Overview
- Headquarters
- East Brunswick, NJ
- Total Firm Assets
- $185 million
- Average High-Net-Worth Client Portfolio Size
- $0.9 million
Fee Structure
Primary Fee Schedule (ADV PART 2A BROCHURE SUPPLEMENT)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.50% |
| $1,000,001 | $5,000,000 | 1.25% |
| $5,000,001 | $10,000,000 | 1.00% |
| $10,000,001 | and above | 0.75% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $15,000 | 1.50% |
| $5 million | $65,000 | 1.30% |
| $10 million | $115,000 | 1.15% |
| $50 million | $415,000 | 0.83% |
| $100 million | $790,000 | 0.79% |
Clients
- High-Net-Worth Share of Firm Assets
- 34.61%
- Number of High-Net-Worth Clients
- 68
- Total Client Accounts
- 597
- Discretionary Accounts
- 597
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 309784
Primary Brochure: ADV PART 2A BROCHURE SUPPLEMENT (2026-05-08)
View Document Text
PCB Capital LLC
An SEC Registered Investment Adviser
557 Cranbury Rd, Suite 16
East Brunswick, NJ 08816
Version date: May 8, 2026
This brochure provides information about the qualifications and business practices of PCB Capital
LLC (“PCB Capital”). If you have any questions about the content of this brochure, please contact us at
732-634-3620. 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 PCB Capital is also available on the SEC’s website at
www.adviserinfo.sec.gov. PCB Capital’s CRD# is 309784.
SEC registration does not imply a certain level of skill or training.
PCB Capital LLC (CRD #309784)
May 2026
Page 2
Item 2. Material Changes
There are no material changes in this brochure from the last annual updating amendment of PCB
Capital, LLC on 01/26/2026. Material changes relate to PCB Capital, LLC’s policies, practices or
conflicts of interest.
PCB Capital LLC (CRD #309784)
May 2026
Page 3
Item 3. Table of Contents
Item 2. Material Changes .............................................................................................................. 2
Item 3. Table of Contents .............................................................................................................. 3
Item 4. Advisory Business .............................................................................................................. 4
Item 5. Fees and Compensation ..................................................................................................... 5
Item 6. Performance-Based Fees and Side-by-Side Management ................................................... 7
Item 7. Types of Clients ................................................................................................................. 7
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss .............................................. 7
Item 9. Disciplinary Information .................................................................................................... 9
Item 10. Other Financial Industry Activities and Affiliations ........................................................... 9
Item 12. Brokerage Practices ....................................................................................................... 10
Item 13. Review of Accounts ........................................................................................................ 13
Item 14. Client Referrals and Other Compensation ....................................................................... 13
Item 15. Custody ......................................................................................................................... 14
Item 16. Investment Discretion .................................................................................................... 14
Item 17. Voting Client Securities .................................................................................................. 14
Item 18. Financial Information .................................................................................................... 15
PCB Capital LLC (CRD #309784)
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Item 4. Advisory Business
PCB Capital offers wealth management services to individual and high net worth clients as well as
small businesses. The firm prides itself on its investment strategies, client service, and ongoing
commitment to bringing innovative solutions to its clients’ financial lives. PCB Capital is owned and
founded by Peter Bombara. Mr. Bombara has more than twenty years of experience provided
investment management and advisory services.
This Disclosure Brochure describes the business of PCB Capital. Certain sections will also
describe the activities of Supervised Persons. Supervised Persons are any of PCB Capital’s
officers, partners, directors (or other persons occupying a similar status or performing similar
functions), or employees, or any other person who provides investment advice on PCB Capital’s
behalf and is subject to PCB Capital’s supervision or control.
Financial Planning Services:
PCB Capital provides its clients with financial planning and consultation services (e.g., review
of goals and objectives, analysis and recommendations for cash flow planning, asset
allocation/investment planning, income tax planning, insurance planning, estate planning,
retirement planning, education planning, real estate/mortgage planning, etc.).
A conflict of interest exists to the extent PCB Capital’s financial planning recommends the utilization
of PCB Capital to manage their assets for a fee. In order to address this conflict, the client is under
no obligation to act upon the investment adviser’s recommendation, and if the client elects to act on
any of the recommendations, the client is under no obligation to affect the transaction through the
investment adviser
Investment Management Services:
PCB Capital provides investment management services on a discretionary and non-discretionary
basis according to the investment objectives of the client and in accordance with the terms and
conditions of the Investment Advisory Agreement between PCB Capital and the client. Based upon
the client’s stated investment objectives, PCB Capital primarily allocates clients’ investment
management assets through the use of mutual funds, exchange-traded funds (ETFs), and
Independent Managers (as defined below). Clients are advised to promptly notify PCB Capital if
there are changes in their financial situation or investment objectives or if they wish to impose any
reasonable restrictions upon PCB Capital’s management services.
Use of Independent Managers: As mentioned above, PCB Capital generally recommends that clients
authorize the active discretionary management of a portion of their assets by and/or among certain
independent investment managers (“Independent Managers”), based upon the stated investment
objectives of the client. The terms and conditions under which the client engages the Independent
Managers are set forth in a separate written agreement between PCB Capital or the client and the
designated Independent Managers. PCB Capital monitors and reviews the account performance and
the client’s investment objectives. PCB Capital receives an annual advisory fee which is based upon a
percentage of the market value of the assets being managed by the designated Independent
Managers.
PCB Capital LLC (CRD #309784)
May 2026
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When recommending an Independent Manager for a client, PCB Capital reviews information about
the Independent Manager such as its disclosure statement and/or material supplied by the
Independent Manager or independent third parties for a description of the Independent Manager’s
investment strategies, past performance and risk results to the extent available. Factors that PCB
Capital considers in recommending an Independent Manager include the client’s stated investment
objectives, management style, performance, reputation, financial strength, reporting, pricing, and
research. The investment management fees charged by the designated Independent Managers,
together with the fees charged by the corresponding designated broker-dealer/custodian of the
client’s assets, are in addition to PCB Capital’s investment advisory fee set in Item 5. As discussed
above, the client may incur additional fees than those charged by PCB Capital, the designated
Independent Managers, and corresponding broker-dealer and custodian.
In addition to PCB Capital’s written disclosure statement, the client will also receive the written
disclosure statement of the designated Independent Managers. Certain Independent Managers may
impose more restrictive account requirements and varying billing practices than PCB Capital. In such
instances, PCB Capital may alter its corresponding account requirements and/or billing practices to
accommodate those of the Independent Managers.
Wrap Fee Programs
A wrap fee program is an investment program wherein the investor pays one stated fee that
includes management fees, transaction costs, and certain other administrative fees. PCB Capital
does not participate in any wrap fee programs.
Assets Under Management:
As of December 31, 2025, PCB Capital has $184,775,085 in discretionary assets under
management.
Item 5. Fees and Compensation
PCB Capital offers its services on a fee basis, which may include fixed fees, as well as fees based
upon assets under management. Additionally, certain of PCB Capital’s Supervised Persons, in their
individual capacities, may offer insurance products under a commission arrangement. For all
services, PCB Capital’s annual fee is exclusive of, and in addition to brokerage commissions,
transaction fees, and other related costs and expenses which are incurred by the client. PCB Capital
does not, however, receive any portion of these commissions, fees, and costs.
Financial Planning Fees:
PCB Capital’s financial planning and consulting fees are negotiable, but generally are $400 on an
hourly rate basis, and from $1,000 to $25,000 on a fixed fee basis, depending upon the level and
scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging
PCB Capital to provide financial planning or consulting services, clients will be required to enter
into a Financial Planning Agreement with PCB Capital setting forth the terms and conditions of the
engagement, describing the scope of the services to be provided, and the portion of the fee that is
due from the client prior to PCB Capital commencing services
Investment Management Fees:
PCB Capital’s investment management fee schedule (“Advisory Fees”) for accounts managed by
PCB Capital is based on a percentage of assets (generally net of any debit balances) and is set forth
below. The Advisory Fees represent the highest fee that may be charged absent special
PCB Capital LLC (CRD #309784)
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circumstances:
Advisory Assets
0 - $1,000,000
$1,000,001 - $5,000,000
$5,000,001 – 10,000,000
All assets in excess of $10 million
Annual Fee
1.50%
1.25%
1.00%
0.75%
PCB Capital’s Advisory Fees shall also be prorated and paid monthly, in advance, based upon the
market value of the assets on the last business day of the previous month. PCB Capital’s actual fees
may be negotiated, and a client may pay more or less than similar clients depending on the particular
circumstances of the client, which may include considerations related to size of the client’s account,
additional and/or differing levels of service or as negotiated. Clients that negotiate fees may end up
paying a higher fee than that set forth in the fee schedules above as a result of fluctuations in the
client’s assets under management and/or account performance.
Fees Charged by Financial Institutions
PCB Capital generally recommends that clients utilize the brokerage and clearing services of
Charles Schwab & Co., Inc. Advisor Services for investment management accounts.
PCB Capital may only implement its investment management recommendations after the client has
arranged for and furnished PCB Capital with all information and authorization regarding accounts
with appropriate financial institutions. Clients may incur certain charges imposed by the Financial
Institutions and other third parties such as fees charged by Independent Managers, custodial fees,
charges imposed directly by a mutual fund or ETF in the account, which are disclosed in the fund’s
prospectus (e.g., fund management fees and other fund expenses), 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.
Additionally, clients may incur brokerage commissions and transaction fees. Such charges, fees and
commissions are exclusive of and in addition to PCB Capital’s fee. PCB Capital’s Agreement and the
separate agreement with any Financial Institutions may authorize PCB Capital or Independent
Managers to debit the client’s account for the amount of PCB Capital’s fee and to directly remit that
management fee to PCB Capital or the Independent Managers. Any Financial Institutions
recommended by PCB Capital have agreed to send a statement to the client, at least quarterly,
indicating all amounts disbursed from the account including the amount of management fees paid
directly to PCB Capital. Alternatively, clients may elect to have PCB Capital send an invoice for
payment.
Fees for Management During a Partial Month of Service
For the initial period of investment management services, the fees are calculated on a pro rata basis.
The Agreement between PCB Capital and the client will continue in effect until terminated by either
party pursuant to the terms of the Agreement. PCB Capital’s fees are charged in advance so that any
termination date shall be prorated, and all unearned advisory fees will be returned to the client.
Clients may make additions to and withdrawals from their account at any time, subject to PCB
Capital’s right to terminate an account. Additions may be in cash or securities provided that PCB
Capital reserves the right to liquidate any transferred securities or decline to accept particular
securities into a client’s account.
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Clients may withdraw account assets on notice to PCB Capital, subject to the usual and customary
securities settlement procedures. However, PCB Capital designs its portfolios as long-term
investments and the withdrawal of assets may impair the achievement of a client’s investment
objectives. PCB Capital may consult with its clients about the options and ramifications of
transferring securities. However, clients are advised that when transferred securities are
liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent
deferred sales charge) and/or tax ramifications.
Clients are responsible for the payment of all third party fees (i.e., custodian fees, commissions,
brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from
the fees and expenses charged by PCB Capital. Please see Item 12 of this brochure regarding
broker-dealer/custodian.
Clients always have the right to decide whether to purchase PCB Capital-recommended products
and, if purchasing, have the right to purchase those products through other brokers or agents that
are not affiliated with PCB Capital.
Peter Bombara in his outside business activities (see Item 10 below) is licensed to accept
compensation for the sale of insurance products to PCB Capital clients. Commissions are not PCB
Capital’s primary source of compensation for advisory services.
Item 6. Performance-Based Fees and Side-by-Side Management
PCB Capital does not charge a performance-based fee.
Item 7. Types of Clients
PCB Capital provides its services to individuals, trusts, estates, non-profits and business entities.
Item 8. Methods of Analysis, Investment Strategies and Risk of Loss
PCB Capital’s primary methods of analysis are fundamental and technical:
Methods of Analysis
Fundamental analysis involves the fundamental financial condition and competitive position of a
Company or asset class. PCB Capital may analyze the financial condition, capabilities of
management, earnings, new products and services, as well as the company’s or asset class’ markets
and position amongst its competitors in order to determine the recommendations made to clients. The
primary risk in using fundamental analysis is that while the overall health and position of a company
or asset class may be good, market conditions may negatively impact the security
Technical analysis involves the analysis of past market data rather than specific company data in
determining the recommendations made to clients. Technical analysis may involve the use of charts
to identify market patterns and trends which may be based on investor sentiment rather than the
fundamentals of the company. The primary risk in using technical analysis is that spotting historical
patterns may not help to predict such patterns in the future. Even if the pattern will eventually reoccur,
there is no guarantee that PCB Capital will be able to accurately predict such a reoccurrence.
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Investment Strategies
PCB Capital customizes its asset management strategies based on individual needs and concerns of
their clients. While PCB Capital offers each of the services described in Item 4 (above), the main
focuses of the firm are its diversified portfolio management. For its diversified portfolio management,
PCB Capital may recommend a combination of in-house Model portfolios and Independent Managers
depending on the needs and goals of the client. PCB Capital selects securities and asset managers for
the portfolio based on asset allocation decisions and what suits the client’s needs and goals most
appropriately. Specifically, PCB Capital tries to determine the mix of stock, bonds, money markets,
and other investments that it feels offers the best combination of potential return and risk. At any
given time, PCB Capital may allocate all, a portion, or none of the portfolio’s assets to various areas
of the stock, bonds, or alternative investments
Material Risks Involved
Methods of Analysis
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.
Technical analysis attempts to predict a future stock price or direction based on market trends. The
assumption is that the market follows discernible patterns and if these patterns can be identified then a
prediction can be made. The risk is that markets do not always follow patterns and relying solely on this
method may not work long term.
Modern Portfolio Theory assumes that investors are risk averse, meaning that given two portfolios that offer
the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk
only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns
must accept more risk. The exact trade-off will be the same for all investors, but different investors will
evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a
rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected
return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns.
Investment Strategies
PCB Capital’s use of Independent Managers and model portfolios generally holds greater risk and clients
should be aware that there is a material risk of loss using any of those strategies.
Use of Independent Managers
Although PCB CAPITAL will seek to select only independent managers who will invest clients' assets with
the highest level of integrity, PCB Capital’s selection process cannot ensure that money managers will
perform as desired, and PCB Capital will have no control over the day-to-day operations of any of its
selected money managers. PCB Capital would not necessarily be aware of certain activities at the
underlying independent manager level, including without limitation an independent manager's engaging in
unreported risks, investment “style drift” or even regulator breach or fraud.
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Model portfolios are designed to capture return and risk at market rates. This seeks to provide
clients with diversification benefits help to smooth returns, reduce volatility and decrease asset-
class and single-strategy risks. Risks specific to using model portfolios include the possibility that
the model portfolio will underperform the market and the possibility that the model will not be able
take advantage of opportunities that a non-model portfolio management approach might capture.
Model portfolios entail inflation (purchasing power) risk, interest rate risk, economic risk, market
risk, political/regulatory risk, and asset allocation risk – meaning that any given asset allocation
strategy does not guarantee any specific result or profit nor protect against a loss.
Risks of Loss
Market Risks
The profitability of a significant portion of PCB Capital’s recommendations may depend to a great
extent upon correctly assessing the future course of price movements of stocks and bonds. There can
be no assurance that PCB Capital will be able to predict those price movements accurately.
Use of Independent Managers
PCB Capital may recommend the use of Independent Managers for certain clients. PCB Capital
will continue to do ongoing due diligence of such managers, but such recommendations rely, to a
great extent, on the Independent Managers ability to successfully implement their investment
strategy. In addition, PCB Capital does not have the ability to supervise the Independent Managers
on a day-to- day basis other than as previously described in response to Item 4, above.
Management Through Similarly Managed Accounts
For certain clients, PCB Capital may manage portfolios by allocating portfolio assets among
various securities on a discretionary basis using one or more of its proprietary investment strategies
(collectively referred to as “investment strategy”). In so doing, PCB Capital buys, sells, exchanges
and/or transfers securities based upon the investment strategy. PCB Capital’s management using
the investment strategy complies with the requirements of Rule 3a- 4 of the Investment Company
Act of 1940, as amended. Rule 3a-4 provides similarly managed accounts, such as the investment
strategy, with a safe harbor from the definition of an investment company. Securities in the
investment strategy are usually exchanged and/or transferred without regard to a client’s individual
tax ramifications. Certain investment opportunities that become available to PCB Capital’s clients
may be limited. As further discussed in response to Item 12B (below), PCB Capital allocates
investment opportunities among its clients on a fair and equitable basis.
General Risk of Loss
Investing in securities involves the risk of loss. Clients should be prepared to bear such loss.
Item 9. Disciplinary Information
PCB Capital is required to disclose the facts of any legal or disciplinary events that are material to a
client’s evaluation of its advisory business or the integrity of management. PCB Capital does not have
any required disclosures to this Item.
Item 10. Other Financial Industry Activities and Affiliations
PCB Capital is required to disclose any relationship or arrangement that is material to its advisory
business or to its clients with certain related persons. PCB Capital has described such relationships
PCB Capital LLC (CRD #309784)
May 2026
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and arrangements below.
Receipt of Insurance Commissions
Certain of PCB Capital’s Supervised Persons, in their individual capacities, are also licensed
insurance agents with various insurance companies, and in such capacity, may recommend, on a
fully- disclosed commission basis, the purchase of certain insurance products. While PCB Capital
does not sell such insurance products to its investment advisory clients, PCB Capital does permit
its Supervised Persons, in their individual capacities as licensed insurance agents, to sell insurance
products to its investment advisory clients. A conflict of interest exists when PCB Capital’s
Supervised Persons recommends insurance products and receives compensation.
Item 11. Code of Ethics
PCB Capital and persons associated with PCB Capital (“Associated Persons”) are permitted to buy
or sell securities that it also recommends to clients consistent with PCB Capital’s policies and
procedures. PCB Capital has adopted a code of ethics that sets forth the standards of conduct
expected of its associated persons and requires compliance with applicable securities laws (“Code
of Ethics”). In accordance with Section 204A of the Investment Advisers Act of 1940 (the
“Advisers Act”), its Code of Ethics contains written policies reasonably designed to prevent the
unlawful use of material non- public information by PCB Capital or any of its associated persons.
The Code of Ethics also requires that certain of PCB Capital’s personnel (called “Access Persons”)
report their personal securities holdings and transactions and obtain pre-approval of certain
investments such as initial public offerings and limited offerings.
Unless specifically permitted in PCB Capital’s Code of Ethics, none of PCB Capital’s Access
Persons may effect for themselves or for their immediate family (i.e., spouse, minor children, and
adults living in the same household as the Access Person) any transactions in a security which is
being actively purchased or sold or is being considered as such on behalf of PCB Capital’s clients.
When PCB Capital is purchasing or considering for purchase any security on behalf of a client, no
Access Person may effect a transaction in that security prior to the completion of the purchase or
until a decision has been made not to purchase such security. Similarly, when PCB Capital is
selling or considering the sale of any security on behalf of a client, no Access Person may effect a
transaction in that security prior to the completion of the sale or until a decision has been made not
to sell such security.
Clients and prospective clients may contact PCB Capital to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
As discussed above, in Item 5, PCB Capital generally recommends that clients utilize the brokerage
and clearing services of Charles Schwab & Co., Inc. Advisor Services. Factors which PCB Capital
considers in recommending the Custodians or any other broker-dealer to clients include the
irrespective financial strength, reputation, execution, pricing, research and service. Charles Schwab
& Co., Inc. Advisor Services enables PCB Capital to obtain many mutual funds without transaction
charges and other securities at nominal transaction charges. The commissions and/or transaction
fees charged may be higher or lower than those charged by other Financial Institutions.
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The commissions paid by PCB Capital’s clients comply with PCB Capital’s duty to obtain “best
execution.” Clients may pay commissions that are higher than another qualified Financial Institutions
might charge to affect the same transaction where PCB Capital determines that the commissions are
reasonable in relation to the value of the brokerage and research services received. In seeking best
execution, the determinative factor is not the lowest possible cost, but whether the transaction
represents the best qualitative execution, taking into consideration the full range of a Financial
Institution’s services, including among others, the value of research provided, execution capability,
commission rates, and responsiveness. PCB Capital seeks competitive rates but may not necessarily
obtain the lowest possible commission rates for client transactions.
PCB Capital periodically and systematically reviews its policies and procedures regarding its
recommendation of Financial Institutions in light of its duty to obtain best execution. The client may
direct PCB Capital in writing to use a particular Financial Institution to execute some or all transactions
for the client. In that case, the client will negotiate terms and arrangements for the account with that
Financial Institution, and PCB Capital will not seek better execution services or prices from other
Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by PCB Capital. As a result, the client may pay
higher commissions or other transaction costs or greater spreads, or receive less favorable net prices,
on transactions for the account than would otherwise be the case. Subject to its duty of best execution,
PCB Capital may decline a client’s request to direct brokerage if, in PCB Capital’s sole
discretion, such directed brokerage arrangements would result in additional operational difficulties
or violate restrictions imposed by other broker-dealers (as further discussed below). Transactions
for each client generally will be affected independently unless PCB Capital decides to purchase or
sell the same securities for several clients at approximately the same time. PCB Capital may (but is
not obligated to) combine or “batch” such orders to obtain best execution, to negotiate more
favorable commission rates, or to allocate equitably among PCB Capital’s clients.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker-
dealers in return for investment research products and/or services which assist PCB Capital in its
investment decision-making process. Such research generally will be used to service all of PCB
Capital’s clients, but brokerage commissions paid by one client may be used to pay for research that
is not used in managing that client’s portfolio. The receipt of investment research products and/or
services as well as the allocation of the benefit of such investment research products and/or services
poses a conflict of interest because PCB Capital does not have to produce or pay for the products or
services.
1. Research and Other Soft Dollar Benefits
PCB Capital has access to research, products, or other services from its broker/dealer in connection
with client securities transactions (“soft dollar benefits”) consistent with (and not outside of) the
safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended, and
may consider these benefits in recommending brokers. There can be no assurance that any
particular client will benefit from any particular soft dollar research or other benefits. PCB Capital
benefits by not having to produce or pay for the research, products or services, and PCB Capital
will have an incentive to recommend a broker dealer based on receiving research or services.
Clients should be aware that PCB Capital’s acceptance of soft dollar benefits may result in higher
commissions charged to the client.
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2. Software and Support Provided by Financial Institutions
PCB Capital may receive from Charles Schwab & Co., Inc. Advisor Services, without cost to PCB
Capital, computer software and related systems support, which allow PCB Capital to better monitor
client accounts maintained at Charles Schwab & Co., Inc. Advisor Services. PCB Capital may
receive the software and related support without cost because PCB Capital renders investment
management services to clients that maintain assets at Charles Schwab & Co., Inc. Advisor
Services. The software and related systems support may benefit PCB Capital, but not its clients
directly. In fulfilling its duties to its clients, PCB Capital endeavors at all times to put the interests of its
clients first. Clients should be aware, however, that PCB Capital’s influence PCB Capital’s choice of
broker-dealer over another broker-dealer that does not furnish similar software, systems support, or
services. Additionally, PCB Capital may receive the following benefits from Charles Schwab &
Co., Inc. Advisor Services through their respective investment adviser divisions: receipt of
duplicate client confirmations and bundled duplicate statements; access to a trading desk that
exclusively services its investment adviser participants; access to block trading which provides
the ability to aggregate securities transactions and then allocate the appropriate shares to client
accounts; and access to an electronic communication network for client order entry and account
information
3. Brokerage for Client Referrals
PCB Capital receives no referrals from a broker-dealer or third party in exchange for using that
broker-dealer or third party.
4. Clients Directing Which Broker/Dealer/Custodian to Use
PCB Capital may permit clients to direct it to execute transactions through a specified broker-
dealer. Clients must refer to their advisory agreements for a complete understanding of how they
may be permitted to direct brokerage. If a client directs brokerage, the client will be required to
acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any
authority granted to PCB Capital to select brokers; this direction may result in higher commissions,
which may result in a disparity between free and directed accounts; the client may be unable to
participate in block trades unless PCB Capital is able to engage in “step outs” and trades for the
client and other directed accounts may be executed after trades for free accounts, which may result
in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not
all investment advisers allow their clients to direct brokerage.
B. Aggregating (Block) Trading for Multiple Client Accounts
To the extent that PCB Capital determines to aggregate client orders for the purchase or sale of
securities, including securities in which PCB Capital’s Supervised Persons may invest, PCB Capital
generally does so in accordance with applicable rules promulgated under the Advisers Act and no-
action guidance provided by the staff of the U.S. Securities and Exchange Commission. PCB Capital
does not receive any additional compensation or remuneration as a result of the aggregation. In the
event that PCB Capital determines that a prorated allocation is not appropriate under the particular
circumstances, the allocation will be made based upon other relevant factors, which may include: (i)
when only a small percentage of the order is executed, shares may be allocated to the account with the
smallest order or the smallest position or to an account that is out of line with respect to security or
sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to
one account when one account has limitations in its investment guidelines which prohibit it from
purchasing other securities which are expected to produce similar investment results and can be
purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot
PCB Capital LLC (CRD #309784)
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participate in an allocation, shares may be reallocated to other accounts (this may be due to
unforeseen changes in an account’s assets after an order is placed);(iv) with respect to sale
allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation
of a potential execution would result in a de minimis allocation in one or more accounts, PCB
Capital may exclude the account(s) from the allocation; the transactions may be executed on a pro
rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is
executed in all accounts, shares may be allocated to one or more accounts on a random basis.
Item 13. Review of Accounts
For those clients to whom PCB Capital provides wealth management services, PCB Capital monitors
those portfolios as part of an ongoing process while regular account reviews are conducted on at least
an annual basis. Such reviews are conducted by one of PCB Capital’s investment adviser
representatives. All investment advisory clients are encouraged to discuss their needs, goals, and
objectives with PCB Capital and to keep PCB Capital informed of any changes thereto. PCB Capital
contacts ongoing investment advisory clients at least annually to review its previous services and/or
recommendations and to discuss the impact resulting from any changes in the client’s financial
situation and/or investment objectives. Unless otherwise agreed upon, clients are provided with
transaction confirmation notices and regular summary account statements directly from the broker-
dealer or custodian for the client accounts.
Item 14. Client Referrals and Other Compensation
Charles Schwab & Co., Inc. Advisor Services provides PCB Capital with access to Charles
Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are
typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These
services generally are available to independent investment advisers on an unsolicited basis, at no
charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are
maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co.,
Inc. Advisor Services includes brokerage services that are related to the execution of securities
transactions, custody, research, including that in the form of advice, analyses and reports, and
access to mutual funds and other investments that are otherwise generally available only to
institutional investors or would require a significantly higher minimum initial investment. For PCB
Capital client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services
generally does not charge separately for custody services but is compensated by account holders
through commissions or other transaction-related or asset-based fees for securities trades that are
executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab
& Co., Inc. Advisor Services accounts.
Charles Schwab & Co., Inc. Advisor Services also makes available to PCB Capital other products
and services that benefit PCB Capital but may not benefit its clients’ accounts. These benefits may
include national, regional or PCB Capital specific educational events organized and/or sponsored
by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional
business entertainment of personnel of PCB Capital by Charles Schwab & Co., Inc. Advisor
Services personnel, including meals, invitations to sporting events, including golf tournaments, and
other forms of entertainment, some of which may accompany educational opportunities. Other of
these products and services assist PCB Capital in managing and administering clients’ accounts.
These include software and other technology (and related technological training) that provide
access to client account data (such as trade confirmations and account statements), facilitate trade
execution (and allocation of aggregated trade orders for multiple client accounts, if applicable),
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May 2026
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provide research, pricing information and other market data, facilitate payment of PCB Capital’s
fees from its clients’ accounts (if applicable), and assist with back-office training and support
functions, recordkeeping and client reporting. Many of these services generally may be used to
service all or some substantial number of PCB Capital’s accounts. Charles Schwab & Co., Inc.
Advisor Services also makes available to PCB Capital other services intended to help PCB Capital
manage and further develop its business enterprise. These services may include professional
compliance, legal and business consulting, publications and conferences on practice management,
information technology, business succession, regulatory compliance, employee benefits providers,
and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc.
Advisor Services may make available, arrange and/or pay vendors for these types of services
rendered to PCB Capital by independent third parties. Charles Schwab & Co., Inc. Advisor
Services may discount or waive fees it would otherwise charge for some of these services or pay
all or a part of the fees of a third-party providing these services to PCB Capital. PCB Capital is
independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor
Services.
PCB Capital does not compensate non-advisory personnel (solicitors) for client referrals.
Item 15. Custody
PCB Capital does not maintain physical custody client assets. PCB Capital engages several qualified,
nationally recognized SEC registered broker-dealers to custody and safe keep client assets. PCB
Capital’s Agreement and/or the separate agreement with any Financial Institution may authorize PCB
Capital through such Financial Institution to debit the client’s account for the amount of PCB
Capital’s fee and to directly remit that management fee to PCB Capital in accordance with applicable
custody rules. The Financial Institutions recommended by PCB Capital have agreed to send a
statement to the client, at least quarterly, indicating all amounts disbursed from the account.
PCB Capital effects third party asset transfers in client accounts using a Standing Letter of
Authorization (“SLOA”). Pursuant to the SEC No Action Letter, PCB Capital is deemed to have
Custody over these accounts. Accordingly, PCB CAPITAL LLC has instituted procedures and
controls such that it can comply with the seven representations noted in the SEC No-Action letter and
avoid the annual surprise audit requirement. Additionally, since many of the seven representations
involve the qualified custodian’s operations, PCB Capital is in close collaboration to ensure
compliance with the SEC guidance.
Item 16. Investment Discretion
PCB Capital generally is granted the authority to exercise discretion on behalf of its clients. PCB
Capital is considered to exercise investment discretion over a client’s account if it can affect
transactions for the client without first having to seek the client’s consent. PCB Capital is given this
authority through a power-of-attorney included in the agreement between PCB Capital and the client.
Clients may request a limitation on this authority (such as certain securities not to be bought or sold).
Item 17. Voting Client Securities
PCB Capital does not vote client proxies. PCB Capital’s clients maintain exclusive responsibility for:
(1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the
client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers,
bankruptcyproceedingsorothertypeeventspertainingtotheclient’sinvestmentassets. PCB Capital
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May 2026
Page 15
and the client shall correspondingly instruct each custodian of the assets to forward to the client copies
of all proxies and shareholder communications relating to the client’s investment assets.
With respect to shareholder class action litigation and similar matters, PCB Capital generally will not
make any filings in connection with any shareholder class action lawsuits involving securities currently
or previously held in clients’ accounts. PCB Capital recommends that its clients promptly review
these materials, as they identify important deadlines and may require action in the client’s part.
PCB Capital will not be required to notify third party custodians or clients who utilize third party
custodians of shareholder class action lawsuits and similar matters.
Item 18. Financial Information
PCB Capital does not require or solicit the prepayment of more than $1,200 in fees six months or
more in advance. In addition, PCB Capital is required to disclose any financial condition that is
reasonably likely to impair its ability to meet contractual commitments to clients. PCB Capital has not
been the subject of a bankruptcy petition in the last ten years. PCB Capital has no disclosures
pursuant to this Item.