics, a
Morningstar Company. In general, RI Models exhibiting the following responsible investing characteristics are
favored: clear incorporation of ESG criteria in their security analysis and investment decision-making; seek to
have an impact on thematic issues; utilize negative screening to avoid investments that violate norms-based,
faith-based, or other values-based criteria; practice a form of active ownership through which they engage with
corporate management on ESG issues; have actively supported ESG arrangements through their proxy voting;
holding companies with lower risk related to ESG issues or misconduct, as scored by Sustainalytics. Note that
funds may exhibit any one or more of the preceding characteristics.
Responsible investing priorities are a matter of personal preferences, and there is no assurance that criteria
utilized by a particular RI Strategist or PNCWM will match your personal responsible investing priorities. You
should carefully review the prospectus, Form ADV, or other offering documents for the RI Models and evaluate if
the applicable RI Strategists’ ESG or other values-based criteria and strategy match your own priorities.
Additionally, you should know that, while RI Strategists may apply responsible investing or ESG criteria to their
proxy voting decision making process, where PNCWM votes proxies on your behalf, discussed further below,
PNCWM, through its delegate Envestnet, will apply our standard proxy voting policies and will not apply any
responsible investing or ESG related criteria to proxies we vote on your behalf in the RI Models. PNCWM expects
that the RI Models will typically include one or more Funds without a specific responsible investment mandate.
RI Strategists may include Funds without a specific responsible investing mandate when they are unable to
identify suitable responsible investing Funds to fulfil a particular portfolio allocation. PNCWM does not set a
minimum percentage allocation to Funds with a responsible investment mandate for the RI Models. Finally, all
investment strategies, including responsible investing related strategies, carry the risk of loss, and there is no
assurance that a responsible investing strategy can guarantee a profit or protect against loss. In addition, there is
no assurance that any responsible investing related strategy, including the RI Models, will provide any
investment benefit relative to similarly constructed non-responsible investing related strategies.
In addition to RI Models, PNCWM offers values-based investments, with categories such as gender, minority,
religion, sustainability or environment, which seek to reflect a customer’s values by avoiding or increasing
exposure to specific companies, sectors or practices. Certain religious values-based investment managers invest
in companies that generate income and returns inconsistent with a particular religion’s philosophies. In cases
where this occurs, it is the customer’s responsibility to determine the amount, if any, of non-compliant
generated income and/or gains. For more information about how to address these types of non-compliant
income or returns, please refer to the religious values-based investment’s prospectus or disclosure agreement.
Account Statements
You will receive a monthly statement following any month in which there is investment activity in your Account,
confirming all transactions in your Account, including additions, disbursements, purchases, sales, and advisory
fees paid to PNC Wealth Management or fees paid to Strategists. For periods in which there is no investment
activity in your Account, statements will be provided quarterly. You will also receive a quarterly performance
report that tracks the performance of your portfolios against relevant benchmarks. You will be reminded
quarterly to contact your Financial Advisor if you should have any questions, or if there have been material
changes in your financial goals or needs that would affect your investment strategy.
Account Termination
Either party may terminate the Investment Management Agreement on 30 days’ written notice to the other
party. You are also entitled to terminate such agreement within five (5) business days of your execution of it
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without incurring a Program Fee, defined below; you may, however, be subject to certain other fees incurred
with respect to the Account for the relevant period. Upon the termination of the Investment Management
Agreement, PNCWM will be under no obligation to provide advice on any holdings in your Account. Any
transactions executed by you after the termination of the Investment Management Agreement will be subject to
fees and commissions described in the PNC Wealth Management Overview of Products and Services (the
“Overview of Products and Services”). You may obtain a copy of our current Overview of Products and Services,
at any time, by contacting your Financial Advisor, by contacting us at (800) 622-7086 or online at
www.pnc.com/investments-relationship-summary. In addition, upon learning of the death of any account
owner, PNCWM will immediately terminate the Investment Management Agreement. You should be aware that
any transactions executed by your heirs or beneficiaries after your death will be subject to fees and commissions
described in the Overview of Products and Services, unless waived by us in our sole discretion. Please see the
agreement governing your Portfolio Solutions Strategist Program Account for more information.
Review of Accounts
When you open a Portfolio Solutions Strategist Program Account, we review and must approve your investment
objectives and strategy for consistency with Portfolio Solutions Strategist Program guidelines. Thereafter, we will
continuously monitor the Account, including its performance, the appropriateness of the individual securities in
it, and any investment restrictions that might apply.
We will attempt to contact you at least annually, including by mail or email (if you have authorized us to send
you electronic communications), to request that you review your Account and inform us of any changes to your
financial profile or investment objectives. You should inform your Financial Advisor of any changes to your
financial profile or investment objectives as they occur. Your Financial Advisor will communicate any changes
about you to PNC Wealth Management. You will have very limited, if any, direct contact with the Strategist
selected for your Account. Therefore, it is very important that you maintain contact and communication with
your Financial Advisor. You should direct any inquiries about your Account, allocations to Investment Models, or
any Strategists to your Financial Advisor or by calling us at 800-622-7086. Finally, your Financial Advisor will be
reasonably available to you for consultation about the Account. We encourage you to please contact your
Financial Advisor if you have any questions.
Securities Transferred into an Account
You should be aware that if you transfer securities into a Portfolio Solutions Strategist Account, any transferred
securities that are not part of the recommended investments for your Account will be liquidated upon or shortly
after transfer. Typically, this means that we will liquidate all of the securities you transfer into your account prior
to investing your account in the recommended investments.
If your account is not tax-exempt, you will incur tax consequences as well as a result of these transactions. You
should consult with your tax adviser to review these consequences. Additionally, if you liquidate securities prior
to transferring your account to PNC Wealth Management or liquidate your securities prior to establishing your
Portfolio Solutions Strategist account, you will likely incur transaction costs for those transactions. PNC Wealth
Management will not reimburse you for transactions executed at another firm. Please note that if you transfer
illiquid securities into a Portfolio Solutions Strategist Account, it will delay management of that Account until
such securities are transferred out or otherwise removed. You may, at your election, choose an optional Dollar
Cost Averaging (“DCA”) feature when adding funds to your Program Account. With the DCA feature, you have
the ability to deploy free cash to your Allocation Model over a defined period and in pre-determined amounts.
The DCA feature can enable clients to slowly invest excess cash over time, rather than make one lump-sum
investment. You have no obligation to complete scheduled DCA transactions and may terminate the DCA feature
at any time, by providing notice to us, at least 5 business days prior to the next scheduled DCA transaction. You
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should know that if sufficient cash is not available in your Account at the time of a scheduled DCA transaction,
that transaction, and all future scheduled DCA transactions will be canceled. You should also be aware that cash
pending investment under an optional DCA plan will be treated as unallocated cash and swept to a deposit
account at our affiliate bank, as described below. The parameters of DCA requests are subject to our approval.
Withdrawals from an Account
You should also be aware that if you request a withdrawal from a Portfolio Solutions Strategist Account, PNC
Wealth Management or the Investment Delegate will need to liquidate a portion of the Account to cover the
requested withdrawal amount if the cash in your Account is insufficient to accommodate the requested
withdrawal. If your account is taxable, you will incur tax consequences as a result. These transactions are subject
to short-term trading policies of Funds held in your account. Liquidation requests are processed according to our
standard procedures and your liquidation request may not be completed on the day it was submitted. This is
more likely if your request is submitted late in the day or during periods of severe market volatility. Cash is
available for distribution three to five business days after the initial request is made, however, you should also
be aware that liquidation transactions are at the discretion of the Investment Delegate and could exceed this
timeframe.
Taxes
You need to be aware that the Program operates in a manner that will likely cause non-retirement Portfolio
Solutions Strategist accounts to more frequently experience taxable gains and losses than a brokerage account
holding individual securities for the same amount of time. When we, at our discretion, or the Investment
Delegate sell securities to rebalance your asset allocation or to adjust your account to changes in the Investment
Model, the transaction will likely create a capital gain or loss for you. Additionally, any securities that you sell in
order to raise cash to open and/or be deposited into your account will likely create a capital gain or loss. These
capital gains and losses are in addition to dividends and capital gains paid by the securities in the account. You
should consider this and discuss the potential tax implications of opening and maintaining a Portfolio Solutions
Strategist account with your tax adviser.
Fees and Expenses
You will pay both a program fee (the “Program Fee”) and a separate strategist fee (the “Strategist Fee”) for the
services provided under the Portfolio Solutions Strategist Program. The Program Fee and Strategist Fee will be
combined and reflected on your account statement as the management fees (the “Management Fee”). You
should be aware that your account is subject to the Management Fee whether you make or lose money on the
investments. Each fee is calculated as a percentage of assets under management and will vary depending on the
services provided to you. Generally, a commission or service charge per trade will be charged to your brokerage
account when liquidating assets to establish the Portfolio Solutions Strategist Account; you should discuss your
options for funding your account with your Financial Advisor.
The Program Fee is based on the total assets under management, including any portion of the Account
maintained in cash or in short‐term vehicles including, but not limited to, unallocated cash swept to a deposit
account at our affiliate, PNC Bank, or money market funds. As the aggregate market value of the Program
Account and if applicable other managed accounts in the billing household reaches a higher tier, as shown in the
table below, the assets within that higher tier are charged a lower rate. Our standard Program Fee schedule is as
follows:
Assets Under Management
Maximum Program Fee
First $250,000
2.00%
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Portfolio Solutions Strategist Program
September 8, 2026
Assets Under Management
Maximum Program Fee
Next $250,000
1.75%
Next $500,000
1.50%
Next $1,000,000
1.25%
Next $2,000,000
1.00%
Over $4,000,000
Negotiable
From time to time, we offer discounted pricing programs at our discretion. For example, current employees of
PNCWM and their immediate family members are eligible for employee pricing.
Your Financial Advisor has discretion to negotiate a Program Fee that varies from the standard schedule above.
This can depend on certain factors, including the type and size of your Account, the range of services provided
and the total amount you or other members of your household have invested with PNC Wealth Management.
The Program Fee for your Account is referenced in the fee schedule included as part of the Proposal completed
and accepted by you. The Program Fee you pay to PNC Wealth Management for the Portfolio Solutions
Strategist Program is charged quarterly in advance and will be based on the average daily balance in your
Portfolio Solutions Strategist Account over the prior calendar quarter or portion thereof (except in the case of a
new account, as outlined below). The Program Fee covers the cost of brokerage commissions and other
transaction fees only for transactions executed through National Financial Services LLC (“National Financial”) on
an agency basis. The Investment Delegate will typically route trades to National Financial for execution. From
time to time, the Investment Delegate will trade with Broker Dealers other than National Financial when the
Investment Delegate determines, in their sole discretion that this is in your best interest. Trades executed away
from National Financial are described as “trading away” or “step-out trades”. You will bear the cost of any
brokerage commissions incurred on transactions executed through other brokers, dealer markups, markdowns
and spreads when the Investment Delegate Trades Away from National Financial. See the Additional Fees for
Brokerage Services and Trading Practices section below for details.
In addition to the Program Fee, you will pay a separate Strategist Fee for the services provided by the
investment manager(s) that provide the Investment Model(s) you have selected. The Strategist Fee is based on
the average daily balance of assets under advisement invested pursuant to the applicable Investment Model(s),
including any portion of the Account maintained in cash, or in short‐term vehicles including, but not limited to,
unallocated cash swept to a deposit account at our affiliate, PNC Bank, or money market funds, over the prior
calendar quarter, or portion thereof. PNCWM will bill Program Accounts on behalf of Strategists and will remit
payment to the appropriate Strategists on behalf of Program Accounts. PNCWM does not anticipate retaining
any portion of the Strategist Fee. Current Strategist Fees are set forth in the table below. From time to time,
Strategists may change their fees without notice to PNC Wealth Management or you.
Annual Fee
Model Provider
Alger Capital Appreciation
Annual Fee
0.4
0.38
0.27
0.4
0.45
0.45
0.4
Model Provider
BlackRock Global Dividend Income ADR 0.4
BlackRock Equity Dividend
BlackRock Fundamental Core Taxable
Fixed Income
BlackRock Intermediate Municipal
Fixed Income
Alger Mid Cap Growth
Aristotle Value Equity
Baird Chautauqua International Growth
Equity
Baird Mid‐Cap Growth Equity
Baird Small/Mid Cap Growth
0.4
0.4
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Portfolio Solutions Strategist Program
September 8, 2026
Annual Fee
0.27
0.27
0.15
0.15
0.15
0.38
0.27
0.27
0.27
0.4
0.2
0.2
0.23
0.5
0.4
0.23
0.45
0.23
0.3
0.23
0.3
0.45
0.15
0.3
0.45
0.23
0.4
0.44
0.48
0.4
0.45
0.5
0.4
0.5
0.5
0.5
Model Provider
BlackRock Intermediate Taxable Fixed
Income
BlackRock Laddered Municipal (10‐20
Year) Fixed Income
BlackRock Laddered Municipal (1‐10
Year) Fixed Income
BlackRock Laddered Municipal (1‐5
Year) Fixed Income
BlackRock Large Cap Value
BlackRock Long‐Term Municipal Fixed
Income
BlackRock Short‐Term Municipal Fixed
Income
BlackRock Short‐Term Taxable Fixed
Income
BNYM Walter Scott International Stock
ADR
Boston Partners All Cap
Boston Partners International Equity
ADR
Boyd Watterson All ETF Ultra Enhanced
Core
Boyd Watterson Investment Grade
Intermediate
0.3
Boyd Watterson Limited Duration*
Boyd Watterson Ultra Enhanced Core* 0.3
0.5
Brandes Emerging Markets Value
Equity ADR
Brown Advisory Large‐Cap Sustainable
Growth
Capital Wealth Planning Enhanced
Dividend Income
Causeway Global Value ADR
0.38
Causeway International Value ADR
0.45
Cincinnati High Yield Fixed Corp Bond
0.4
ClearBridge Appreciation ESG
0.4
ClearBridge Dividend ESG Strategy
0.48
ClearBridge Dividend Strategy
0.48
0.43
ClearBridge Large Cap Value
Cohen & Steers US Realty Total Return 0.32
0.43
ClearBridge Small Cap Growth
0.48
Columbia Contrarian Core
0.4
Columbia Dividend Income
Model Provider
Annual Fee
Dana Large Cap Equity
0.4
Dana Municipal Bond*
0.45
Dana Small Cap Core Equity
0.3
Dana Unconstrained Equity
0.5
Dean Capital Mid Cap Value
0.45
EARNEST Partners Mid Cap Core
0.48
EARNEST Partners Mid Cap Value
0.48
Earnest Partners Small Cap Core
0.5
EARNEST Partners Small Cap Value
0.5
0.35
Federated Core Plus
Federated International Strategic Value 0.45
Federated Strategic Value Dividend
Franklin Intermediate Fixed Income
Franklin Intermediate Muni*
Franklin Templeton Dow Jones U.S.
Select Dividend - Canvas Tax Managed
Account
Franklin Templeton S&P 1500 - Canvas
Tax Managed Account
Franklin Templeton S&P 500 - Canvas
Tax Managed Account
Franklin Templeton S&P ADR - Canvas
Tax Managed Account
GW&K Core Bond*
Harding Loevner International Equity
ADR
Invesco Investment Grade Floating
Bond
Invesco Tax Free Limited Term
Ithaka Growth
Janus Henderson Mid Cap Growth
Jennison International Equity
Opportunities
Jennison Large Cap Growth Equity
Jensen Quality Growth Discipline
John Hancock US Small Cap Core
JP Morgan Equity Income
Kayne Anderson Rudnick Small Cap
Lazard Emerging Markets Equity Select
ADR
Lazard International Quality Growth
ADR
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Portfolio Solutions Strategist Program
September 8, 2026
Annual Fee
0.2
0.2
0.4
Annual Fee
0.4
0.4
0.4
0.45
0.27
0.4
0.27
0.25
0.25
0.15
0.15
0.45
0.4
0.43
0.55
0.02
0.2
0.2
0.5
0.5
0.55
0.2
0.2
0.45
0.38
0.17
0.2
0.2
0.2
0.2
0.2
0.2
0.45
0.3
0.3
0.25
0.28
0.17
0.17
0.17
0.17
0.17
0.23
0.4
0.28
0.4
0.5
0.6
0.45
0.45
0.45
0.38
0.25
Model Provider
Lazard US Equity Select Tax‐Aware
Leeward Mid Cap Value
Leeward Small Cap Value
Loomis Sayles Large Cap Growth
Lord Abbett Intermediate Tax‐Exempt
Fixed Income
Lord Abbett Long Tax Exempt Fixed
Income
Madison Mid‐Cap Equity
Mar Vista Strategic Growth
MFS Large Cap Growth
Miller/Howard MLP Strategy
Morningstar Absolute Return Strategy‐
BNY
Morningstar All‐Cap Equity
Morningstar Dividend Managed
Neuberger Small Cap Intrinsic Value
(SCIV)
Neuberger Berman International ADR
Nuveen Dividend Growth
Nuveen Intermediate Municipal Fixed
Income
Nuveen Long Term Municipal
Nuveen Municipal Ladder 10‐25 Years
Nuveen Municipal Ladder 1‐10 Years
Nuveen Municipal Ladder 1‐15 Years
Nuveen Municipal Ladder 1‐7 Years
Nuveen Municipal Ladder 5‐15 Years
PIMCO 1‐5 yr Corporate Ladder
PIMCO Low Duration
PIMCO Municipal Income Opportunity
PIMCO Total Return
Polen Global Growth ADR
Polen U.S. Small Company Growth
Principal US Small Cap Equity
Principal US Small Cap Value
Principal Real Estate Securities
Principal Spectrum Tax Advantaged
Preferred Securities
QRG QP: Market Series All Cap Core**
0.2
Model Provider
QRG QP: Market Series All Cap Core ‐
Low Minimum**
QRG QP: Market Series Global**
QRG QP: Market Series Emerg Mrkts
ADR**
QRG QP: Market Series Emerg Mrkts
ADR ‐ Low Minimum**
QRG QP: Market Series Intl ADR**
QRG QP: Market Series Intl ADR ‐Low
Minimum**
QRG QP: Market Series Large Cap
Core**
QRG QP: Market Series Large Cap Core
‐ Low Minimum**
QRG QP: Market Series Large Cap
Dividend Income**
QRG QP: Market Series Large Cap
Dividend Income ‐ Low Minimum**
QRG QP: Market Series Large Cap
Growth**
QRG QP: Market Series Large Cap
Growth ‐ Low Minimum**
QRG QP: Market Series Large Cap
Value**
QRG QP: Market Series Large Cap Value
‐ Low Minimum**
QRG QP: Market Series Mid Cap
Growth**
QRG QP: Market Series Mid Cap
Value**
QRG QP: Market Series Small Cap
Core**
QRG QP: Market Series Small Cap Core
‐ Low Minimum**
QRG QP: Sustainable Emerging Markets
ADR Portfolio**
QRG QP: Sustainable International
ADR**
QRG QP: Sustainable Large Cap Core ‐
Catholic Values**
QRG QP: Sustainable Large Cap Core‐
Gender and Diversity**
QRG QP: Sustainable Large Cap Core
Portfolio ‐ ESG**
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Portfolio Solutions Strategist Program
September 8, 2026
Annual Fee
0.25
Annual Fee
0.5
0.42
0.4
0.3
0.095
0.095
0.4
0.42
0.4
0.45
0.55
0.45
0.55
0.45
0.45
0.4
0.45
0.45
0.45
0.4
0.5
0.48
0.38
Model Provider
T. Rowe US Large‐Cap Core Equity
Managed Account
Tandem Large Cap Core
The London Company Income Equity
Managed Account
The London Company SMID Managed
Account
Tributary Small Cap Core
TS&W Mid Cap Value Managed
Account
WCM Quality Global Growth Managed
Account
WCM Focused Growth International
Managed Account
WestEnd Large Cap Core
Westfield Mid Cap Growth Equity
Managed Account
Westwood Small Cap Managed
Account
Westwood Salient MLP
Westwood SMidCap Managed Account 0.45
0.42
WST Asset Manager Credit Select Risk
Managed Account
0.38
Model Provider
QRG QP: Sustainable Small Cap Core
Portfolio ‐ ESG**
QRG QP: SustainableGlobal Climate**
QRG: 1-10 Yr Corp Ladder
QRG: 1-10 Yr Muni Ladder
RNC Genter Muni Quality Intermediate 0.3
0.3
Sage Advisory Tactical ETF Core Plus
Fixed Income Managed Account
Schafer Cullen Global High Dividend
Value ADR Managed Account
Schafer Cullen International High
Dividend ADR Managed Account
Schroders International Alpha ADR
Managed Account
Segall Bryant & Hamill Small Cap
Growth Managed Account
Stonebridge Tax‐Advantaged QDI
Preferred Securities Managed Account
Suncoast Large Cap Growth Managed
Account
T. Rowe International Core Equity
Managed Account
T. Rowe Price US Growth Stock
Managed Account
T. Rowe Price US Value Equity
Managed Account
*Strategist Traded Model
**Tiered Fee Schedule ‐ Maximum Rate is Displayed
Calculation of Account Fees
The Program Fee and the Strategist Fee will be paid in advance following the end of each calendar quarter for
the upcoming quarter and will be calculated on the last business day of the quarter as follows. The Program Fee
is calculated based upon the average daily market value of the total assets in the Account over the prior
calendar quarter, including cash holdings. Cash holdings in excess of 7.5% (operational cash purposes i.e.,
trading and account maintenance needs) will be excluded from the average daily market value calculation when
the Program fee is calculated. The Strategist Fee is calculated based on the average daily market value of assets
in the Account invested pursuant to the applicable Investment Model(s), including any portion of such assets
maintained in cash, money market funds or other short‐term vehicles pursuant to the applicable Investment
Model(s), over the prior calendar quarter. Because the Strategist Fee differs based upon the investment options
selected for the Account, the actual aggregate fees charged to the Account will be based upon the fees
attributable to the investment options included in the Account at the time of the fee calculation (i.e. , the last
business day of the calendar quarter). Accordingly, it is important to note that changes in the Account’s asset
allocation caused by rebalancing, as well as changes among the types of investment options, during a particular
calendar quarter will cause the aggregate of the Program Fee and the Strategist Fee to be higher or lower than
such aggregate amount would have been if calculated based on the composition of the investment options
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Portfolio Solutions Strategist Program
September 8, 2026
actually held in the Account during the relevant calendar quarter. Upon your request, we will provide you with a
detailed explanation of the fee calculation which will allow you to recalculate the fees should you so desire.
If your Account is new, you will pay an initial fee after the date that National Financial, the custodian, receives
the initial assets of your Account. An adjustment to the next quarterly fee will be made for any significant
contributions or distributions that occur during the inception quarter of your Account. With your initial
contribution and for any additional contribution or distribution adjustments, your fee will be calculated for that
portion of the ongoing quarterly Program Fee that relates to the number of days remaining in the calendar
quarter as of the date your Account becomes subject to the Investment Management Agreement or that you
make the additional contribution or distribution, as applicable. This Program Fee will be based on the total
market value of assets in your Account on that date.
If your Account is terminated by you or PNC Wealth Management during a calendar quarter, the fee for that
quarter will be prorated over the number of days that the Account was open during the quarter. Any
overpayment will be refunded to you after the Account is closed. Fees are not prorated for contributions or
withdrawals made during a calendar quarter, except in the case of a new or terminated Account, as outlined
above. If you terminate your Portfolio Solutions Strategist account within 90 calendar days of initial investment,
PNC Wealth Management reserves the right to charge you commissions, according to the Overview of Products
and Services, for transactions executed on your behalf during the time your account was managed, less any pro-
rated advisory fee paid by you.
Additional Fees for Brokerage Services
PNC Wealth Management will charge its standard fees for additional brokerage account services that are not
included in the Program. Such fees include, but are not limited to, account termination/transfer fees, wire
transfer fees, IRA fees and stop payment fees. You should be aware that in some cases, PNCWM retains this
entire fee or marks up the fee our clearing firm, National Financial, charges to PNCWM for these services. This is
a conflict of interest for us because PNCWM has an incentive to utilize a clearing firm that allows us to mark up
designated fees. PNCWM also has incentive to recommend to you services that have been marked-up. Please
refer to the Account Level Fees section of the Overview of Products and Services for details.
Deduction of Account Fees
All fees incurred by the Account will be paid from the cash balance or by selling shares of a money market
mutual fund. If the Account does not have a sufficient cash balance or enough money market mutual fund
shares to cover the fees, we will liquidate other securities as necessary to pay them. Selling securities to pay fees
is subject to the short-term trading policies of Funds and, if your account is taxable, will create tax consequences
for you. You may contact your Financial Advisor if you have any questions regarding the fees charged to your
Account.
Additional Compensation
PNC Wealth Management receives additional compensation, referred to as revenue sharing, from the advisors
or distributors of the mutual funds offered by PNC Wealth Management, which compensates us for
administrative services we provide to them and is based on the level of assets invested in the mutual funds they
advise or distribute. PNC Wealth Management does not receive revenue sharing payments on assets invested in
the Portfolio Solutions Strategist Program and assets invested in Program Accounts are specifically excluded
from revenue sharing calculations. Nevertheless, this creates a conflict of interest for us because PNC Wealth
Management has an incentive to recommend our other advisory programs that do participate in our revenue
sharing program. Additionally, PNC Wealth Management has an incentive to utilize investment managers that
participate in our revenue sharing program. Our independent due diligence process for selecting mutual funds
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Portfolio Solutions Strategist Program
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for our investment advisory programs, excluding Portfolio Solutions Strategist, is designed so that mutual funds
are selected based on objective, investment-related criteria and does not take into account compensation to
PNC Wealth Management. However, only funds for which we receive revenue sharing are considered for
inclusion in this due diligence process. We will not credit your Account for any revenue sharing payments we
receive. For details on revenue sharing received by PNC Wealth Management from advisors or distributors,
please see the following link: https://www.pnc.com/content/dam/pnc-com/pdf/personal/wealth-
management/Additional-Compensation-Disclosure.PDF.
For more information around the compensation a particular mutual fund provider may pay, please refer to the
mutual fund’s prospectus and/or Statement of Additional Information.
Other Expenses
Each Fund in which your Account is invested charges its own separate fund‐level fees and operating expenses,
including, for example, administrative, custody, transfer agent, legal and audit fees and expenses, investment
advisory or management fees, shareholder servicing fees, omnibus accounting fees, fees for sub‐administration,
recordkeeping, print mail services and other expenses. These fees and operating expenses are ultimately borne
by the shareholders invested in the Fund, including you, and will reduce your investment returns. Other classes
of mutual funds have lower fund‐level fees and expenses than those used in this Program. Please review the
relevant Funds’ prospectuses for a full explanation of fund expenses and charges.
While it is the responsibility of each Strategist to select the share class of mutual funds used in its Investment
Model, it is anticipated that Strategists will primarily select share classes eligible for no‐transaction fee trading
available through our custodian’s Institutional No‐Transaction Fee or No-Transaction Fee programs (collectively
“INTF/NTF Eligible” share classes). INTF/NTF Eligible share classes reduce PNC Wealth Management’ overall
program trading costs, which costs would otherwise by payable by PNC Wealth Management. This represents a
conflict of interest for us because it enables PNC Wealth Management to avoid costs and because the INTF/NTF
Eligible share class of a fund that is included in an Investment Model may be more expensive than other share
classes of the same fund that you are eligible to purchase. PNC Wealth Management will not direct any
Strategist to select a specific share class in their Investment Model, however, we may decline to approve
Strategists or Investment Models not expected to use INTF/NTF Eligible share classes. This will limit investment
options available to you in the Program.
INTF/NTF Eligible share classes do not typically charge shareholders 12b‐1 fees or pay those fees to us or our
custodian, which reduces costs to you, as compared to share classes that do pay 12b‐1 fees. Please note that the
mutual funds included in the Program may provide compensation such as fees for omnibus accounting, sub-
administration, shareholder services, recordkeeping, print mail services or other related fees (“Mutual Fund
Compensation”). While we do not expect to receive such fees, PNC Wealth Management will credit to your
Account any Mutual Fund Compensation or 12b-1 fees paid to us in connection with the holdings in your
Account. Our custodian or other entities not affiliated with PNC Wealth Management may receive Mutual Fund
Compensation. PNC Wealth Management is not a party to such arrangements and we will not credit your
Account for Mutual Fund Compensation received by such entities. You should be aware that any Mutual Fund
Compensation paid to entities not affiliated with PNC Wealth Management increases Fund expenses and,
consequently, reduces the investment performance of your account.
PNC Wealth Management receives an annual credit from National Financial (the “Business Development
Credit”). PNCWM is incentivized to select and continue its relationship with National Financial to receive the
Business Development Credit, which is contingent on the fully disclosed clearing agreement with National
Financial remaining in effect. The Business Development Credit is not related to the sale or offer of any specific
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Portfolio Solutions Strategist Program
September 8, 2026
products or services, nor is it dependent upon assets under management. If received, we will retain the Business
Development Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor
does not receive any portion of the Business Development Credit.
Additionally, if under certain circumstances our clearing arrangement with National Financial is terminated prior
to the expiration of our agreement, PNCWM is subject to certain contractual fees and penalties (collectively, the
“Termination Fee”). The Termination Fee creates a strong disincentive for PNCWM to consider clearing
relationships other than National Financial. This creates a conflict of interest for us as we expect to benefit from
the continued recommendation of National Financial as our clearing firm. Additionally, PNCWM is further
incentivized to continue the relationship with National Financial as we may not receive the same incentives from
other clearing firm arrangements, such as receiving particular credits from National Financial or having the
ability to mark-up certain fees to clients.
Additionally, some Funds impose redemption fees depending on the share class, if they are redeemed within a
specified time period, to discourage short‐term trading or for other reasons. The relevant Fund company retains
these redemption charges from the proceeds of the redemption for the benefit of the remaining shareholders of
the Fund. Refer to the prospectus or Statement of Additional Information of relevant Funds for details on each
Funds’ short-term trading policies. The amount of such fees and charges retained will be reflected on your
account trade confirmations.
Purchasing securities in the Program may cost you more or less than purchasing the securities directly from the
funds or through agents of the funds without enrolling in the Program, including through a brokerage account at
PNC Wealth Management. By purchasing mutual funds outside of the Program, you may invest in a single fund
family and obtain “breakpoints” that could lower the cost of the Funds. However, if you purchase mutual fund
shares directly, you may not receive the asset allocation and account monitoring services available via the
Program and may not qualify to invest in share classes available to investors through the Program. In addition,
mutual funds purchased outside the Program may charge commissions, front‐end or back‐end sales cha rges, and
redemption fees, depending on the share class. Finally, Strategists may purchase, for Program Accounts, Fund
share classes that are not eligible to be held outside of the Program. If you own any such share classes in your
Program Account, they will be liquidated upon the termination of your Account from the Program. If your
Account is taxable, this will create tax consequences for you.
Your Account may be invested in Funds for which PNC Wealth Management or one of our affiliates acts as an
advisor, sub‐advisor, or administrator, and receives a fee for such services. Therefore, PNC Wealth Management
or an affiliate receives fees for the services provided to the Funds. The level of advisory or sub‐advisory fees paid
to PNC Wealth Management or its affiliates by such Funds, is disclosed in the Prospectus and/or Statement of
Additional Information of such Funds. The maximum amount of your Account assets that may be invested in
Funds, which pay advisory or sub‐advisory fees to PNC Wealth Management or its affiliates will depend on many
factors, but in certain circumstances may reach 100% of your Account assets. You should ask your Financial
Advisor about these advisory or sub‐advisory fees, and you may terminate your Investment Management
Agreement with PNC Wealth Management at any time if you have any concerns about the level of these fees or
the incentives that they create. PNC Wealth Management has an obligation to invest your assets in a manner
that considers your best interests first. To that end, PNC Wealth Management will take steps to minimize
potential conflicts of interest that arise from investing with Funds that pay PNC Wealth Management or its
affiliates advisory or sub‐advisory fees, to the extent required by applicable federal or state laws. PNC Wealth
Management evaluates the appropriateness of investing your assets in Funds managed by affiliates of PNC
Wealth Management, in the same manner as it evaluates all other Funds available through the Program.
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Strategists may also select for your Account Funds for which the Strategist or an affiliate of the Strategist acts as
an advisor, sub-advisor, or administrator. In these cases, the Strategist or its affiliate will receive fees for the
services provided to the Funds. PNC Wealth Management’ evaluation of Strategists includes an evaluation of
total fees and costs associated with each Strategist. PNC Wealth Management evaluates the appropriateness of
the fee structure of each Strategist and has made a determination that the fee structure is appropriate. You may
ask your Financial Advisor about any conflicts of interest this creates for Strategists and may terminate your
Investment Management Agreement with PNCWM or select a different Strategist if you have any concerns
about the level of fees or the incentives that they create for applicable Strategists.
Cash Balances
Unallocated cash will be automatically swept through the Bank Deposit Sweep Program (“BDSP”) into an
interest-bearing deposit account (“Deposit Account”) at our affiliate, PNC Bank (and, as noted above, are
included in the assets on which Management Fees are charged). The interest rate (“BDSP interest rate”) for
BDSP assets held in the Deposit Account is determined by PNC Bank with input from PNC Wealth Management.
BDSP is the only cash sweep option available to your Program Account. The only exception is in very limited
situations where your account type is not eligible for BDSP (such as participant accounts of employer sponsored
qualified plans) and your funds will be invested in a money market mutual fund selected by us. You should be
aware that although assets held in the Deposit Account are protected by FDIC insurance neither PNC Wealth
Management nor PNC Bank will monitor whether BDSP deposits, individually or in combination with other
deposits you hold at PNC Bank, exceed FDIC insurance limitations. You should review your cash balance held in
the Deposit Account and other PNC Bank accounts to ensure that cash balances do not exceed FDIC insurance
coverage levels, or alternatively, in the event your cash balance exceeds FDIC insurance limitations, that you are
comfortable with the risks associated with having uninsured cash. The rate of return you receive on cash
balances will, in certain market conditions, be less than the Management Fees attributable to such cash
balances. Additional information about FDIC insurance can be found on
https://www.fdic.gov/resources/deposit-insurance/
PNC Bank uses the BDSP program assets to fund its lending activities, allowing PNC Bank to earn revenue based
on the difference between the rate paid to you and the higher rate of interest earned by lending the assets to its
customers. Moreover, PNC Wealth Management receives revenue from PNC Bank based on the assets in the
BDSP, this revenue amount varies depending on market conditions, but will not exceed the current Federal
Funds Target Rate Range – Upper Limit rate (available online at https://fred.stlouisfed.org/series/DFEDTARU)
plus 0.50%. This means PNC Wealth Management benefits in two ways from placing assets in the BDSP (i.e., the
Management Fee and the revenue share from our affiliate). We will not credit any portion of this revenue to
your Program Account. Note that the revenue earned by PNC Wealth Management and our affiliate PNC Bank
will significantly exceed the interest credited to your Program Account from the allocation to BDSP. The revenue
we receive creates a financial incentive for us to select the BDSP as the cash sweep option, and thus is a conflict
of interest for us. Additionally, the revenue we receive is a conflict of interest for us, because we, and our
affiliate, PNC Bank, obtain a financial benefit when your unallocated cash is held through the BDSP in a Deposit
Account. This financial benefit is greater than the financial benefit we would receive if your unallocated cash was
invested through a different cash sweep vehicle such as a money market fund, which could pay you a higher rate
of interest.
For information pertaining to the interest rate spread earned by PNC on all loans, including those generated
from BDSP assets, please see the Net Interest Margin discussion in the most recent Annual Report on Form 10-K
and subsequent Quarterly Reports on Form 10-Q for The PNC Financial Services Group, Inc., available at,
https://investor.pnc.com/financial-information/financial-results.
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Account assets invested through the BDSP typically will pay you less interest – and in some market conditions,
much less interest – than they would if invested in alternative cash sweep vehicles that are available to PNC
Wealth Management such as a money market fund. Accordingly, you should not participate in the Program if
you wish to hold your unallocated cash in another sweep vehicle. (Please note that while BDSP is used as the
sweep option to hold unallocated cash, if your account has an investment allocation to cash, that allocation will
typically be held in money market mutual funds or other short duration securities). The rate of return you
receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to
such cash balances.
You should also know that Strategists utilized in your Program Account will have discretion to select the vehicle
(BDSP, money market mutual fund or other short duration security) for any cash in the Investment Model. For
more information regarding BDSP, including information about FDIC insurance limitations, please see the
PNCWM BDSP Disclosure Document, you may also review the current BDSP interest rate at the following link:
https://www.pnc.com/en/personal-banking/investments-and-retirement/sweep-program-rates.html.
Financial Advisor Compensation
A portion of the fees charged for Program services generally will be paid to your Financial Advisor in connection
with opening your Account, as well as for providing client‐related services within the Program. This
compensation may be more or less than a Financial Advisor would receive if you transacted in a brokerage
account, rather than a managed account in the Portfolio Solutions Strategist Program, and paid separately for
investment advice, brokerage and other services covered by the Program Fee. Therefore, your Financial Advisor
may have greater financial incentive to offer a managed product over a brokerage product. As disclosed above,
certain of our Programs charge a negotiable Program Fee and others charge a negotiable Program Fee plus a
Model Provider Fee, which in certain circumstances may be waived but is not negotiable. Differences in fees for
Model Providers in Programs with a third-party manager, or the absence of such fees in any Program, create a
conflict of interest as such differences provide an opportunity for Financial Advisors to negotiate a higher Fee for
a strategy with lower or no separate Model Provider Fees than they would for strategies that charge a higher
Model Provider Fee. The opportunity to negotiate a higher fee also creates a financial incentive for Financial
Advisors to recommend such Programs and/or Model Providers. The ability of the Financial Advisor to negotiate
a higher Program Fee in these circumstances also provides a financial benefit to PNC Wealth Management,
which retains a portion of the Program Fee. Occasionally, Program Accounts may be reassigned from the
originating Financial Advisor to a new Financial Advisor because the originating Financial Advisor leaves our firm,
takes a new position, or for other reasons. Financial Advisors receive less compensation for accounts reassigned
to them (“Reassigned Accounts”) than accounts they originated and therefore have a conflict of interest because
they have a financial incentive to provide better service to accounts that they have originated versus Reassigned
Accounts. Financial Advisors receive additional compensation when clients add funds to Reassigned Accounts
and have incentive to encourage additional deposits to Reassigned Accounts. PNC Wealth Management has
established policies and procedures reasonably designed to ensure that any recommendation made is suitable
for your unique circumstances. PNC Wealth Management typically will advance to Financial Advisors a portion of
the first year’s estimated fees for clients who invest in the Program. In addition, certain Financial Advisors who
typically work with higher net worth clients can earn enhanced upfront compensation when customers establish
a new advisory account or add new assets into an existing advisory account with us. This compensation creates a
conflict of interest because these Financial Advisors have an additional incentive to encourage clients to place
their funds in investment advisory accounts.
From time to time, PNC Wealth Management initiates incentive programs for its employees including Financial
Advisors. These programs include, but are not limited to, programs that compensate them for attracting new
assets and clients, or for referring business to our affiliates (such as referrals for mortgages, trusts, or insurance
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services); programs that reward them for promoting investment advisory services , in some circumstances by
enhancing revenue credits paid to them in connection with new advisory accounts or additions to existing
advisory accounts, for participating in advanced training, and for improving client service; and programs that
reward Financial Advisors who meet total production criteria.
Financial Advisors who participate in these incentive programs are rewarded with cash and/or non‐cash
compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. These
programs may be partly subsidized by external vendors or our affiliates, such as mutual fund companies,
insurance carriers or money managers. Therefore, our Financial Advisors have a financial incentive to
recommend the programs and services included in these incentive programs over other available products and
services that we offer.
ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS
Account Minimums and Types of Clients
The minimum account size for the Portfolio Solutions Strategist Program is $250,000. PNC Investment may in
certain instances lower the required minimum account size for Accounts invested in certain Investment Models.
We may terminate the advisory services on any Account that falls below minimum account value guidelines
established by the firm on 30 days’ written notice to the Account holder. To avoid termination, you may be
required to deposit additional assets in your Account to remain in the Portfolio Solutions Strategist Program.
Under certain limited circumstances, we may waive the minimum account size requirement.
In addition, Strategists utilized for the Program typically impose their own investment minimums and may limit
or terminate the availability of their Investment Model for Accounts that fall below this minimum. Upon receipt
of such account minimum notices from a Strategist, PNC Wealth Management will use commercially reasonable
efforts to identify another Strategist that is consistent with or substantively similar to the Investment Model
and/or Strategist that has terminated the availability of their Investment Model and resume a continuous
investment program for the Account. The replacement Investment Model may be more expensive than the
Investment Model it replaces. PNC Wealth Management has limited or no ability to waive Strategist minimums.
Collateral Accounts
Under certain circumstances you may elect to pledge the assets in your non‐IRA/ERISA Account as collateral for
a general purpose loan with our affiliate, PNC Bank, or other financial institution (collectively the “Lending
Arrangements”).
When your Account assets are pledged or otherwise used as collateral in connection with Lending
Arrangements, you give the lender certain rights and powers over the assets in the Account. Importantly,
lenders have the right to direct PNC Wealth Management to sell or redeem any and all assets pledged as
collateral for the loan. In the event of a collateral call on the Account, securities will be liquidated from the
Account, which may be contrary to your interests and/or inconsistent with the investment stra tegy for the
Account because positions may be redeemed or liquidated more rapidly (and/or at significantly lower prices)
than might be desirable. You or your Financial Advisor may not be provided with prior notice of the liquidation
of the securities in the Account. Furthermore, you and your Financial Advisor may not be entitled to choose the
securities to be liquidated. After the execution of a collateral call, any remaining securities in the Account may
be lower in value than the investment minimums required for the Portfolio Solutions Strategist Program and the
Account may be subject to termination as described above.
You may wish to discuss with your Financial Advisor how a collateral call could impact you if your pledged
Account makes up all, or substantially all, of your overall net worth or investible assets. Any action taken by us,
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or an affiliate, with respect to the assets held in your Account pursuant to the Lending Arrangements will not
constitute a breach of our fiduciary duties as an investment adviser to you under the Portfolio Solutions
Strategist Program.
The costs associated with the Lending Arrangements are not included in the Program Fee you pay under the
Program. Your transaction costs may rise as a result of a collateral call, because securities may be liquidated
under unfavorable market conditions. You should consult with your own independent tax advisor in order to
fully understand the tax implications associated with the Lending Arrangements. The securities subject to the
collateral call will not be liquidated in a manner that considers tax efficiency. PNC Wealth Management does
not provide legal, tax or accounting advice.
You are encouraged to speak with your Financial Advisor to the extent you have questions about the Program,
the Lending Arrangements and how they may impact the management of your Account. You should be aware
that PNC Wealth Management and your Financial Advisor have a conflict of interest because PNC Wealth
Management and your Financial Advisor’s compensation is based on the assets held in your account and
benefits if you enter into a Lending Arrangement instead of withdrawing funds from your account. In
addition, you should be aware that PNC Wealth Management and your Financial Advisor will be
compensated based on the amounts you draw on the credit line. This is a conflict of interest for your Financial
Advisor because he or she has an incentive to recommend Lending Arrangements as opposed to other potential
funding sources, because your Financial Advisor is not compensated for other options. In addition, PNC Bank
generates revenue by charging interest on any loan underwritten by PNC Bank, which represents a further
conflict of interest for PNC Wealth Management.
Qualification criteria and requirements, including but not limited to, approval criteria, underwriting standards,
loan to value requirements, maintenance requirements and asset eligibility vary by program. You should refer
back to the Lending Arrangements and associated documents for the specific terms governing the Lending
Arrangements.
PORTFOLIO MANAGER SELECTION AND EVALUATION
The Portfolio Solutions Strategist Account is managed to diversify your investments and, depending on the
Investment Model(s) selected, may include investments in equity and fixed‐income securities, options, Funds
and money market instruments. Accounts are managed on an individual basis, and our asset allocation and
investment recommendations are determined by and based on our understanding of your financial situation,
investment objectives and risk tolerance. You may impose further reasonable restrictions and guidelines on your
Account, but these will affect the composition and performance of your portfolio.
Model and Strategist Selection and Evaluation
We select the Investment Models and Strategists that are available in the program. The factors influencing the
inclusion of any Investment Model on our list of available Investment Models may include, among other things,
investment objective, past performance, management style, quality of the relevant Strategist, its investment
process, the number and continuity of investment professionals, and its client servicing capabilities. While PNC
Wealth Management is the sole sponsor of the Program, we receive research and assistance in selecting and
reviewing Strategists and Investment Models from affiliates or third parties we contract to provide such services.
Expenses for these services are paid by PNC Wealth Management. We ask relevant Strategists to complete a
questionnaire and provide database information on the firm and statistical analysis of the Strategist’s track
record. We may also conduct interviews with members of the Strategist management. This process is an ongoing
one, and Investment Models or Strategists are added or removed from the Program based on many factors,
either internal or external to a Strategist management. Returns reported by Strategists are derived from sources
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believed to be reliable, but we make no representations or warranties as to the accuracy of such performance
information.
The Investment Models included in the Program include holdings of products managed by investment
management affiliates of PNC Wealth Management including PNC Capital Advisors, LLC, which receive
compensation for their investment advisory and other services. The services provided by our affiliates and the
fees they collect for these services vary and generally are disclosed in each Fund’s prospectus. These fees are
paid directly by the Fund and affect the total return of a shareholder’s investment.
PNC Wealth Management and Other Service Providers to the Program
PNC Wealth Management was formed in 2003, and is a direct, wholly owned subsidiary of PNC Bank. PNC Bank
is a wholly owned subsidiary of The PNC Financial Services Group, Inc., a financial holding company. PNC Wealth
Management is registered with the SEC as an investment advisor and a broker‐dealer. PNC Wealth Management
is a member of FINRA and SIPC and serves as the sponsor of the Program.
PNC Wealth Management does not receive performance‐based fees calculated as a share of capital gains on, or
capital appreciation of, the funds or any portion of the funds or other investments in a client’s Account.
National Financial provides trading, custody and operational services for the Program. National Financial carries
client Accounts, is the custodian for the investments in your Account, reports all the trades in your Account and
effects many such trades. National Financial will provide you with trade confirmations, monthly statements, and
income tax reporting.
PNC Wealth Management has also engaged a service provider to perform certain support services in connection
with the Program, including account rebalancing for the asset allocation models. This service provider is also
responsible for calculating and preparing quarterly performance reports for client accounts and may calculate
the Program Fees and Strategist Fees.
Risks of Investing in the Portfolio Solutions Strategist Program
Investing in securities, including the investments offered through the Program, involves risk of loss that you
should be prepared to bear. There is no guarantee that the elements of the Program, including the asset
allocation models, selection of investment manager models and/or research recommendations will protect
against such loss. Other risks include:
• Market Risk. Market risk is the risk that the price of securities will fall over short or extended periods of
time. Historically, the prices of equity securities have moved in cycles, and the value of an Account’s
investments will fluctuate from day to day. When individual companies are negatively impacted by
industry or economic trends or report poor operating results, the price of securities issued by those
companies will typically decline in response. These factors contribute to price volatility.
• Allocation Risk. A client Account is subject to the risk that asset allocation decisions will not anticipate
market trends correctly. For example, weighting an Account too heavily in equities during a stock market
decline may cause a loss of value. Conversely, investing too heavily in fixed income securities during a
period of stock market appreciation may result in lower total returns.
• Concentration/Diversification Risk. Concentration risk occurs when a client Account holds significant
positions in certain securities, sectors or geographic regions. Concentrated positions can be more
volatile and present a greater risk of loss, especially over the short term.
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• Credit Risk. The value of debt securities is affected by the ability of issuers to make principal and interest
payments. If an issuer cannot meet its payment obligations or if its credit rating is lowered, the value of
its debt securities will typically fall.
•
Interest Rate Risk. The value of fixed‐income investments will typically decline because of an increase in
market interest rates. In addition, in certain low-yield interest rate environments, some short-term
investments may produce negative yield, after accounting for fees, inflation and other expenses.
•
Liquidity Risk. The risk stemming from the lack of marketability of an investment that cannot be bought
or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in unusually wide
bid-ask spreads or large price movements (especially to the downside).
• Stock-Specific (Unsystematic) Risk. Unsystematic risk is unique to a specific company or industry. Also
known as “nonsystematic risk,” “specific risk,” “diversifiable risk” or “residual risk,” in the context of an
investment portfolio, unsystematic risk can be reduced through diversification.
•
International Crisis Risk. From time to time, major political, international or military crises may occur
which could have a significant effect on economic conditions and the financial markets. Such crises,
depending on their timing, location and scale, could cause very high volatility in the financial markets. A
crisis could harm the value of your portfolio, thereby increasing the potential of losses in your portfolio.
• Digital Asset Risk. Digital assets, which may be used in Investment Models offered by Strategists, are
digitally created, stored, and traded on decentralized digital ledgers commonly referred to as
“blockchains.” These assets are not backed or protected by any bank or regulated financial institution.
Digital assets remain highly volatile, with prices subject to sharp and unpredictable movements driven
by various market and non-market forces.
The Program is intended to be a long‐term investment program and does not support market‐timing or frequent
trading. You will be limited to one account level model change per calendar quarter, except as warranted by
changes to your financial situation as agreed by you and PNC Wealth Management. In addition, you will be
limited to one investment manager model change per quarter, except as may be agreed by you and PNC Wealth
Management. Frequent or excessive trading in Portfolio Solutions Strategist accounts are grounds for account
termination, with 30 days’ written notice, by PNC Wealth Management, even if the rules above are not violated.
The determination of frequent and/or excessive trading is solely at the discretion of PNC Wealth Management.
Trading Practices
PNC Wealth Management is an introducing broker-dealer, clearing transactions related to the Program Accounts
through National Financial. PNC Wealth Management has a best execution committee (“BEC”) that meets
regularly to rigorously review data for equity orders executed by National Financial including those orders that
are sent by the Investment Delegate. Such data includes, among other things, speed of execut ion and price
improvement provided by the execution venues selected by National Financial. PNC Wealth Management does
not receive any payment for order flow from the execution venues. The BEC also reviews data for fixed income
trades executed through trading systems used by PNC Wealth Management to ensure that the net prices
obtained are reasonable under the circumstances.
The Program Fee includes the costs of trades executed only for transactions executed through National Financial
on an agency basis. The Program Fee does not include any additional trading expenses incurred when the
Investment Delegate determines to trade away from National Financial, for trades executed in Strategist Traded
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Models (as directed by the Strategists) or for transactions where National Financial acts as principal. The
Investment Delegate will trade away from National Financial when the Investment Delegate determines it is in
your best interest to do so. This can occur when the Investment Delegate is implementing a model change
simultaneously across accounts with many different introducing firms, such as PNC Wealth Management. In
these instances, the Investment Delegate may group together trades from several different introducing firms
and execute those trades through a single broker-dealer. This process is known as Block Trading (“Block
Trading”). Block Trading is intended to reduce the market impact of executing large transactions in a particular
security and can allow clients to get better overall execution prices than if the trades were placed individually.
The Investment Delegate may also trade away from National Financial when it determines that a broker-dealer
other than National Financial is capable of obtaining a better execution price for the trade. This can typically
occur in thinly traded securities or in fixed-income securities. Additionally, Strategist Traded Models are
implemented directly by the Strategist rather than by PNC Wealth Management or the Investment Delegate. A
Strategist of a Strategist Traded Model may trade away from National Financial for the same reasons as
described above. Strategists historically implement substantially all trades in Strategist Traded Models away
from National Financial. Strategists for Strategist Traded Models typically trade fixed income securities away
from National Financial. These trades will incur additional costs per bond or on a per transaction basis. These
costs are embedded in the net price you receive and are not separately disclosed by the executing broker in your
confirmation or statement. PNCWM does not receive any benefit when the Investment Delegate or Strategist
elect to trade away.
In either case, it is important that you understand that you will typically pay any commissions, mark-ups or
mark-downs incurred, in addition to the Program Fee when the Investment Delegate or a Strategist elects to
trade away from National Financial or for transactions where National Financial acts as principal. For additional
information on the trading practices of the Investment Delegate and the Strategists, please see the following
link: https://www.pnc.com/content/dam/pnc-com/pdf/personal/wealth-investments/PNCWM/Trade-Practice-
Disclosure.pdf. Information regarding Investment Delegate and Strategist trading practices is based upon data
provided to us by both the Investment Delegate and the Strategists. We make no representations regarding the
accuracy of the information presented and cannot guarantee that the trading practices reflected in the
information presented will be followed by the Investment Delegate or Strategists in the future.
You should be aware that certain Strategists provide their model portfolio updates to the Investment Delegate
after they make changes to accounts that they manage directly. In these instances, this will impact execution
prices for your Account relative to other accounts in the same investment strategy that are managed directly by
the Strategist. Depending on various factors, including price movements and variations in trade execution, the
performance of your Account will differ from, and be better or worse than, the performance of such other
accounts managed directly by the Strategist. You should also review the Form ADV Part 2 for the Investment
Delegate and, if applicable, the Strategist you have selected, for additional information regarding that firm’s
execution practices.
Proxy Voting
PNC Wealth Management will vote all proxies for securities held in the Program Account on your behalf, unless
you direct otherwise. PNC Wealth Management has retained and delegated our proxy voting power to
Envestnet, a third‐party service provider, to receive proxy statements and to vote shares. Envestnet votes
proxies based on the recommendations of Glass-Lewis & Co. (“Glass-Lewis”), an independent third-party
research provider. Glass-Lewis issues voting recommendations based on its own internal guidelines, which assist
in limiting possible conflicts of interest in voting your proxies.
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We will not vote proxies in accordance with voting instructions received from you. PNC Wealth Management has
adopted policies and procedures to address any conflicts that arise in connection with voting proxies. PNC
Wealth Management may depart from its stated guidelines in order to avoid voting decisions believed to be
contrary to the best interests of its clients. More information regarding our policies and procedures regarding
proxies can be obtained by contacting your Financial Advisor or by calling PNC Wealth Management at (800)
622-7086.
If you choose, you may request to vote your own proxies by providing us with written instructions to deliver all
proxy related materials directly to you for consideration and execution. If you choose this option, proxy
materials typically will be forwarded to you by the custodian for your Account. If this option is selected, PNC
Wealth Management, or its third‐party service provider, will no longer be in a position to vote proxies for any
securities for your Account, including securities over which PNC Wealth Management has investment discretion.
PNC Wealth Management will not advise or act for you with respect to any legal matters for securities held in
your Account, including class actions or bankruptcies. Documents received with respect to such matters will be
forwarded directly to you for your consideration.
CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS
As part of the acceptance and approval process, and by signing the Investment Management Agreement, you
grant us discretionary trading authority over your Account. PNC Wealth Management utilizes information
regarding your financial circumstances, investment goals and objectives and any special written instructions you
may wish to give regarding your Account. Client information is not provided to Strategists.
CLIENT CONTACT WITH PORTFOLIO MANAGERS
Your Financial Advisor will communicate any changes about you to PNC Wealth Management. You will have very
limited, if any, direct contact with the individuals responsible for making investment decisions for the Program
and will have no direct contact with the provider of any Manager Model you might select. You should direct any
inquiries regarding the investment manager to your Financial Advisor.
ADDITIONAL INFORMATION
Disciplinary Information
• On April 11, 2016, PNC Wealth Management entered into a settlement (an “AWC”) with FINRA. Without
admitting or denying the findings, PNC Wealth Management consented to the entry of findings that it
failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales and
failed to apply such waivers to mutual fund purchases by certain retirement plan customers that were
eligible to purchase Class A shares in certain mutual funds without a front‐end sales charge. The findings
also stated that PNC Wealth Management failed to maintain adequate written policies and procedures
or to provide adequate training to assist financial advisors in determining when sales charge waivers
were available for retirement plan customers. PNC Wealth Management was not required to pay a fine,
but consented to be censured and to pay restitution to eligible customers who did not receive sales
charge waivers for fund purchases since July 1, 2009.
• On April 6, 2018, PNC Wealth Management entered into a settlement (“Order”) with the Securities and
Exchange Commission (“SEC”). Without admitting or denying the findings, PNC Wealth Management
consented to the findings that, as a result of the conduct described below, PNCWM willfully violated
Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)-
7 thereunder. The Order finds that the violations resulted from the following conduct of PNCWM: (1)
PNCWM, without adequate disclosure of the associated conflicts of interest, invested advisory clients in
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mutual fund share classes with 12b-1 fees instead of available lower-cost share classes of the same
funds without 12b-1 fees; (2) PNCWM did not disclose a conflict of interest regarding marketing support
payments paid on such mutual fund share classes that charged 12b1 fees; (3) PNCWM improperly
charged advisory fees to client accounts where the investment adviser representative departed the firm
(“Orphaned Accounts”) and where PNCWM failed to assign a new investment adviser representative
within thirty days; and (4) PNCWM failed to adopt and implement written compliance policies and
procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in
connection with its mutual fund share class selection practices and treatment of Orphaned Accounts.
The Order requires PNCWM to cease and desist from committing or causing any violations and any
future violations of Advisers Act Sections 206(2), 206(4), and 207 and Rule 206(4)-7; censures PNCWM;
and requires PNCWM to pay disgorgement of $5,234,856, and prejudgment interest of $612,344, to
compensate advisory clients who were affected by certain conduct detailed in the Order. PNCWM will
pay, in addition to the disgorgement and prejudgment interest described above, disgorgement of
$497,144 in marketing support fees and prejudgment interest thereon of $63,426 to the SEC for the
transfer to the general fund of the United States Treasury. Lastly, PNCWM will pay a civil monetary
penalty of $900,000.
• On April 22, 2024, PNC Wealth Management signed a Final Order with the State of North Carolina
Department of the Secretary of State Securities Division. Without admitting or denying the findings,
PNCWM was ordered to pay civil penalties in the amount of $7,500 and costs of investigation in the
amount of $1,000 resulting from the following conduct: (1) PNCWM and one investment adviser
representative (“IAR”) failed to comply with North Carolina’s IAR registration requirements in violation
of N.C.G.S. §78C-16(a1) in which the IAR transacted advisory business in North Carolina from on or
about December 2021 through on or about October 2023 without being IAR registered; (2) PNCWM was
in violation of N.C.G.S. §78C-18(b) and 18 NCAC 06A .1801(a)(18) by employing the IAR in North Carolina
without the appropriate registration and by not furnishing this information to the IAR’s PNCWM
advisory clients; and (3) PNCWM failed to supervise the IAR’s acts, practices and conduct to ensure
adherence with North Carolina’s IAR registration provisions in violation of N.C.G.S. §78C -19(a)(2)(j) and
18 NCAC 06A .1808.
• On April 24, 2024, PNC Wealth Management signed a Consent Agreement and Order with the
Pennsylvania Department of Banking and Securities. The Department alleged that from on or about
December 2018 until December 2023, PNCWM failed to register at least one employee as an investment
adviser representative in Pennsylvania in violation of Section 301(c.1)(1)(ii) of the Pennsylvania
Securities Act of 1972 (“the 1972 Act”), 70 P.S. § 1-301(c.1)(1)(ii). Without admitting or denying the
findings in the Order, PNCWM agreed to pay a monetary fine of $100,000 and to comply with the
relevant provision of the 1972 Act.
• On September 3, 2024, PNC Wealth Management signed a Settlement Order with the Commonwealth of
Virginia Division of Securities and Retail Franchising. The Division alleged that from on or about February
2019 to June 2024, PNCWM failed to register an investment advisor representative in Virginia in
violation of § 13.1-504 C (ii) of the Virginia Securities Act. Without admitting or denying the findings in
the Order, PNCWM paid $10,000 in monetary penalties and $1,000 in investigation costs.
• On September 18, 2024 PNC Wealth Management entered into an Administrative Consent Agreement
and Order with the District of Columbia’s Department of Insurance, Securities and Banking alleging that
from on or about August 2012 through February 2024, PNCWM failed to register three investment
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advisor representatives in D.C. in violation of D.C. Official Code §§ 31-5602(b)(2) and 31-5605.01(4).
PNCWM paid $162,500 as a civil penalty and $1,080 in unpaid registration fees.
• On June 16, 2025, PNC Wealth Management entered into an agreement (an “AWC”) with FINRA.
Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings
that from at least June 2021, it violated FINRA rules by failing to establish and maintain a reasonably
designed supervisory system, including written supervisory procedures, for the surveillance and
supervision of rates of deferred variable annuity exchanges. PNC Wealth Management was required to
pay a $200,000 fine and to implement a supervisory system and written supervisory procedures
reasonably designed to achieve compliance in surveilling registered representatives’ rates of deferred
variable annuity exchanges consistent with applicable securities laws and regulations, and with
applicable FINRA rules.
Other Financial Industry Activities and Affiliations
PNC Wealth Management’ principal business is that of a full‐service, general securities broker‐dealer and
investment adviser, registered with the SEC and as a member of FINRA. Our primary retail brokerage activities
include the sale of corporate equities, corporate debt, municipal securities and funds, mutual funds, ETFs and
annuities.
PNC Wealth Management is part of a broad financial services organization and is therefore affiliated with other
entities engaged in a variety of financial services businesses. In some cases, the firm has business arrangements
with its affiliates that are material to its advisory business or to its clients. These are described in more detail
below and, in some cases, cause PNC Wealth Management’ or a related person’s interests to diverge from the
best interests of our clients.
PNC Wealth Management is affiliated with the following financial services entities through its parent, The PNC
Financial Services Group, Inc.:
• PNC Bank, National Association is a wholly owned subsidiary of The PNC Financial Services Group, Inc.,
and is a full-service bank engaged in traditional lending, cash and/or treasury management and other
services.
• PNC Capital Advisors, LLC is a wholly owned subsidiary of PNC Bank and provides discretionary fixed
income investment advisory services to institutional accounts.
• PNC Capital Markets LLC is an indirect, wholly owned subsidiary of The PNC Financial Services Group,
Inc. and offers loan syndication, public finance underwriting and advisory services, securities
underwriting and trading, private placements, asset securitizations and merger and acquisition advisory
services.
• PNC Insurance Services, LLC is a wholly owned subsidiary of PNC Wealth Management and a licensed
insurance agency. It provides a variety of insurance products and advice.
Selected conflicts of interest that exist between PNC Wealth Management and its affiliates are discussed below.
Although PNC Wealth Management is committed to acting in the best interests of our clients, in some situations
there are conflicts of interest between the firm’s interests and a client’s interests, or there are conflicts in the
interests of multiple clients. Many of these conflicts of interest are inherent in operating an investment advisory
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business. PNC Wealth Management has adopted policies and procedures that it believes are reasonably
designed to help mitigate these conflicts of interest.
Affiliates of PNC Wealth Management provide advice to their clients with respect to investment strategies that
are similar to or the same as strategies offered by PNC Wealth Management. Those advisory affiliates may
purchase on behalf of their clients the same securities that PNC Wealth Management may purchase for our
clients. As a result, the interests of PNC Wealth Management’ clients may conflict with the interests of the
clients of these affiliated advisors. For example, if an investment advisor affiliate implements a portfolio
management decision for its client ahead of, or contemporaneously with, a decision PNC Wealth Management
makes for its client(s), the market impact of the decision made by the firm’s advisory affiliate could result in one
or more of PNC Wealth Management’ clients receiving less favorable trading results than they otherwise would.
PNC Wealth Management’ trade allocation and trade aggregation procedures do not typically apply to portfolio
management decisions and trading executed by investment advisory affiliates for their clients that are not
clients of PNC Wealth Management.
Affiliate Transactions
PNC Wealth Management or its affiliates may from time to time recommend investments in transactions in
which PNC Wealth Management or its affiliates act as financial advisor or a broker‐dealer, or in securities which
are underwritten, issued, packaged or serviced by an affiliate.
Moreover, PNC Wealth Management may act as a broker in executing your purchase or sale for your account of
a debt security from or to PNC Capital Markets, a brokerage affiliate. Additionally, your Financial Advisor may
recommend you purchase a mutual fund advised by PNC Capital Advisors, an affiliated registered investment
adviser. These affiliates receive compensation as a result of these transactions, if these transactions were to
occur.
PNC TotalRewards Program (Affiliate Banking Program Disclosure)
PNC Bank, National Association (“PNC Bank”), an affiliate of PNC Wealth Management, offers a
relationship‑based loyalty program known as the PNC TotalRewards Program. Clients who elect to enroll in the
program and who satisfy applicable eligibility requirements established by PNC Bank may receive certain
non‑investment benefits on eligible PNC banking or investment accounts, such as fee adjustments or other
account‑related benefits. Participation in the PNC TotalRewards Program is voluntary and subject to separate
terms and conditions administered by PNC Bank, which may change from time to time.
PNC Wealth Management does not sponsor, administer, or control the PNC TotalRewards Program and does not
determine program eligibility or benefits. A client’s participation in the program does not affect the investment
advice provided by PNC Wealth Management, and investment recommendations are made independently of,
and without regard to, program enrollment or benefits.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
PNC Wealth Management has adopted a Code of Ethics, which consists of certain general principles, including
the following:
• Advisory personnel must place client interests before their own
• The personal securities transactions of our personnel must avoid even the appearance of a conflict with
client interests
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• Our personnel must avoid actions or activities that allow, or appear to allow, them to profit or benefit
from their position with respect to clients, or that would otherwise bring into question their
independence or judgment
• From time to time, PNC Wealth Management personnel may accept training, business entertainment or
gifts of de minimis value from product vendors. PNC Wealth Management has adopted policies and
procedures reasonably designed to ensure any such activity does not impact our personnel’s ability to
act in the best interests of our clients
•
In addition, the Code of Ethics requires our employees to report their personal securities transactions
and holdings. A copy of our Code of Ethics will be provided to any client or prospective client upon
request.
Our employees are also subject to the PNC Employee Conduct Policies, which cover matters including
compliance with law, conflicts of interest, insider trading, outside activities , and safeguarding confidential
information.
Client Reports
As part of the Portfolio Solutions Strategist Program, we will provide periodic reports to assist you in monitoring
and assessing the performance of your Account. These reports will contain information regarding trades,
investment return, and selected benchmark comparisons. These reports may also contain letters, notices and
other important information regarding the Model Managers and any changes to the Account during the period.
Client Referrals and Other Compensation
Your Financial Advisor may refer you to PNC Bank or other PNC Wealth Management affiliates for additional
products or services and will generally receive compensation for such referrals. A portion of the fees charged for
the Portfolio Solutions Strategist Program services described in this Brochure may be paid to your Financial
Advisor in connection with the introduction of Accounts as well as for providing client‐related services within the
Programs. This compensation may be more or less than a Financial Advisor would receive if you paid separately
for investment advice, brokerage and/or other services.
Certain employees of PNC Bank’s Wealth Management and/or Private Client Group receive compensation in
connection with referrals to PNC Wealth Management.
PNC Wealth Management has related persons who are investment advisors who act as general partners in
partnerships in which our clients may be solicited. PNC Wealth Management would not have knowledge of such
solicitations should they occur, and consequently, would not be a participant in them, nor would we receive any
compensation for them.
Financial Information
In certain circumstances, PNC Wealth Management would be required to provide you with financial information
or disclosures about our financial condition. Currently, no such circumstances exist for PNC Wealth
Management.
PNC Wealth Management has no financial commitments that impair our ability to meet our contractual and
fiduciary commitments to our clients and has never been the subject of a bankruptcy proceeding.
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