ADV 2A

F O R M A D V P A R T 2 A D I S C L O S U R E B R O C H U R E Powers Investment Advisory Corporation Office Address: 279 Skye Road Highland Heights, OH 44143 Tel: 440-442-4483 Fax: 440-442-4485 Andrew@powersiac.com Website: www.powersiac.com OCTOBER 26, 2026 This brochure provides information about the qualifications and business practices of Powers Investment Advisory Corporation. Being registered as an investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 440-442-4483. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Additional information about Powers Investment Advisory Corporation (CRD #110401) is available on the SEC’s website at www.adviserinfo.sec.gov i  Item 2: Material Changes Annual Update The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update Since the last filing of this brochure on November 20, 2025, the following changes have been made: • Item 4 amended to disclose updated assets under management. • Updated Item 15 to add 3rd party SLOA information. Full Brochure Available This Firm Brochure being delivered is the complete brochure for the Firm. ii  Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Annual Update ................................................................................................................................................................... ii Material Changes since the Last Update.................................................................................................................. ii Full Brochure Available .................................................................................................................................................. ii Item 3: Table of Contents ................................................................................................................... iii Item 4: Advisory Business .................................................................................................................. 5 Firm Description ............................................................................................................................................................... 5 Types of Advisory Services ........................................................................................................................................... 5 Client Tailored Services and Client Imposed Restrictions ............................................................................... 5 Wrap Fee Programs ......................................................................................................................................................... 5 Client Assets Under Management .............................................................................................................................. 5 Item 5: Fees and Compensation ....................................................................................................... 5 Method of Compensation and Fee Schedule .......................................................................................................... 5 Client Payment of Fees ................................................................................................................................................... 6 Additional Client Fees Charged ................................................................................................................................... 6 Prepayment of Client Fees ............................................................................................................................................ 7 External Compensation for the Sale of Securities to Clients ........................................................................... 7 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 7 Sharing of Capital Gains ................................................................................................................................................. 7 Item 7: Types of Clients ....................................................................................................................... 7 Description .......................................................................................................................................................................... 7 Account Minimums .......................................................................................................................................................... 7 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 7 Methods of Analysis ......................................................................................................................................................... 7 Investment Strategy ........................................................................................................................................................ 7 Security Specific Material Risks .................................................................................................................................. 8 Item 9: Disciplinary Information ................................................................................................... 11 Criminal or Civil Actions ............................................................................................................................................. 11 Administrative Enforcement Proceedings .......................................................................................................... 11 Self- Regulatory Organization Enforcement Proceedings ............................................................................ 11 iii  Item 10: Other Financial Industry Activities and Affiliations ............................................. 11 Broker-Dealer or Representative Registration ................................................................................................. 11 Futures or Commodity Registration ...................................................................................................................... 11 Material Relationships Maintained by this Advisory Business and Conflicts of Interest ................ 11 Recommendations or Selections of Other Investment Advisors and Conflicts of Interest ............. 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................................................................................... 12 Code of Ethics Description ......................................................................................................................................... 12 Investment Recommendations Involving a Material Financial Interest and Conflict of Interest. 12 Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest 12 Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest .................................................................................................................. 13 Item 12: Brokerage Practices ......................................................................................................... 13 Factors Used to Select Broker-Dealers for Client Transactions ................................................................. 13 Aggregating Securities Transactions for Client Accounts ............................................................................. 14 Item 13: Review of Accounts ........................................................................................................... 14 Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved ............................................................................................................................................................................. 14 Review of Client Accounts on Non-Periodic Basis ........................................................................................... 14 Content of Client Provided Reports and Frequency ........................................................................................ 15 Item 14: Client Referrals and Other Compensation ................................................................ 15 Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest ............................................................................................................................................................................... 15 Advisory Firm Payments for Client Referrals .................................................................................................... 16 Item 15: Custody .................................................................................................................................. 16 Account Statements ...................................................................................................................................................... 16 Item 16: Investment Discretion ..................................................................................................... 16 Discretionary Authority for Trading...................................................................................................................... 16 Item 17: Voting Client Securities ................................................................................................... 17 Proxy Votes ...................................................................................................................................................................... 17 Item 18: Financial Information ...................................................................................................... 17 Balance Sheet .................................................................................................................................................................. 17 Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients ............................................................................................................................................................................ 17 Bankruptcy Petitions during the Past Ten Years .............................................................................................. 17 iv  Item 4: Advisory Business Firm Description Powers Investment Advisory Corporation (“PIAC”) was founded in 1984. William Powers and Andrew Powers are co-owners. Types of Advisory Services ASSET MANAGEMENT PIAC offers discretionary asset management services to advisory Clients. PIAC will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize PIAC discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. Client Tailored Services and Client Imposed Restrictions The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. Agreements may not be assigned without written Client consent. Wrap Fee Programs PIAC does not sponsor any wrap fee programs. Client Assets Under Management PIAC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: $127,222,867 $0 Date Calculated: September 30, 2026 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT PIAC offers discretionary direct asset management services to advisory Clients. PIAC charges an annual investment advisory fee on the total assets under management as follows : Annual Fee 1.00% 0.80% Quarterly Fee .25% .20% 0.60% .15% Assets Under Management First $2,500,000 ($0-$2,500,000) Your next $2,500,000 ($2,500,000.01 - $5,000,000) Subsequent amounts ($5,000,000.01+) This is a tiered/blended fee schedule, the asset management fee is calculated by applying different rates to different portions of the portfolio. PIAC may group certain related Client accounts for the purposes of achieving the minimum account size and determining the annualized fee. 5  For example (based on quarterly billing period): Client with $5,500,000 under management would pay $12,000.00 on an quarterly basis. AUM Quarterly fee Total First $2,500,000 x 0.25% = $6,250.00 Next $2,500,000 x 0.20% = $5,000.00 Next $500,000 x 0.15% = $750.00 Total for the quarter $12,000.00 In addition, PIAC charges an annual administrative fee. The administrative fee is as follows: Client Assets Under Management Administrative Fee Up to $75,000 $250 $75,001 - $125,000 $175 $125,001 - $150,000 $100 Above $150,000 Fee waived Billing cycles are January, April, July and October. The annual fee is not negotiable. Fees are billed quarterly in arrears based on the amount of assets managed as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. After five (5) business days, the Client may cancel by providing written notice to PIAC and PIAC may terminate advisory services with thirty (30) days written notice to the Client. For accounts opened or closed mid-billing period, fees will be prorated based on the days services are provided during the given period. All unpaid earned fees will be due to PIAC. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. Client Payment of Fees Fees for asset management services are deducted from a designated Client account to facilitate billing or they may pay PIAC directly. The Client must consent in advance to direct debiting of their investment account. Additional Client Fees Charged Custodians may charge transaction fees and other related costs on the purchases or sales of mutual funds, equities, bonds, options and exchange-traded funds. Mutual funds, money market funds and exchange-traded funds also charge internal management fees, which are disclosed in the fund’s prospectus. PIAC does not receive any compensation from these fees. All of these fees are in addition to the management fee you pay to PIAC. For more details on the brokerage practices, see Item 12 of this brochure. 6  Prepayment of Client Fees PIAC does not require any prepayment of fees. External Compensation for the Sale of Securities to Clients Investment Advisor Representatives of PIAC receive external compensation for the sale of securities to clients as a registered representative of LPL Financial, a broker-dealer. This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. As registered representatives, they do not charge advisory fees for the services offered through LPL Financial. This conflict is mitigated by disclosures, procedures, and PIAC’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another registered representative of their choosing. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. PIAC does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for PIAC to recommend an investment that may carry a higher degree of risk to the Client. Item 7: Types of Clients Description PIAC generally provides investment advice to individuals and high net worth individuals. Client relationships vary in scope and length of service. Account Minimums PIAC does not require a minimum to open an account. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange Commission. Investment Strategy The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by 7  providing written notice to PIAC. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. When PIAC’s Advisors constructs a new portfolio for a Client, they begin with a very basic risk tolerance questionnaire. The Advisors use this assessment along with the Client's own description of their risk profile to establish a very basic asset allocation model. Once the Advisors have established the percentages for each asset category, they begin to search for specific investments which generally include, but are not limited to, various equity and fixed income mutual funds (including “no-load” funds), REITs, individual equities, bonds and other fixed income securities, ETFs, and brokered CDs. The Advisors search for securities based on the Client’s objectives and risk tolerance (i.e. growth versus income). To aid in their search, PIAC purchases research from several sources including ValueLine, Argus Research, TheStreet, Thomson Reuters, CFRA, and Morningstar. The Advisors use the screening tools and research reports from these providers to determine which securities might be timely buys. In addition, The Advisors search for stocks with above average dividend yields at reasonable prices and P/E ratios. The Advisors sell securities as the Client’s investment objectives change; when the securities have higher than average gains; or if the future outlook for any given stock or security turns unfavorable (i.e. lowered earnings guidance or estimates, etc.). PIAC’s overall strategy, based on the demographics of its client base, is to manage accounts to generate income (especially given the current market trends). PIAC’s Advisors don't use any one specific investment strategy. The Advisor’s investment strategy is tailored specifically to the needs of each client. Security Specific Material Risks All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with PIAC: • Market Risk: The prices of securities in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. 8  • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the client’s portfolio may suffer. • Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. lower trading volume, which may Smaller companies may also have a disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate. • Investment Companies Risk: When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de- listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Adviser has no control over the risks taken by the underlying funds in which client invests. • Foreign Securities Risk: Funds in which clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, 9  social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies. • Long-term purchases: Long-term investments are those vehicles purchased with the intention of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. • Short-term purchases: Short-term investments are typically held for one year or less. Generally there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation. • Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved. • Leveraged Risk: The risks involved with using leverage may include compounding of returns (this works both ways – positive and negative), possible reset periods, volatility, use of derivatives, active trading and high expenses. inequitable treatment of minority and/or • Foreign Investment Risk: Investments in foreign securities may be riskier than U.S. investments because of factors such as, unstable international, political and economic conditions, currency fluctuations, foreign controls on investment and currency exchange, foreign governmental control of some issuers, potential confiscatory taxation or nationalization of companies by foreign governments, withholding taxes, a lack of adequate company information, less liquid and more ineffective or detrimental government volatile exchanges and/or markets, regulation, varying accounting standards, political or economic factors that may severely limit business activities, and legal systems or market practices that may non-domestic permit investors. Investments in emerging markets may involve these and other significant risks such as less mature economic structures and less developed and more thinly- traded securities markets. • Preferred stock: One risk of preferred stocks is that shares are often sensitive to changes in interest rates. Investors in these vehicles don't enjoy the same voting rights as common shareholders. • Bonds: The risks associated with bonds include the inverse relationship between interest rates and bond prices. As interest rates fall, bond prices rise. Conversely, 10  when interest rates rise, bond prices tend to fall. Investors must also be aware of credit/default risk, corporate bonds aren’t guaranteed by the full faith and credit of the U.S. government, but instead depend on the issue’s ability to repay the debt. Item 9: Disciplinary Information Criminal or Civil Actions PIAC and its management have not been involved in any criminal or civil action. Administrative Enforcement Proceedings PIAC and its management have not been involved in administrative enforcement proceedings. Self- Regulatory Organization Enforcement Proceedings PIAC and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of PIAC or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration PIAC is not registered as a broker- dealer, however, Managing Member Andrew Powers is a registered representative of LPL Financial, a FINRA/SIPC broker-dealer. Futures or Commodity Registration Neither PIAC nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Andrew Powers has a financial affiliated business as an independent insurance agent. Approximately 5% of his time is spent on this activity. In addition, Mr. Powers is a registered representative with LPL Financial. Approximately 10% of his time is spent on this activity. He will offer Clients services from those activities. As an insurance agent and registered representative, he will receive separate yet typical compensation. William Powers has a financial affiliated business as an independent tax preparer. Approximately 8% of his time is spent in this activity. He will offer Clients services from this activity. As a tax preparer, he will receive separate yet typical compensation. These practices represent conflicts of interest because it gives an incentive to recommend products or services based on the commission or fee amount received. This conflict is mitigated by disclosures, procedures and the firm’s fiduciary obligation to place the best interest of the Client first and the Clients are not required to purchase any products or services. Clients have the option to purchase these products or services through another tax preparer of their choosing. Recommendations or Selections of Other Investment Advisors and Conflicts of Interest PIAC does not select or recommend other investment advisors. 11  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description include employees and/or The affiliated persons (affiliated persons independent contractors) of PIAC have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of PIAC affiliated persons and addresses conflicts that may arise. The Code defines acceptable behavior for affiliated persons of PIAC. The Code reflects PIAC and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. PIAC’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of PIAC may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. PIAC’s Code is based on the guiding principle that the interests of the Client are our top priority. PIAC’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non-public. PIAC will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Investment Recommendations Involving a Material Financial Interest and Conflict of Interest PIAC and its affiliated persons do not recommend to Clients securities in which we have a material financial interest. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest PIAC and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide PIAC with copies of their brokerage statements. 12  The Chief Compliance Officer of PIAC is Andrew Powers. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest PIAC does maintain a firm proprietary trading account and affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, the firm and affiliated persons are required to disclose all reportable securities transactions as well as provide PIAC with copies of their brokerage statements. The Chief Compliance Officer of PIAC is Andrew Powers. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions PIAC will recommend the use of a particular broker-dealer based on their duty to seek best execution for the client, meaning they have an obligation to obtain the most favorable terms for a client under the circumstances. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. PIAC will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. PIAC relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by PIAC. PIAC does not receive any portion of the trading fees. PIAC will recommend the use of Charles Schwab & Co., Inc. • Research and Other Soft Dollar Benefits The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by PIAC from or through a broker-dealer in exchange for directing Client transactions to the broker-dealer. Although PIAC has no formal soft dollar arrangements, PIAC may receive products, research and/or other services from custodians or broker-dealers connected to client transactions or “soft dollar benefits”. As permitted by Section 28(e) of the Securities Exchange Act of 1934, PIAC receives economic benefits as a result of commissions generated from securities transactions by the custodian or broker-dealer from the accounts of PIAC. PIAC cannot ensure that a particular client will benefit from soft dollars or the client’s 13  transactions paid for the soft dollar benefits. PIAC does not seek to proportionately allocate benefits to client accounts to any soft dollar benefits generated by the accounts. A conflict of interest exists when PIAC receives soft dollars which could result in higher commissions charged to Clients. This conflict is mitigated by the fact that PIAC has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. • Brokerage for Client Referrals PIAC does not receive client referrals from any custodian or third party in exchange for using that broker-dealer or third party. • Directed Brokerage Clients who direct brokerage outside our recommendation may be unable to achieve the most favorable execution of client transactions as client directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices. Aggregating Securities Transactions for Client Accounts PIAC is authorized in its discretion to aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of PIAC. All Clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis. If aggregation if not allowed or infeasible and individual transactions occur (e.g., withdrawal or liquidation requests, odd-late trades, etc.) an account may potentially be assessed higher costs or less favorable prices than those where aggregation has occurred. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Account reviews are performed periodically by the Advisors of PIAC. Account reviews are conducted quarterly for all clients with assets under management in excess of $2,000,000; tri-annually for clients with assets between $1,000,000 and $2,000,000; every five months for clients with assets between $500,000 and $1,000,000; and semi-annually for clients with assets below $500,000. Account reviews are performed more frequently when market conditions dictate. Reviews of Client accounts include, but are not limited to, a review of Client documented risk tolerance, adherence to account objectives, investment time horizon, and suitability criteria, reviewing target allocations of each asset class to identify if there is an opportunity for rebalancing, and reviewing accounts for tax loss harvesting opportunities. Review of Client Accounts on Non-Periodic Basis Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new investment information, and changes in a Client's own situation. 14  Content of Client Provided Reports and Frequency Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by PIAC’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs. Performance reports will be provided by PIAC at least quarterly to Clients with assets under management. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Mr. Andrew Powers receives external compensation for the sale of securities to Clients as a registered representative of LPL Financial, a broker-dealer. LPL also provides various benefits and/or payments to Andrew Powers that are new to the LPL platform to assist them with the costs (including foregone revenues during account transition) associated with transitioning their business to LPL (collectively referred to as “Transition Assistance”). The proceeds of such Transition Assistance payments are intended to be used for a variety of purposes, including but not necessarily limited to, providing working capital to assist in funding the Andrew Powers’ business, satisfying any outstanding debt owed to the Andrew Powers‘ prior firm, offsetting account transfer fees (ACATs) as a result of the Andrew Powers’ clients transitioning to LPL’s custodial platform, technology set-up fees, marketing and mailing costs, stationary and licensure transfer fees, moving expenses, office space expenses, staffing support and termination fees associated with moving accounts. The amount of the Transition Assistance payments is often significant in relation to the overall revenue earned or compensation received by the Andrew Powers at their prior firm. Such payments are generally based on the size of the Andrew Powers’ business established at the prior firm. These payments are generally in the form of payments or loans to the Andrew Powers with favorable interest rate terms as compared to other lenders, which are paid by LPL or forgiven by LPL based on years of service with LPL (e.g., if the Andrew Powers remains with LPL for 5 years) and/or the scope of business engaged in with LPL. LPL does not verify that any payments made are actually used for such transition costs. The receipt of Transition Assistance creates a conflict of interest in that Andrew Powers has a financial incentive to recommend that a client open and maintain an account with the IAR and LPL for advisory, brokerage and/or custody services, and to recommend switching investment products or services where a client’s current investment options are not available through LPL, in order to receive the Transition Assistance benefit or payment, and in cases of businesses not supported by LPL, to further recommend that a client’s current holdings be reinvested in a program offering LPL does support. LPL and Andrew Powers’ attempt to mitigate these conflicts of interest by evaluating and recommending that clients use LPL’s services based on the benefits that such services provide to clients, rather than the Transition Assistance earned by any particular Andrew Powers. However, clients should be aware of this conflict and take it into consideration in making a decision whether to establish or maintain a relationship with LPL. If LPL makes a loan to Andrew 15  Powers, there is also a conflict of interest because LPL’s interest in collecting on the loan affects its ability to objectively supervise the registered representatives. Advisory Firm Payments for Client Referrals PIAC does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to carefully compare the account statements received directly from their custodians to any documentation or reports prepared by PIAC. PIAC is deemed to have limited custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of PIAC. PIAC is also deemed to have custody due to its Third-Party Standing Letters of Authorization (“SLOA”). PIAC and its qualified custodian meet the following seven (7) conditions in order to avoid being subject to the custody surprise exam requirement: 1. The Client provides an instruction to the qualified custodian, in writing, that includes the Client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. 2. The Client authorizes PIAC, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. 3. The Client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the Client’s authorization and provides a transfer of funds notice to the Client promptly after each transfer. 4. The Client has the ability to terminate or change the instruction to the Client’s qualified custodian. 5. PIAC has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the Client’s instruction. 6. PIAC maintains records showing that the third party is not a related party nor located at the same address as PIAC. 7. The Client’s qualified custodian sends the Client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion Discretionary Authority for Trading PIAC requires discretionary authority to manage securities accounts on behalf of Clients. PIAC has the authority to determine, without obtaining specific Client consent, the 16  securities to be bought or sold, and the amount of the securities to be bought or sold. The client will authorize PIAC discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement, as well as the custodian’s application. PIAC allows Clients to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments. These restrictions must be provided to PIAC in writing. PIAC does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes PIAC does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. When assistance on voting proxies is requested, PIAC will provide recommendations to the Client. If a conflict of interest exists, it will be disclosed to the Client. If the Client requires assistance or has questions, they can reach out to the investment advisor representatives of the firm at the contact information on the cover page of this document. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided to Clients because PIAC does not serve as a custodian for Client funds or securities and PIAC does not require prepayment of fees of more than $1,200 per Client and six months or more in advance. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients PIAC has no condition that is reasonably likely to impair our ability to meet contractual commitments to our Clients. Bankruptcy Petitions during the Past Ten Years PIAC has not had any bankruptcy petitions in the last ten years. 17