PCM ENCORE, LLC

Disclosure Brochure October 23, 2025 PCM ENCORE, LLC a Registered Investment Adviser 520 East Cooper Avenue, Suite 7C, Aspen, CO 81611 www.encoreinvestment.com (425) 214-1755 This brochure provides information about the qualifications and business practices of PCM Encore, LLC (hereinafter “PCM Encore” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm at the telephone number listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the Firm is available on the SEC’s website at www.adviserinfo.sec.gov. The Firm is a registered investment adviser. Registration does not imply any level of skill or training.  Disclosure Brochure PCM Encore, LLC Item 2. Material Changes In this Item, PCM Encore is required to discuss any material changes that have been made to the brochure since the last other-than-annual amendment dated June 10, 2025. The Firm has updated: • Title Page: o Update to the Firm primary office address Item 4. Advisory Business: • o Disclosure of PCM Tax, LLC Item 5. Fees and Compensation: • o Disclosure of PCM Tax, LLC Item 10. Other Financial Industry Activities and Affiliations • o Disclosure of PCM Tax, LLC Item 10. Other Financial Industry Activities and Affiliations • o Disclosure of Michael Paulus affiliation with American Capital Group Item 12. Brokerage Practices: • o Disclosure of soft-dollar arrangement with Custodian – Morgan Stanley Page | 2 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC Item 3. Table of Contents Item 2. Material Changes ................................................................................................................................................... 2 Item 3. Table of Contents ................................................................................................................................................... 3 Item 4. Advisory Business ................................................................................................................................................. 3 Item 5. Fees and Compensation ......................................................................................................................................... 6 Item 6. Performance-Based Fees and Side-by-Side Management ................................................................................... 10 Item 7. Types of Clients ................................................................................................................................................... 10 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ............................................................................ 10 Item 9. Disciplinary Information ..................................................................................................................................... 14 Item 10. Other Financial Industry Activities and Affiliations .......................................................................................... 14 Item 11. Code of Ethics .................................................................................................................................................... 15 Item 12. Brokerage Practices ........................................................................................................................................... 16 Item 13. Review of Accounts ........................................................................................................................................... 19 Item 14. Client Referrals and Other Compensation ......................................................................................................... 20 Item 15. Custody .............................................................................................................................................................. 21 Item 16. Investment Discretion ........................................................................................................................................ 21 Item 17. Voting Client Securities ..................................................................................................................................... 22 Item 18. Financial Information ........................................................................................................................................ 22 Item 4. Advisory Business PCM Encore offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to PCM Encore rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with PCM Encore setting forth the relevant terms and conditions of the advisory relationship (the “Advisory Agreement”). PCM Encore filed for registration as an investment adviser in September 2024 and is owned by Michael Paulus and Paulus Family Irrevocable Trust. As of February 13, 2025 the Firm had $1,235,192,427 assets under management, all of which were managed on a discretionary basis. Page | 3 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC While this brochure generally describes the business of PCM Encore, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or other persons who provide investment advice on PCM Encore’s behalf and are subject to the Firm’s supervision or control. Financial Planning and Consulting Services • • PCM Encore offers clients a broad range of financial planning and consulting services, which include any or all of the following functions: Business Planning Retirement Planning • • Cash Flow Forecasting Tax Planning • Education Planning Trust and Estate Planning Insurance Planning • • While each of these services is available on a stand-alone basis, certain of them can also be rendered in conjunction with investment portfolio management as part of a comprehensive wealth management engagement (described in more detail below). In performing these services, PCM Encore is not required to verify any information received from the client or from the client’s other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. PCM Encore recommends certain clients engage the Firm for additional related services, its Supervised Persons in their individual capacities as insurance agents and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage PCM Encore or its affiliates to provide (or continue to provide) additional services for compensation, including investment management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by PCM Encore under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising PCM Encore’s recommendations and/or services. Investment and Wealth Management Services PCM Encore provides certain clients with wealth management services which include a broad range of financial planning and consulting services as well as discretionary management of investment portfolios. PCM Encore primarily allocates client assets among various mutual funds and exchange-traded funds (“ETFs”) in accordance with their stated investment objectives. In addition, for certain client with Page | 4 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC additional needs, the Firm can allocate assets to individual debt and equity securities, options, privately placed securities (including debt, equity and/or interests in pooled investment vehicles) and independent investment managers (“Independent Managers”). Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients can engage PCM Encore to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, PCM Encore directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product’s provider. PCM Encore tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios are managed in a manner consistent with those needs and objectives. PCM Encore consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify PCM Encore if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if PCM Encore determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Use of Independent Managers As mentioned above, PCM Encore can select certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement with the designated Independent Manager. That agreement can be between the Firm and the Independent Manager (often called a subadvisor) or the client and the Independent Manager (sometimes called a separate account manager). In addition to this brochure, clients will typically also receive the written disclosure documents of the respective Independent Managers engaged to manage their assets. PCM Encore evaluates a variety of information about Independent Managers, which includes the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance and risk results in relation to its clients’ individual portfolio allocations and risk exposure. PCM Encore also takes into consideration Page | 5 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors. PCM Encore continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. PCM Encore seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. PCM Tax, LLC PCM Tax, LLC (“PCM Tax”) launched in October 2025. Though independent in service offerings from PCM Encore, PCM Tax and PCM Encore are under common control. PCM Tax and respective conflicts of interest are expanded upon below in Item 10. Other Financial Activities and Affiliations PCM Tax is an affiliated platform designed to deliver tax and estate planning services for family office and private wealth clients. The PCM Tax services is entirely voluntary and is not a prerequisite for receiving PCM Encore investment advisory services. Investment advisory clients are under no obligation to use PCM Tax services. Item 5. Fees and Compensation PCM Encore offers services on a fee basis, which includes fixed fees, as well as fees based upon assets under management. Additionally, certain of the Firm’s Supervised Persons, in their individual capacities, offer insurance products under a separate commission-based arrangement. As described above, PCM Tax can obtain fees for tax and estate planning services rendered. The billing and fees for PCM Tax services are separate from investment advisory fees defined below. Clients are advised that PCM Tax creates a conflict of interest for PCM Encore to refer clients to services offered by PCM Tax. Financial Planning and Consulting Fees PCM Encore charges a fixed fee for providing financial planning and consulting services under a standalone engagement. These fees are negotiable, but range from $1,000 to $5,000, depending upon the scope and complexity of the services and the professional rendering the financial planning and/or the consulting services. If the client engages the Firm for additional investment advisory services, PCM Encore can offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. Page | 6 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC The terms and conditions of the financial planning and/or consulting engagement are set forth in the Advisory Agreement. PCM Encore requires one-half of the fee payable upon execution of the Advisory Agreement. The outstanding balance is due upon delivery of the financial plan or completion of the agreed upon services. The Firm does not, however, take receipt of $1,200 or more in prepaid fees, six or more months in advance of services rendered. Investment Management Fees PCM Encore offers investment management services for an annual fee based on the amount of assets under the Firm’s management. This management fee varies depending upon the size and composition of a client’s portfolio, the type and amount of services rendered, the individual(s) providing the services, and the relationship the Firm has with the client. This management fee varies in accordance with the following fee schedule: PORTFOLIO VALUE BASE FEE Up to $1,000,000 1.25% $1,000,001 - $3,000,000 1.15% $3,000,001 - $5,000,000 1.00% 0.85% 0.70% 0.40% 0.30% 0.25% $5,000,001 - $10,000,000 $10,000,001 - $25,000,000 $25,000,001 - $50,000,000 $50,000,001 - $100,000,000 $100,000,001 - $250,000,000 Above $250,000,000 0.20% The annual fee is prorated and charged quarterly, in advance, based upon the market value of the assets being managed by PCM Encore on the last day of the previous quarter as determined by a party independent from the Firm (including the client’s custodian or another third-party). If a valuation for private securities is not available through the custodian, the Firm will typically rely on the valuation provided by the issuer. Because valuations may only be provided periodically (including monthly, quarterly or even annually), the Firm can be billing on a valuation that would be different if updated. That valuation can be higher or lower depending on the increase or decrease in value of the private investment. The Firm includes cash in a client’s account in determining the valuation for billing purposes. The Firm may, in its sole discretion, not include cash in determining the fee, especially where a client has a high percentage of cash for reasons other than the Firm's investment management decision. If assets are deposited into or withdrawn from an account after the inception of a billing period, the fee payable with respect to such assets is adjusted to reflect the interim change in portfolio value. For the initial Page | 7 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC period of an engagement, the fee is calculated on a pro rata basis. In the event the advisory agreement is terminated, the fee for the final billing period is prorated through the effective date of the termination and the outstanding or unearned portion of the fee is charged or refunded to the client, as appropriate. Additionally, for asset management services the Firm provides with respect to certain client holdings (e.g., held-away assets, accommodation accounts, alternative investments, etc.), PCM Encore can negotiate a fee rate that differs from the range set forth above. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage PCM Encore for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. Fee Discretion PCM Encore may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria, such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing/legacy client relationship, account retention, pro bono activities, or competitive purposes. The Firm will discount fees for clients who are charged a fee (or have prior compensation from an adviser or broker-dealer “clawed back”) for moving their account to the Firm and their assets to the brokerdealers/custodians recommended by the Firm. This fee discount is meant to assist these clients so that they are not penalized for switch their adviser to the Firm. Additional Fees and Expenses In addition to the advisory fees paid to PCM Encore, clients also incur certain charges imposed by other third parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions (collectively “Financial Institutions”). These additional charges include securities brokerage commissions, transaction fees, custodial fees, fees attributable to alternative assets, fees charged by the Independent Managers, margin and other borrowing costs, charges imposed directly by a mutual fund or ETF in a client’s account, as 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. The Firm’s brokerage practices are described at length in Item 12, below. Page | 8 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC Use of Third-Party for Certain Assets Held Away For assets held at a custodian that is not directly accessible by the Firm ("Held Away Accounts"), the Firm may, but is not required to, manage these Held Away Accounts using Pontera. Pontera allows the Firm to view and manage assets. The annual fee for investment management services for Held Away Accounts will follow the Firm’s fee schedule as noted above. The fees will not be deducted directly from the accounts managed through Pontera. The client does not pay an additional fee for Pontera. Clients will give written authorization to deduct the Firm’s fees from an account managed by the Firm. Further, the qualified custodian will deliver an account statement to clients at least quarterly. These account statements will show all disbursements in the account. Direct Fee Debit Clients provide PCM Encore and/or certain Independent Managers with the authority to directly debit their accounts for payment of the investment advisory fees. The Financial Institutions that act as the qualified custodian for client accounts, from which the Firm retains the authority to directly deduct fees, have agreed to send statements to clients not less than quarterly detailing all account transactions, including any amounts paid to PCM Encore. Use of Margin PCM Encore can recommend that certain clients utilize margin in the client’s investment portfolio or other borrowing. PCM Encore only recommends such borrowing for non-investment needs, such as bridge loans and other financing needs. The Firm’s fees are determined based upon the value of the assets being managed gross of any margin or borrowing. Account Additions and Withdrawals Clients can make additions to and withdrawals from their account at any time, subject to PCM Encore’s right to terminate an account. Additions can be in cash or securities provided that the Firm reserves the right to liquidate any transferred securities or declines to accept particular securities into a client’s account. Clients can withdraw account assets on notice to PCM Encore, subject to the usual and customary securities settlement procedures. However, the Firm designs its portfolios as long-term investments and the withdrawal of assets may impair the achievement of a client’s investment objectives. PCM Encore may consult with its clients about the options and implications of transferring securities. Clients are advised that when transferred securities are liquidated, they may be subject to transaction fees, short-term redemption fees, fees assessed at the mutual fund level (e.g., contingent deferred sales charges) and/or tax ramifications. Page | 9 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC Item 6. Performance-Based Fees and Side-by-Side Management PCM Encore does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a client’s assets). Item 7. Types of Clients PCM Encore offers services to individuals, trusts, estates, charitable organizations, corporations and other business entities. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies PCM Encore’s investment strategy centers around constructing and maintaining portfolios that match each client’s goals, risk tolerance, and financial needs. The Firm emphasizes diversification of assets and strategic asset management, viewing the market on the long-term basis and managing portfolios when they become out of balance or the client needs change. PCM Encore is also mindful of maintaining tax efficiency in its portfolios. In parts of the Firm’s portfolios where it believes it is difficult to outperform the market, the Firm focuses on finding low-cost solutions. PCM Encore’s offers its clients long-term investment strategies based on Modern Portfolio Theory. PCM Encore believe that asset allocation is the primary driver of portfolio performance and therefore look to construct appropriate portfolios given the clients goals, risks tolerance, and financial needs. We then employ strategic asset management when portfolios fall out of balance or clients needs change. PCM Encore recognizes the power of diversified portfolios to optimize the risk and return of client portfolios. PCM Encore enacts this primarily through the use of passively managed and low-fee mutual funds and ETF’s. PCM Encore may also purchase conservative fixed income securities for clients and utilize SMA’s to optimize tax efficiency. Page | 10 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC PCM Encore recognizes that in certain cases active management may be worth its cost. Because we believe generally in efficient markets, we view these managers with skepticism and have a high bar for their inclusion in client portfolios. PCM Encore recognizes the power of dollar cost averaging and adding investment time as another vector of diversification. Clients are encouraged to regularly contribute to their portfolios in order to allow for systematic investing. PCM Encore is designed for investors seeking a buy-and-hold strategy, recognizing the transaction, tax, and other costs frequent trading brings. Risk of Loss The following list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with respect to the Firm’s investment management activities. Clients should consult with their legal, tax, and other advisors before engaging the Firm to provide investment management services on their behalf. Market Risks Investing involves risk, including the potential loss of principal, and all investors should be guided accordingly. The profitability of a significant portion of PCM Encore’s recommendations and/or investment decisions may depend to a great extent upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. In addition, investments may be adversely affected by financial markets and economic conditions throughout the world. There can be no assurance that PCM Encore will be able to predict these price movements accurately or capitalize on any such assumptions. Volatility Risks The prices and values of investments can be highly volatile, and are influenced by, among other things, interest rates, general economic conditions, the condition of the financial markets, the financial condition of the issuers of such assets, changing supply and demand relationships, and programs and policies of governments. Cash Management Risks The Firm may invest some of a client’s assets temporarily in money market funds or other similar types of investments, during which time an advisory account may be prevented from achieving its investment objective. Page | 11 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC Equity-Related Securities and Instruments The Firm may take long positions in common stocks of U.S. and non-U.S. issuers traded on national securities exchanges and over-the-counter markets. The value of equity securities varies in response to many factors. These factors include, without limitation, factors specific to an issuer and factors specific to the industry in which the issuer participates. Individual companies may report poor results or be negatively affected by industry and/or economic trends and developments, and the stock prices of such companies may suffer a decline in response. In addition, equity securities are subject to stock risk, which is the risk that stock prices historically rise and fall in periodic cycles. U.S. and non-U.S. stock markets have experienced periods of substantial price volatility in the past and may do so again in the future. In addition, investments in small-capitalization, mid-capitalization and financially distressed companies may be subject to more abrupt or erratic price movements and may lack sufficient market liquidity, and these issuers often face greater business risks. Fixed Income Securities While the Firm emphasizes risk-averse management and capital preservation in its fixed-income bond portfolios, clients who invest in this product can lose money, including losing a portion of their original investment. The prices of the securities in our portfolios fluctuate. The Firm does not guarantee any particular level of performance. Below is a representative list of the types of risks clients should consider before investing in this product. • Interest rate risk. Prices of bonds tend to move in the opposite direction to interest rate changes. Typically, a rise in interest rates will negatively affect bond prices. The longer the duration and average maturity of a portfolio, the greater the likely reaction to interest rate moves. • Credit (or default) risk. A bond’s price will generally fall if the issuer fails to make a scheduled interest or principal payment, if the credit rating of the security is downgraded, or if the perceived creditworthiness of the issuer deteriorates. • Liquidity risk. Sectors of the bond market can experience a sudden downturn in trading activity. When there is little or no trading activity in a security, it can be difficult to sell the security at or near its perceived value. In such a market, bond prices may fall. • Call risk. Some bonds give the issuer the option to call or redeem the bond before the maturity date. If an issuer calls a bond when interest rates are declining, the proceeds may have to be reinvested at a lower yield. During periods of market illiquidity or rising rates, prices of callable securities may be subject to increased volatility. • Prepayment risk. When interest rates fall, the principal of mortgage-backed securities may be prepaid. These prepayments can reduce the portfolio’s yield because proceeds may have to be reinvested at a lower yield. Page | 12 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC • Extension risk. When interest rates rise or there is a lack of refinancing opportunities, prepayments of mortgage-backed securities or callable bonds may be less than expected. This would lengthen the portfolio’s duration and average maturity and increase its sensitivity to rising rates and its potential for price declines. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for index-based ETFs and potentially more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Finally, some mutual funds and ETFs may have lock-up periods that restrict an investor from selling their position for a period of time. Other mutual funds and ETFs could also have early redemption fees that are taken if the investor sells their position before a certain amount of time. Use of Independent Managers As stated above, PCM Encore selects certain Independent Managers to manage a portion of its clients’ assets. In these situations, PCM Encore continues to conduct ongoing due diligence of such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategies. In addition, PCM Encore does not have the ability to supervise the Independent Managers on a day-to-day basis. Page | 13 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC Use of Private Collective Investment Vehicles PCM Encore recommends that certain clients invest in privately placed collective investment vehicles (e.g., hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments which may be traded and no requirement to diversify. Hedge funds may trade on margin or otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not registered as investment companies, there is an absence of regulation and regulatory oversight. There are numerous other risks in investing in these securities. Clients should consult each fund’s private placement memorandum and/or other documents explaining such risks prior to investing. Use of Private Investments PCM Encore recommends that certain clients invest in privately placed securities in companies. This can be debt or equity investments. The investments are not registered so there is an absence of regulation and regulatory oversight. There are numerous other risks in investing in these securities. Clients should consult each investments private placement memorandum and/or other documents explaining such risks prior to investing. Interest Rate Risks Interest rates may fluctuate significantly, causing price volatility with respect to securities or instruments held by clients. Item 9. Disciplinary Information PCM Encore has not been involved in any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of its management. Item 10. Other Financial Industry Activities and Affiliations This item requires investment advisers to disclose certain financial industry activities and affiliations. The Firm recently instituted PCM Tax, LLC, (“PCM Tax”) a dedicated platform focused on proactive tax strategy for clients. PCM Tax is not a registered investment adviser with the Securities and Exchange Commission, nor does it provide investment advice to clients. PCM Tax is an additional elected service that can be offered to and opted into by existing and prospective PCM Encore clients. This presents a conflict of interest, as PCM Encore will be incentivized to offer and promote PCM Tax services to clients, in which Page | 14 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC the elected tax services of PCM Tax are not inclusive of the fee schedule indicated in the client wealth management agreement. PCM Encore discloses that the Firm Chief Executive Officer – Michael Paulus - is affiliated with American Capital Group (“ACG”), a real estate investment and development firm. PCM Encore clients are advised that this creates a conflict of interest wherein Mr. Paulus has financial interest in the business and performance of investments managed by ACG. PCM Encore is committed to acting in the best interest of our clients and have adopted a compliance manual and code of ethics to ensure this philosophy is upheld. Item 11. Code of Ethics PCM Encore has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that sets forth the standards of conduct expected of its Supervised Persons. PCM Encore’s Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Firm or any of its Supervised Persons and the trading by the same of securities ahead of clients in order to take advantage of pending orders. The Code of Ethics also requires certain of PCM Encore’s personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Firm’s Supervised Persons are permitted to buy or sell securities that it also recommends to clients if done in a fair and equitable manner that is consistent with the Firm’s policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below. When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless: • the transaction has been completed; • the transaction for the Supervised Person is completed as part of a batch trade with clients; or • a decision has been made not to engage in the transaction for the client. These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high quality short-term debt instruments, including repurchase Page | 15 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC agreements; (iii) shares issued by money market funds; and iv) shares issued by other unaffiliated open-end mutual funds. Clients and prospective clients may contact PCM Encore to request a copy of its Code of Ethics by contacting the Firm at the phone number on the cover page of this brochure. Item 12. Brokerage Practices Recommendation of Broker-Dealers for Client Transactions PCM Encore recommends that clients utilize the custody, brokerage and clearing services of Morgan Stanley Smith Barney LLC (“Morgan Stanley”), Charles Schwab & Co, Inc. through its Schwab Advisor Services division (“Schwab”) and National Financial Services LLC and Fidelity Brokerage Services LLC (together with affiliates, “Fidelity” and together with Schwab and Morgan Stanley “Custodian”) for investment management accounts. The final decision to custody assets with Custodian is at the discretion of the client, including those accounts under ERISA or IRA rules and regulations, in which case the client is acting as either the plan sponsor or IRA accountholder. PCM Encore is independently owned and operated and not affiliated with Custodian. Custodian provides PCM Encore with access to its institutional trading and custody services, which are typically not available to retail investors. Factors which PCM Encore considers in recommending Custodian or any other broker-dealer to clients include their respective financial strength, reputation, execution, pricing, research and service. Custodian enables the Firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Custodian may be higher or lower than those charged by other Financial Institutions. The commissions paid by PCM Encore’s clients to Custodian comply with the Firm’s duty to obtain “best execution.” Clients may pay commissions that are higher than another qualified Financial Institution might charge to effect the same transaction where PCM Encore 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. PCM Encore seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. PCM Encore periodically and systematically reviews its policies and procedures regarding its recommendation of Financial Institutions in light of its duty to obtain best execution. Page | 16 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC Software and Support Provided by Financial Institutions PCM Encore receives Custodian administrative support, brokerage support, computer software, related systems support, research and other third-party support as further described below (together "Support") which allow PCM Encore to better monitor client accounts maintained at Custodian and otherwise conduct its business. PCM Encore maintains custodial relationships with multiple Custodians (defined further in Item 12. Brokerage Practices below), of which the Support may require varying fees to be incurred by client accounts (“Soft Dollars”). PCM Encore has a Soft Dollar arrangement with Custodian - Morgan Stanley - in which a 10bps relationship partnership fee is assessed to PCM Encore client accounts. The calculation of the 10bps relationship partnership fee assessment is based on asset value of respective Morgan Stanley client accounts. The Support received from Custodian benefits PCM Encore, but not its clients directly. Clients should be aware that PCM Encore’s receipt of economic benefits such as the Support from a broker- dealer creates a conflict of interest since these benefits will influence the Firm’s choice of broker-dealer over another that does not furnish similar software, systems support or services. In fulfilling its duties to its clients, PCM Encore endeavors at all times to put the interests of its clients first and has determined that the recommendation of Custodian is in the best interest of clients and satisfies the Firm's duty to seek best execution. Specifically, PCM Encore receives the following benefits from Custodians: i) receipt of duplicate client confirmations and bundled duplicate statements; ii) access to a trading desk that exclusively services its institutional traders; iii) access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and iv) access to an electronic communication network for client order entry and account information. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them so long as a certain amount of the advisor’s clients’ assets are maintained in accounts at Custodian. Custodian’s services include 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 client accounts maintained in its custody, Custodian 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 Custodian or that settle into Custodian accounts. Custodian also makes available to the Firm other products and services that benefit the Firm but may not benefit its clients’ accounts. These benefits may include national, regional or Firm specific educational events organized and/or sponsored by Custodian. Other potential benefits may include occasional business entertainment of personnel of PCM Encore by Custodian personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany Page | 17 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC educational opportunities. Other of these products and services assist PCM Encore 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), provide research, pricing information and other market data, facilitate payment of the Firm's fees from its clients’ accounts, 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 the Firm’s accounts, including accounts not maintained at Custodian. Custodian also makes available to PCM Encore other services intended to help the Firm 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, human capital consultants, insurance and marketing. In addition, Custodian may make available, arrange and/or pay vendors for these types of services rendered to the Firm by independent third parties. Custodian 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 the Firm. While, as a fiduciary, PCM Encore endeavors to act in its clients’ best interests, the Firm's recommendation that clients maintain their assets in accounts at Custodian may be based in part on the benefits received and not solely on the nature, cost or quality of custody and brokerage services provided by Custodian, which creates a conflict of interest. Brokerage for Client Referrals PCM Encore does not consider, in selecting or recommending broker-dealers, whether the Firm receives client referrals from the Financial Institutions or other third party. Directed Brokerage The client may direct PCM Encore 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 the Firm 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 PCM Encore (as described above). As a result, the client may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net prices, on transactions for the account than would otherwise be the case. Subject to its duty of best execution, PCM Encore may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties. Page | 18 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC Trade Aggregation Transactions for each client will be effected independently, unless PCM Encore decides to purchase or sell the same securities for several clients at approximately the same time. PCM Encore 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 the Firm’s clients differences in prices and commissions or other transaction costs that might not have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and allocated among PCM Encore’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that the Firm determines to aggregate client orders for the purchase or sale of securities, including securities in which PCM Encore’s Supervised Persons may invest, the Firm 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. PCM Encore does not receive any additional compensation or remuneration as a result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which 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 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, the Firm 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 Account Reviews PCM Encore monitors client portfolios on a continuous and ongoing basis and regular account reviews are conducted on at least an annual basis. Such reviews are conducted by the Firm’s Investment Committee Page | 19 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC and/or investment adviser representatives. All investment advisory clients are encouraged to discuss their needs, goals and objectives with PCM Encore and to keep the Firm informed of any changes thereto. Account Statements and Reports Clients are provided with transaction confirmation notices and regular summary account statements directly from the Financial Institutions where their assets are custodied. From time-to-time or as otherwise requested, clients may also receive written or electronic reports from PCM Encore and/or an outside service provider, which contain certain account and/or market-related information, such as an inventory of account holdings or account performance. Clients should compare the account statements they receive from their custodian with any documents or reports they receive from PCM Encore or an outside service provider. Item 14. Client Referrals and Other Compensation Client Referrals In the event a client is introduced to PCM Encore by either an unaffiliated or an affiliated solicitor, the Firm may pay that solicitor a referral fee in accordance with applicable securities laws. Unless otherwise disclosed, any such referral fee is paid solely from PCM Encore’s investment management fee and does not result in any additional charge to the client. If the client is introduced to the Firm by an unaffiliated solicitor, the client will receive a solicitor’s disclosure statement containing the terms and conditions of the solicitation arrangement and any conflicts of interest. Any affiliated solicitor of PCM Encore is required to disclose the nature of his or her relationship to prospective clients at the time of the solicitation. Compensation for Referring Clients Through advisermatch.com The Firm provides a referral service through advisermatch.com. Advisermatch.com helps to connect individuals with financial advisors. The Firm is one of the financial advisors that users can be connected to, but there are other financial advisors as well. The connections are not provided as investment advice by the Firm. The Firm has a conflict of interest to recommend itself to users of advisermatch.com. In addition, the Firm receives referral fees from other financial advisors for the connections. Therefore, there is a conflict of interest for the Firm to connect prospects to the financial advisors that pay a referral fee to the Firm over other financial advisors. Page | 20 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC Other Compensation The Firm receives economic benefits from Custodian. The benefits, conflicts of interest and how they are addressed are discussed above in response to Item 12. Item 15. Custody PCM Encore is deemed to have custody of client funds and securities because the Firm is given the ability to debit client accounts for payment of the Firm’s fees. As such, client funds and securities are maintained at one or more Financial Institutions that serve as the qualified custodian with respect to such assets. Such qualified custodians will send account statements to clients at least once per calendar quarter that typically detail any transactions in such account for the relevant period. In addition, as discussed in Item 13, PCM Encore will also send, or otherwise make available, periodic supplemental reports to clients. Clients should carefully review the statements sent directly by the Financial Institutions and compare them to those received from PCM Encore. Any other custody disclosures can be found in the Firm’s Form ADV Part 1. Standing Letters of Authorization PCM Encore also has custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017 which includes (in summary): i) client will provide instruction for the SLOA to the custodian; ii) client will authorize the Firm to direct transfers to the specific third party; iii) the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv) the client will have the ability to terminate or change the instruction; v) the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi) the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii) the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16. Investment Discretion PCM Encore is given the authority to exercise discretion on behalf of clients. PCM Encore is considered to exercise investment discretion over a client’s account if it can effect and/or direct transactions in client accounts without first seeking their consent. PCM Encore is given this authority through a power-ofattorney Page | 21 © MarketCounsel 2025  Disclosure Brochure PCM Encore, LLC included in the agreement between PCM Encore and the client. Clients may request a limitation on this authority (such as certain securities not to be bought or sold). PCM Encore takes discretion over the following activities: • The securities to be purchased or sold; • The amount of securities to be purchased or sold; • When transactions are made; and • The Independent Managers to be hired or fired. Item 17. Voting Client Securities Declination of Proxy Voting Authority PCM Encore does not accept the authority to vote a client’s securities (i.e., proxies) on their behalf. Clients receive proxies directly from the Financial Institutions where their assets are custodied and may contact the Firm at the contact information on the cover of this brochure with questions about any such issuer solicitations. Item 18. Financial Information PCM Encore is not required to disclose any financial information listed in the instructions to Item 18 because: • The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or more in advance of services rendered; • The Firm does not have a financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients; and • The Firm has not been the subject of a bankruptcy petition at any time during the past ten years. Page | 22 © MarketCounsel 2025