PASNAU INVESTMENT MANAGEMENT, INC._ADV PART 2A BROCHURE

Pasnau Investment Management, Inc. 375 West Meetinghouse Road New Milford, CT 06776 860 354-9903 pasnauinvestments.com Brochure Dated: October 19, 2026 This brochure provides information about the qualifications and business practices of Pasnau Investment Management, Inc. If you have any questions about the contents of this brochure, contact us at 860-354-9903. 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. Click on the Investment Adviser Search link and then search for Investment Adviser Firm using PASNAU INVESTMENT MANAGEMENT, INC's IARD number which is 125647. Additional information about Pasnau Investment Management, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. Pasnau Investment Management, Inc. is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2 Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual update dated February 20, 2026, we have the following material change to report: 1. Updated our fee schedule and disclosed that some clients are charged a flat fee. 2  Item 3 Table of Contents Item 1 Cover Page Item 2 Summary of Material Changes Item 3 Table of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Item 19 Additional Information Page 1 Page 2 Page 3 Page 4 Page 4 Page 6 Page 6 Page 6 Page 7 Page 7 Page 7 Page 8 Page 9 Page 10 Page 10 Page 10 Page 11 Page 11 Page 11 3  Item 4 Advisory Business Pasnau Investment Management, Inc. Pasnau Investment Management, Inc. is a registered investment advisor with its office located in New Milford, Connecticut. We are organized as a corporation under the laws of the State of Connecticut and registered as an investment advisor since June 1, 1999. Pasnau Investment Management, Inc. obtained its investment advisor registration by the Securities & Exchange Commission ("SEC") in 2025. William C. Pasnau is the sole owner, President and Chief Executive Officer of the firm. Types of Services Investment Advisory Services Pasnau Investment Management, Inc. provides investment advisory services to its clients which include individuals and high net worth individuals. Client Consultation Pasnau Investment Management, Inc. provides investment advisory services specifically tailored to the individual needs of each client. Through extensive discussions and meetings with the client and any other professionals (i.e. accountants and attorneys) that the client so designates, Pasnau Investment Management, Inc. presents a written investment plan to the client with recommendations for securities and investment strategies that meet the client's overall needs, objectives and risk tolerances. Types of investments that Pasnau Investment Management, Inc. recommends include common stocks issued by domestic and foreign companies, bonds issued by domestic companies, U.S. Government securities, preferred stocks issued by domestic companies, municipal securities, commercial paper, warrants, options, domestic and foreign mutual funds and index funds. Once accepted by the client, Pasnau Investment Management, Inc. is responsible for the implementation of the investment plan. Clients of Pasnau Investment Management, Inc. may at any time impose restrictions on investing in certain securities or types of securities. It also remains the client's responsibility to promptly notify Pasnau Investment Management, Inc. if there is ever a change in his financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Pasnau Investment Management, Inc.'s previous recommendations or services. Pasnau Investment Management, Inc. will, whenever possible, consult with its clients prior to purchases or sales being made in their accounts. If the client is not available for consultation, Pasnau Investment Management, Inc. will act in its sole discretion with respect to buying, selling or trading securities for the client. Pasnau Investment Management, Inc. does not participate in a wrap-fee program. As of January 12, 2026, Pasnau Investment Management, Inc. had $128,752,000 in discretionary assets under management and manages no assets on a non-discretionary basis. Item 5 Fees and Compensation Portfolio Management Services Our fee for portfolio management services is either a flat fee or based on a percentage of the assets in your account. Your fee schedule is outlined in your investment advisory agreement. Clients that pay a flat fee are billed quarterly in advance. The following annual fee schedule is for clients that are billed as a percentage of the market value of assets under management: 4  Fee Schedule Market Value of Portfolio % of Assets 1.0% $0-$1,000,000 $1,000,000+ 1.0% on first $1.0 million .75% on amounts over $1 million The specific manner in which fees are charged by Pasnau Investment Management, Inc. is established in a client's written agreement with Pasnau Investment Management, Inc. Pasnau Investment Management, Inc. will generally bill its fees on a quarterly basis. Clients are billed in advance each quarter, based upon the market value of the assets on the last business day of the previous quarter. Clients may also elect to be billed directly for fees or to authorize Pasnau Investment Management, Inc. to directly debit fees from client accounts. In the event that the client elects to be billed directly, payment is due upon the receipt of Pasnau Investment Management, Inc.'s invoice. Management fees shall not be prorated for each capital contribution and withdrawal made during the applicable quarter. Accounts initiated or terminated during a quarter will be charged a prorated fee. Termination is by notice in writing 30 days in advance. Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and any earned, unpaid fees will be due and payable. The Firm's fees are generally negotiable. At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. Unless the client directs otherwise, or a client's circumstances require, Pasnau Investment Management, Inc. will generally recommend that Fidelity Brokerage Services LLC serve as the broker- dealer/custodian for client assets under management. The broker-dealer/custodian charge brokerage commissions and/or transaction fees for effecting securities transactions. In addition, clients may also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (i.e. management fees and other fund expenses). Individual fixed income and/or equity transactions may be effected through David Burleson of Crews and Associates, a broker/dealer with whom Pasnau Investment Management, Inc. has entered into an arrangement for prime brokerage clearing services. Pasnau Investment Management, Inc.'s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund's prospectus. Such charges, fees and commissions are exclusive of and in addition to Pasnau Investment Management, Inc.'s fee, and Pasnau Investment Management, Inc. shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that Pasnau Investment Management, Inc. considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). 5  Item 6 Performance-Based Fees and Side-By-Side Management Pasnau Investment Management, Inc. does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 Types of Clients Pasnau Investment Management, Inc. provides investment advisory services to individuals and high net worth individuals and does not require a minimum asset level for investment advisory services. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss An important note about Investment Risk: Investing in securities involves risk of loss that clients should be prepared to bear. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy will be profitable or equal any specific performance level. At Pasnau Investment Management, Inc. all investment strategies are client based, relying upon information developed through discussions with each client about their investment goals and investing characteristics; risk tolerance, time horizon and overall resources and sophistication. Security Analysis Pasnau Investment Management, Inc. may use the following fundamental strategic methods of security analysis when recommending investments for a portfolio: (1) Fundamental Analysis which involves analyzing a company's financial statements and health, its management and competitive advantages, and its competitors and markets. Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. (2) Technical Analysis which involves an analysis for forecasting the direction of prices through the study of past market data, primarily price and volume and other market information. Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. (3) Cyclical Analysis is a form of fundamental analysis involving the process of making investment decisions based on the different stages of market and economic cycles. The type of position taken will depend on specific investment characteristics within the industry and the industry's relative position in the cycle. Risk: The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. 6  Investment Strategies (1) Buy and Hold is an investment strategy in which stocks are bought and then held for a long period, regardless of the market's fluctuations. Additional benefits to the buy and hold strategy are that trading commissions can be reduced and taxes can be reduced or deferred by buying and selling less often and holding longer. (2) Asset Allocation is the process of dividing investments among different kinds of assets, such as stocks, bonds, real estate and cash, to optimize the risk/reward tradeoff based on a client's specific situation and goals. Individual securities are then selected based upon Pasnau Investment Management, Inc.'s assessment of these fundamental strategic objectives. Pasnau Investment Management, Inc.'s goal is to minimize risk or manage the risk in the account, knowing that ultimately, this risk is borne by the client, including the loss of some or all principal value both in the individual security or in the entire portfolio. Pasnau Investment Management, Inc.'s methods of analysis and investment strategies do not present any significant or unusual risks. However, every method of analysis has its own inherent risks. Pasnau Investment Management, Inc. primarily allocates client investment assets among various individual stocks, debt and fixed income securities, and in certain instances, mutual funds and exchange traded funds in accordance with the client's investment objectives. Item 9 Disciplinary Information Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Pasnau Investment Management, Inc. or the integrity of Pasnau Investment Management, Inc.'s management. Pasnau Investment Management, Inc. has no information applicable to this Item and neither Pasnau Investment Management, Inc., nor its management, has ever been the subject of any disciplinary actions. Item 10 Other Financial Industry Activities and Affiliations Neither Pasnau Investment Management, Inc. nor its management receives, directly or indirectly, any cash or other forms of compensation or economic benefit from any investment advisers or financial planners in connection with providing advice to clients, nor does Pasnau Investment Management, Inc. or its management directly or indirectly compensate any person for client referrals. Pasnau Investment Management, Inc. maintains long standing investment and research relationships with the following broker-dealer/custodians and/or their registered representatives: (a) Fidelity Brokerage Services LLC; (b) David Burleson of Crews and Associates for prime brokerage services. These relationships are all on a non-contractual and non-exclusive basis. Item 11 Code of Ethics Although the Connecticut Uniform Securities Act (CUSA) and its Regulations do not require that state- registered investment advisers prepare a separate code of ethics, ethical concerns should be integrated into a state-registered investment advisers' supervisory and compliance procedures as well as its business operations as more fully discussed in this policy statement. As such, Pasnau Investment Management, Inc. has adopted a Code of Ethics for all supervised persons of the firm 7  describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at Pasnau Investment Management, Inc. must acknowledge the terms of the Code of Ethics annually, or as amended. Pasnau Investment Management, Inc. anticipates that, in appropriate circumstances, consistent with clients' investment objectives, it will cause accounts over which Pasnau Investment Management, Inc. has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which Pasnau Investment Management Inc., its affiliates and/or clients, directly or indirectly, have a position of interest. Pasnau Investment Management, Inc.'s supervised and related persons are required to follow Pasnau Investment Management, Inc.'s Code of Ethics. Officers, directors and employees of Pasnau Investment Management, Inc. and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Pasnau Investment Management, Inc.'s clients. The Code of Ethics is designed to ensure that the personal securities transactions, activities and interests of the employees of Pasnau Investment Management, Inc. will not interfere with making decisions in the best interest of its clients and implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code of Ethics, certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Pasnau Investment Management, Inc.'s clients. In addition, the Code of Ethics requires pre- clearance of many transactions, and restricts trading in close proximity to client trading activity. Because the Code of Ethics in some circumstances would permit officers, directors and employees of Pasnau Investment Management, Inc. and its affiliates to invest in the same securities as clients, there is a possibility that Pasnau Investment Management, Inc. and its management and related persons might benefit from market activity by a client in a security held by Pasnau Investment Management, Inc. or its management. This disclosure addresses this potential conflict of interest. Trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between Pasnau Investment Management, Inc. and its clients. It is Pasnau Investment Management, Inc.'s policy that the firm will not affect any cross securities transactions for client accounts. Pasnau Investment Management, Inc. will also not cross trades between client accounts. Pasnau Investment Management, Inc. does not recommend, buy or sell securities in which Pasnau Investment Management, Inc. or any related person has a material financial interest. Pasnau Investment Management, Inc.'s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Janet A. Silano, Operations Manager at (860) 354-9903. Item 12 Brokerage Practices Pasnau Investment Management, Inc. generally recommends that investment management accounts be maintained at Fidelity Brokerage Services LLC. The client is required to enter into a formal Investment Advisory Agreement with Pasnau Investment Management, Inc. setting forth the terms and conditions under which the client's assets shall be managed. The client enters into a separate custodial agreement with the designated broker-dealer/custodian. Pasnau Investment Management, Inc. considers the following factors before recommending Fidelity Brokerage Services LLC to its clients: financial strength, reputation, execution capabilities, pricing, research and service. Although Pasnau Investment Management, Inc. will seek competitive rates, it may not necessarily obtain the lowest possible commission rate for client account 8  transactions. A client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction, but Pasnau Investment Management, Inc. has determined that the commission fee is reasonable in relation to the value of the brokerage and research services received. Pasnau Investment Management, Inc., in seeking the most favorable execution, also takes into consideration the full range of broker-dealer services, including the value of the research provided, execution capability, commission rates and responsiveness. Pasnau Investment Management, Inc. may receive from Fidelity Brokerage Services LLC, or another broker- dealer/custodian, without cost or at a discount, support services and products (soft dollar benefits) which assist Pasnau Investment Management, Inc. to better monitor and service client accounts maintained at such institutions. These support services include investment related research, pricing information and market data, software and other technology that provides access to client data, compliance and practice management related publications, discounted educational services, marketing support and discounted marketing products used in furtherance of Pasnau Investment Management, Inc.'s advisory business operations. Pasnau Investment Management, Inc.'s clients do not pay more for commissions or transaction fees as a result of these arrangements and there is no commitment made to Fidelity Brokerage Services LLC or any other institution to invest any specific amount or percentage of client assets in any investment product as a result of these arrangements. Soft dollar benefits are not limited to those clients who may have generated a particular benefit although certain soft dollar allocations are connected to particular clients or groups of clients. Soft dollar benefits are not proportionally allocated to any accounts that may generate different amounts of the soft dollar benefits. Pasnau Investment Management, Inc. does not receive referrals from broker-dealers/custodians. Pasnau Investment Management, Inc. does not generally accept directed brokerage arrangements. If a client requires that account transactions be placed through a specific broker-dealer/custodian, the client will negotiate the terms and arrangements for their account with the broker-dealer/custodian. The client may pay higher commissions and other transaction costs and fees, greater spreads, or receive less favorable net asset prices on transactions for this account than Pasnau Investment Management, Inc. might be able to obtain from other broker-dealers. Transactions placed in each client's account will generally be effected independently. However, there may be occasions where Pasnau Investment Management, Inc. decides to purchase or sell the same securities for several clients at the same time. These transactions may be combined to obtain the best execution, to negotiate more favorable commission rates or to allocate equitably the differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Transactions would then be averaged as to price and allocated among clients in proportion to the purchase and or sale orders placed for each client on a given day. Pasnau Investment Management, Inc. shall not receive any compensation as a result of this. Item 13 Review of Accounts In addition to monthly Account statements provided directly from the broker-dealer/custodian, quarterly statements generated by Pasnau Investment Management, Inc. are provided to all clients who request them. These statements are not intended to replace the statements provided by the broker-dealer custodian, but they are intended to supplement and or consolidate the information provided by the broker-dealer/ custodian. Clients are urged to compare all statements with the statements they receive from the broker-dealer custodian and contact Pasnau Investment Management, Inc. in the event of any discrepancies. 9  Pasnau Investment Management, Inc. will provide a detailed written quarterly investment summary and review containing an analysis of all activity that has taken place in the account during the period under review. These quarterly written reviews will be provided to all clients for all accounts and will include income, current yields, and yields on cost. Pasnau Investment Management Inc.'s William Charles Pasnau, President or Benjamin Edmund, Account Manager, will perform appraisals of each account. Each account will be supervised on a daily basis by the President of the firm, William Charles Pasnau or Account Manager, Benjamin Edmund, if required, clients will be contacted. As required, additional reports will be sent to clients on their accounts. Account reviews may also be conducted upon the occurrence of a triggering event, such as a change in client investment objectives and/or financial situation, market correction or at a client's request. Clients are encouraged to review financial planning issues, investment objectives and account performance with Pasnau Investment Management, Inc. on an annual basis either in person or by telephone. Item 14 Client Referrals and Other Compensation Neither Pasnau Investment Management Inc., nor its management, either directly or indirectly, compensates any non-supervised person for client referrals. As fully explained in Item 12, Pasnau Investment Management, Inc. receives indirect economic benefit from Fidelity Brokerage Services LLC. Pasnau Investment Management, Inc. receives support services and products from Fidelity Brokerage Services LLC without cost or at a discount. Pasnau Investment Management Inc.'s clients do not pay more for investment transactions effected and or assets maintained at Fidelity Brokerage Services LLC. Item 15 Custody Your independent custodian will directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. Item 16 Investment Discretion Pasnau Investment Management, Inc.receives discretionary authority from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold and is considered to exercise investment discretion over a client's account if it can effect transactions for the client without first having to seek the client's consent. Pasnau Investment Management, Inc. is given this authority through a power-of-attorney included in the agreement between Pasnau Investment Management, Inc. and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. 10  When selecting securities and determining amounts, Pasnau Investment Management, Inc. observes the investment policies, limitations and restrictions of the clients for which it advises. In acting as Investment Advisor and in exercising its discretion, Pasnau Investment Management, Inc. shall use its best judgment and shall not be liable for any loss or damage sustained or incurred in any manner, except if due to gross negligence or willful misconduct on the part of Pasnau Investment Management, Inc. or its management. Investment guidelines and restrictions must be provided to Pasnau Investment Management, Inc. in writing. Item 17 Voting Client Securities We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitations to vote proxies. Item 18 Financial Information Registered Investment Advisers are required in this Item to provide you with certain financial information or disclosures about Pasnau Investment Management, Inc.'s financial condition. Pasnau Investment Management Inc. does not solicit fees of more than $1200 per client six months or more in advance. Pasnau Investment Management, Inc. has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. Item 19 Additional Information Trade Errors In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. 11