Per Stirling Capital Management, LLC

FORM ADV PART 2A – Disclosure Brochure Version Date: 03/30/2026 4800 Bee Caves Road Austin, Texas 78746 www.perstirling.com (512) 628-2300 (888) 355-6075 Fax: (512) 551-0050 CRD#: 151671 This brochure provides information about the qualifications and business practices of Per Stirling Capital Management, LLC, DBA Per Stirling Private Wealth. If you have any questions about the Item 1. Cover Letter contents of this brochure, please contact us at (512) 628-2300 or by e-mail at info@perstirling.com. 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. Per Stirling Capital Management, LLC, is a Registered Investment Advisor (“RIA”) headquartered in Austin, Texas, registered with the United States Securities and Exchange Commission (“SEC”). Please note that being “registered” does not imply a certain level of skill or training. Additional information on Per Stirling Capital Management, LLC, is also available on the SEC’s website at www.adviserinfo.sec.gov. Page 1 of 2  Item 2. Material Changes Material Changes This section of the brochure will be updated annually or when material changes occur since the previous release of our Disclosure Brochure. Since the last annual update, dated March 28, 2025, no material changes have occurred. More Information Available Current copies of the firm’s disclosures are available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching the firm name or CRD #: 151671. You can also visit our website at www.perstirling.com. You can contact us via email at info@perstirling.com or call us directly at (512) 628-2300 to request up-to-date information or copies of any of our disclosures. Page 2 of 3  Item 3. Table of Contents Item 1. Cover Letter ................................................................................................................... 1 Item 2. Material Changes .......................................................................................................... 2 Material Changes ......................................................................................................................................... 2 More Information Available ...................................................................................................................... 2 Item 3. Table of Contents .......................................................................................................... 3 Item 4. Advisory Business ......................................................................................................... 5 Firm Description ......................................................................................................................................... 5 Principal Owners ......................................................................................................................................... 5 Types of Advisory Services ........................................................................................................................ 5 Investment Management Services ............................................................................................................ 5 Financial Planning Services ........................................................................................................................ 5 Tailored Relationships ................................................................................................................................ 7 Item 5. Fees and Compensation ................................................................................................ 7 Investment Management Fees .................................................................................................................. 7 Financial Planning Fees .............................................................................................................................. 8 Fee Billing ..................................................................................................................................................... 8 Other Fees and Expenses .......................................................................................................................... 9 Termination of Advisory Services ............................................................................................................ 9 Item 6. Performance-Based Fees and Side-By-Side Management ......................................... 10 Sharing of Capital Gains .......................................................................................................................... 10 Item 7. Types of Clients .......................................................................................................... 10 Description ................................................................................................................................................. 10 Asset Minimums ........................................................................................................................................ 10 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss................................... 11 Methods of Analysis ................................................................................................................................. 11 Investment Strategies ................................................................................................................................ 11 Risk of Loss ............................................................................................................................................... 11 Item 9. Disciplinary Information ............................................................................................ 12 Legal and Disciplinary .............................................................................................................................. 12 Item 10. Other Financial Industry Activities and Affiliations ................................................. 12 Financial Industry Activities .................................................................................................................... 12 Affiliations .................................................................................................................................................. 13 Page 3 of 4  Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................................................................................................... 13 Code of Ethics ........................................................................................................................................... 13 Fiduciary Acknowledgement ................................................................................................................... 13 Personal Trading ....................................................................................................................................... 14 Item 12. Brokerage Practices ................................................................................................... 14 Selecting Brokerage Firms ....................................................................................................................... 14 Soft Dollars ................................................................................................................................................ 15 Order Aggregation .................................................................................................................................... 16 Item 13. Review of Accounts ................................................................................................... 16 Periodic Reviews ....................................................................................................................................... 16 Review Triggers ......................................................................................................................................... 16 Regular Reports ......................................................................................................................................... 16 Item 14. Client Referrals and Other Compensation ................................................................ 16 Incoming Referrals .................................................................................................................................... 16 Outgoing Referrals .................................................................................................................................... 16 Promoter Arrangement ............................................................................................................................ 17 Item 15. Custody ...................................................................................................................... 17 Custody ....................................................................................................................................................... 17 Account Statements and Performance Reports.................................................................................... 17 Item 16. Investment Discretion ............................................................................................... 18 Discretionary Authority for Trading ...................................................................................................... 18 Item 17. Voting Client Securities ............................................................................................. 18 Proxy Votes ................................................................................................................................................ 18 Item 18. Financial Information ................................................................................................ 18 Financial Condition................................................................................................................................... 18 Business Continuity Plan ........................................................................................................ 18 Privacy Policy .......................................................................................................................... 19 Page 4 of 5  Item 4. Advisory Business Firm Description Per Stirling Capital Management, LLC, DBA Per Stirling Private Wealth (hereafter “PSCM”), was founded in 2009. The firm’s two directors, John Per O’Sullivan, and Robert Stirling Phipps, III, have decades of working and managing portfolios together. They have held the positions of President, Director, Chief Investment Officer, or Chief Market Strategist of Registered Investment Advisory and/or broker-dealer firms. PSCM’s core competencies include providing discretionary investment management services, along with comprehensive financial planning and consulting services. Further details on these services are outlined below. PSCM is a fee-based Registered Investment Advisor firm and does not sell commissioned products. However, while PSCM is fee-only, some of our registered individuals are dually registered with B. B. Graham & Co., Inc., a registered broker-dealer and member of FINRA/SIPC and can accept commissions for products sold through the broker-dealer. Principal Owners John Per O’Sullivan and Robert Stirling Phipps, III, are the managing members of Per Stirling Capital Management, LLC, and Per Stirling Private Wealth, a DBA of Per Stirling Capital Management, LLC. Of note, John Per O’Sullivan is affiliated with B. B. Graham & Co., Inc., as a Registered Representative, and is located in their Austin, Texas, branch office location, which operates as an Office of Supervisory Jurisdiction (an office identified by the broker-dealer as having supervisory responsibilities). Types of Advisory Services Investment Management Services Most clients choose to have Investment Advisor Representatives (IARs”) of PSCM manage their assets in order to receive ongoing investment advice and continuous investment management, which requires an Investment Management Agreement that details the fee agreement and services provided. The majority of PSCM’s assets under management are invested in portfolios that are designed for the client by their IAR based on the investment objectives noted by the client on their New Client Application. As of December 31, 2025, PSCM manages approximately $1,566,020,358 in assets. All the firm’s assets under management are managed on a discretionary basis. Financial Planning Services PSCM believes that there are benefits to a client working with a financial advisor to craft a financial program and thus encourage clients to discuss the potential benefits of designing a financial plan with their IAR (i.e. the client’s personal financial advisor). PSCM offers financial planning services that can address everything from your current financial situation to your long-term financial goals and objectives. Financial plans can be Page 5 of 6  Investment management Insurance planning either comprehensive or issue specific. A financial plan can include, but is not limited to, areas of: • • Retirement planning • Estate planning • • Tax planning • Asset protection strategies • College funding strategies CONSULTING SERVICES In addition to a financial plan or on-going financial planning services, PSCM also provides consulting services for clients who need advice on a limited scope of work. Together with the IAR, it is determined how much time is required to complete the requested consultations and decide whether the services are billed on an hourly or fixed-fee basis. Fees for consulting services are negotiable based upon the complexity of your situation and the actual services requested. Clients can also receive professional advice on a more limited basis. This may include advice only on isolated areas of concern such as estate planning, retirement planning, or any other specific topic. IARs provide specific consultation services regarding a client’s current or projected financial position or other investment and financial concerns that client may have. Recommendations may be of a generic nature or tailored to specific securities, as outlined in the agreement signed by the client prior to accepting the consulting engagement. Some IARs can also provide consulting services towards clients initiating 1031 exchanges of real property and seeking advice towards re-investment of assets received from the exchange. IARs will provide recommendations regarding the reinvestment of assets into Delaware Statutory Trusts (DST) or any real property instrument. Although IARs may assist clients with the preparation of direct application purchase, PSCM does not facilitate the exchange or purchase of such properties or any investment. Clients may or may not choose to accept the recommendations made by IARs. Some IARs participate in the process of Collaborative Divorce with their clients. In order to engage in these services with their clients, separate Agreement(s) must be signed between the IAR and their client(s) that outlines the IAR’s participation in the process of Collaborative Divorce. These Agreement(s) include, but are not limited to, the services the IAR offers, the fees and how those fees should be paid, how the IAR will interact with their counsel, communication policies, confidentiality of information, and any conflicts of interest that may be present. Please note that none of the aforementioned services include legal or tax advice. You are urged to work closely with your attorney, accountant, or other professionals regarding your financial and personal situation. Page 6 of 7  Tailored Relationships The goals and investment objectives for each client are documented in the firm’s new client documentation. Clients may impose restrictions on investing in certain securities or types of securities. Such restrictions must be agreed to in writing by both the client and the IAR. Item 5. Fees and Compensation Investment Management Fees For clients receiving investment management services, the annual Investment Management Agreement fee is based on a percentage of the investable assets under management (sometimes referred to as an “asset-based fee”) or a flat fee. These advisory fees, which are not to exceed 2.0% of assets under management per annum, are determined between the client and the IAR and may be negotiable based upon certain criteria, including, but not limited to, historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, etc. For an account where PSCM charges an asset-based fee, the more assets there are in your account, the more you will pay in fees, and an IAR therefore has an incentive to encourage you to increase the assets in your account, including transferring or rolling over assets from other accounts. In certain instances, where clients request services outside of PSCM’s core investment management services, hourly charges or fixed fees may apply. Any such hourly charges or fixed fees would be specified in advance through separate agreements. PER STIRLING PRIVATE WEALTH For clients receiving investment management services through Per Stirling Capital Management, LLC’s DBA, Per Stirling Private Wealth, fees for investment management services are based on the following tiered schedule: Assets Under Management Annual Fee (%) 1.00% $0 - $2,000,000 0.85% $2,000,001 - $5,000,000 0.70% $5,000,001 - $10,000,000 0.60% $10,000,001 - $20,000,000 0.50% $20,000,001 and up These fees are determined between the client and Per Stirling Private Wealth and may be negotiable based upon certain criteria, including, but not limited to, historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, etc. Page 7 of 8  Financial Planning Fees Fees for financial planning services are noted on the Financial Planning Agreement and negotiable based on the complexity of your financial situation, the actual services requested, and the IAR providing the services. If a fixed fee is selected for services, a deposit may be due upon presentation of initial invoice to the client. Fixed-fee Services terminate upon presentation of the financial plan or completion of the requested services. If the client requires services after a one-year period, a new Agreement will be required. Fees for financial planning services may also be charged on an hourly-fee basis. If the actual hours needed to complete the plan are more than the estimate given, the IAR will contact the client before proceeding with additional work beyond the estimate. The client will be charged for the actual time expended on preparation of the plan. Any unpaid hourly fees will be due immediately from the client upon presentation of invoice. PSCM also provides hourly consulting services for clients who need advice on a limited scope of work. The hourly rate for limited-scope engagements will vary depending on the expertise of the IAR and the services provided. Consulting services for 1031 Exchange recommendations are billed on a fixed fee not to exceed 5% of the assets included in the recommendations of the 1031 assessment. Clients sign written agreements with their qualified intermediaries which provide that PSCM fees are billed to the qualified intermediary, chosen by the client, and the qualified intermediary pays the fee to PSCM. PSCM provides a written notice of the fee to each client and their qualified intermediary. Fee Billing Investment management fees are billed quarterly, in advance, meaning that PSCM will invoice you, or debit your account, at the beginning of the three-month billing period. Fees are usually deducted from a designated client account to facilitate billing, or payment in full is expected upon an invoice presentation. The client must consent in advance to direct debiting of their investment account. This is further explained and documented in the Investment Management Agreement. Typically, investment management fees will be debited from or billed to each account at the beginning of each quarter based on the value of the account as of the end of the prior quarter. The following formula will be used to determine the fee amounts to be assessed. (Account Value X Management Fee) X (of days in the Quarter/365) Example: The quarterly assessment (for a 91-day quarter) on a $100,000 portfolio with a 150-basis point (1.50%) annual management fee would be $373.97 as shown: ($100,000 X .015) X (91/365) = $373.97 Fees are payable in advance on the 7th day of the quarter and delinquent after the 15th day of the quarter. Any account in which fees are delinquent for more than 15 days is subject to termination of services hereunder, and any fees earned by the Advisor but unpaid by the client will accrue at an interest rate equivalent to the prevailing Prime Rate as published by the Wall Street Journal plus 3%. Clients whose services have been terminated will be notified in writing either by mail to the last known address and/or email if a client has consented to Page 8 of 9  electronic delivery. The firm will not automatically change an investment position in the event of termination of services regardless of the type of account. Prorating for New Client Assets is calculated by the following formula: Quarterly Calculation x {Days Remaining in Quarter/Total # of Days in Quarter} Prorating for Terminating Accounts is calculated by the following formula: Most Recent Quarterly Fee Assessment X {Days Remaining in Quarter/ Total Number of Days in Quarter} Other Fees and Expenses In addition to investment management fees, the client approves the custodian to be used for investment management accounts. Custodians will charge transaction fees on purchases or sales of certain investments. If applicable to your account, you will also pay for other fees including account maintenance fees such as custody, trade confirmation processing, corporate actions, and transfer fees; cash management fees such as cash sweeps, checking and wire fees; and investment specific fees for the administration of alternative investments or foreign securities. Your IAR may recommend that your account be maintained with a custodian who directly debits fees. In such cases, we have no control over the billing schedule or the specific periods covered by these charges. Additionally, the total amount billed may differ from the amount specified in your Investment Management Agreement due to additional fees imposed by the custodian, which are not earned by the IAR. Nonetheless, the fees charged to you will not exceed those outlined in the Investment Management Agreement. Although cost is an important factor that is considered when making a recommendation, it is not the only consideration and therefore recommendations are not always the lowest cost option available. As fees and costs affect the value of your account over time, please ask your IAR to give you personalized information on the fees and costs that you will pay. PSCM does not receive any portion of the fees or costs paid by the client to the custodian. PSCM offers three proprietary model portfolios. The firm’s directors act as portfolio managers for these models offered through Per Stirling Private Wealth, and they are accessible to other PSCM clients for a negotiable fee. Consequently, there is a potential conflict of interest when recommending these portfolios since clients who invest in them may generate higher revenue for the firm compared to those who do not. Termination of Advisory Services Investment management fees are payable in advance on the 7th day of the quarter and delinquent after the 15th day of the quarter. PSCM reserves the right to stop work on any account that is more than 15 days overdue. PSCM also reserves the right to stop work on any account for reasons including, but not limited to, the inability to reach client over an extended period of time or for any reason which impairs PSCM’s ability to appropriately advise the client. Clients whose services have been terminated will be notified in writing either by mail to the last known address and/or email if a client has consented to electronic delivery. Page 9 of 10  A client may also terminate an Agreement with PSCM by providing written notice and termination will be effective upon receipt of such notice. Upon termination, if fees are due to the client, any prepaid and unearned fees exceeding $25.00 will be refunded to the client on a prorated basis according to the formula for terminating accounts noted above. Item 6. Performance-Based Fees and Side-By-Side Management Sharing of Capital Gains Fees are not based on a share of the capital gains or capital appreciation of managed securities. PSCM does not use a performance-based fee structure because of the potential conflict of interest. Performance-based compensation may create an incentive for the IAR to recommend an investment that may carry a higher degree of risk to the client. Item 7. Types of Clients Description PSCM provides advisory services to clients including individuals, corporations or other business entities, trusts, estates, and charitable organizations. While not its core market, PSCM may also provide services to banks or thrift institutions, investment companies, and pension and profit-sharing plans. Client relationships vary in scope and length of service. Asset Minimums The minimum investable assets required for investment management services is $250,000 of assets under management per client “household”. However, these minimums may be waived by PSCM, in its sole discretion, based upon certain criteria (i.e. historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). Page 10 of 11  Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods that IARs may use include charting, fundamental analysis, technical analysis, cyclical analysis, statistical analysis and back-testing. TYPES OF MARKET ANALYSIS Fundamental analysis is based upon fundamental news such as market valuations, earnings growth rates, economic data, currency trends, the interest rate outlook, and the prospects for fiscal and monetary policy. Technical analysis is based on mathematical models and chart patterns. It is intended to provide insight into a market’s internal condition by gauging factors such as investor sentiment, price momentum, and technical valuation. Statistical analysis and back-testing helps the management team to anticipate how various portfolio allocations might perform based upon historical relationships and statistical factors such as absolute volatility, relative volatility, risk-adjusted return, and price correlation. The main sources of fundamental information include financial newspapers, magazines and websites, CNBC, Bloomberg TV, inspections of corporate activities, research materials prepared by others, corporate rating services, annual reports, prospectuses, filings with the Securities and Exchange Commission, and company press releases. Other sources of information that IARs may use include, but are not limited to, Orion Advisor, Morningstar, and tools offered by the firm’s qualified custodians. Investment Strategies IARs manage portfolios across an array of objectives and strategies. Objectives for portfolios range from capital preservation and current income to long-term growth and tactical sector allocation. The investment strategy for a client is based upon the investment objectives, time horizon, financial situation and tolerance of risk stated by the client. The client may change these objectives at any time. It is the responsibility of the client to discuss any such changes with their IAR. Risk of Loss All investment programs have certain risks that are borne by the investor. Past performance is not a guarantee of future returns. Investing in securities and other investments involves a risk of loss that each client should understand and be willing to bear. Clients are reminded to discuss these risks with their IAR. Risks that investors face include, but are not limited to:  Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. Page 11 of 12   Inflation Risk: When any type of inflation is present, a dollar today will buy more than will a dollar next year, because purchasing power is eroding at the rate of inflation.  Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk to profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. The risks associated with potential speculative components of an IAR’s particular strategy are provided to each client in advance of investing client accounts. The IAR will work with each client to determine their tolerance for risk as part of the portfolio construction process. Item 9. Disciplinary Information Legal and Disciplinary As of the date of this brochure, the firm has not been involved in any legal or disciplinary events. If, in the future, an IAR joins the firm who has a legal or disciplinary event in their history, or if a current IAR is the subject of a legal or disciplinary event, the details of such an event will be disclosed in that IAR’s Form U4 and/or Form ADV Part 2B. Form ADV Part 2B will be provided to all current and prospective clients of that IAR. Additional information on PSCM and each IAR of PSCM is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. Item 10. Other Financial Industry Activities and Affiliations Financial Industry Activities PSCM is not registered as a securities broker-dealer, a futures commission merchant, commodity pool operator or commodity trading advisor. Page 12 of 13  Affiliations Some IARs of PSCM are also Registered Representatives (brokers) and are licensed to sell securities through B. B. Graham & Co., Inc., a registered broker-dealer and member of FINRA/SIPC and may also be licensed to sell insurance products through various insurance companies. Differing scales and terms of compensation between investment advisor and broker-dealer platforms creates a potential conflict of interest in recommending one platform in lieu of another. Aside from the above, PSCM has no affiliation relationships or arrangements that are material to its advisory business or its clients. PSCM does not receive commissions or other transaction-related compensation on any account managed by PSCM. Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Associated Persons of PSCM (as defined by IARs, Employees, and registered Promoters of PSCM) have committed to a Code of Ethics that is available for review upon request. In summary, the Code of Ethics is based on the principle that PSCM and each of its Associated Persons owe a fiduciary duty to its clients and a duty to comply with federal and state securities laws and all other applicable laws. In recognition of this fact, PSCM requires that all Associated Persons must place the interest of the clients first and conduct themselves honestly and professionally. Associated Persons have a duty to take appropriate action if any illegal or unethical activity comes to their attention. Associated Persons must refrain from actions or activities that allow a person to profit or benefit from his or her position with respect to a client, or that otherwise bring into question the Associated Person’s independence or judgment. This includes the obligation of Associated Persons to conduct their personal securities transactions in a manner that does not interfere with the transactions of any client or otherwise to take unfair advantage of their relationship with clients. If you would like a copy of PSCM’s Code of Ethics, please contact us via email at info@perstirling.com or call us directly at (512) 628-2300 to request a copy. Fiduciary Acknowledgement PSCM and its IARS act as a fiduciary and is committed to always act in what it perceives to be in the best interest of its clients. IARs are making investment recommendations to you regarding your retirement plan account or individual retirement account (IRA) as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code (Code), as applicable, which are laws governing retirement accounts. The way we make money or otherwise are compensated creates some conflicts with your financial interests, so Page 13 of 14  we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. When we provide investment advice, we are subject to various legal requirements that are overseen by different regulators. We are required to acknowledge fiduciary status under ERISA and the Code for advice we provide to your retirement plan account or IRA. This acknowledgment is not intended to create or modify any agreement, relationship, or obligation we may have to you under other federal and state laws governing the provision of advice to retail investors. Personal Trading IARs may buy or sell securities that are also held by clients. When trading for personal accounts, IARs may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its clients can potentially be violated if personal trades are made with more advantageous terms than client trades, and in turn, such trades are usually aggregated or will not be placed ahead of client trades. For information regarding aggregated trades, please refer to the section, “Order Aggregation”. This risk is mitigated by personal trades being reviewed by the Compliance Department. The personal trading reviews ensure that the personal trading activities do not adversely affect clients of PSCM or the general market by trading being based on material non-public information. Item 12. Brokerage Practices Selecting Brokerage Firms With the exception of the above-noted affiliations, PSCM does not have any affiliation with product sales firms. Specific custodian recommendations are made to clients based on their need for such services. IARs recommend custodians based on the proven integrity and financial responsibility of the firm and the best execution of orders at reasonable rates. PSCM primarily recommends Fidelity Investments/National Financial Services, LLC, and Charles Schwab & Co., Inc. as the qualified custodians utilized by the firm. The client ultimately decides which brokerage firm is selected as the custodian firm. However, certain services may not be available through all brokerage platforms. PSCM reviews the execution of trades at each custodian on an ongoing basis. Trading fees charged by the custodians are also reviewed on an ongoing basis. PSCM does not receive any portion of the trading fees. Page 14 of 15  Soft Dollars Investment Advisers may direct portfolio brokerage discounts to a particular broker-dealer in return for services and research used in making investment decisions in client accounts. The discounts used to acquire these services and research, are known as “soft dollars.” Section 28(e) of the Securities Exchange Act of 1934 provides a “safe harbor” that allows an investment advisor to pay more than the lowest available commission for brokerage and research services if it determines in good faith that the commission paid was reasonable in relation to the brokerage and research services provided. Although PSCM does not allow directed brokerage, PSCM and IARs may still receive products and services from other program sponsors and product issuers. These products and services may be used for both research and non-research purposes and allow us to supplement, at no cost, or a discounted cost, our own research and analysis activities. These products and services can include, but are not limited to: • Reports, publications and data on matters such as the economy, industries, sectors and individual companies or issuers, statistical information, account and law interpretations, political analyses, legal developments affecting portfolio securities, technical market actions, credit analyses, risk management and analyses of corporate responsibility issues. • Online news services and financial and market database services. • Information management systems integrating quotation and trading, performance management accounting, recordkeeping and document retrieval and other administrative matters. • Technology to help trade or help organize, document, and calculate the trades necessary to implement investment decisions. • Meetings, seminars, workshops and conferences with other IARs, issuers, program sponsors and/or other analysts and specialists. Research obtained with soft dollars is not necessarily utilized for the specific account that generated the soft dollars. PSCM or IARs do not attempt to allocate the relative costs or benefits of research among clients because we believe that, in the aggregate, the research we receive benefits all clients and assists us in fulfilling our overall duty to clients. These arrangements may be deemed to create a conflict of interest to the extent that we would have to pay for some or all the research and/or services with “hard dollars” if we were unable to obtain the research and services in exchange for discounts in connection with client transactions. Client trades are implemented based on the goals and objectives of the client and not on any research, products or other incentives available. Additionally, PSCM or IARS may receive marketing/servicing reimbursements from program sponsors and product issuers. The receipt of these reimbursements may be deemed to create a conflict of interest in that it creates a financial incentive for us to recommend these program sponsors and product issuers over others (such as where they are less expensive or have better performance) since these are expenses that we would otherwise be responsible for. Page 15 of 16  Order Aggregation Block trading is the process of adding together trade orders to purchase and sell the same security as one large order. IARs may aggregate orders in a block trade or trades when securities are purchased or sold through the same custodian for multiple accounts on the same trading day so that they can be executed at the same time for administrative convenience and to achieve lower overall execution costs typically associated with larger orders. Item 13. Review of Accounts Periodic Reviews Accounts are monitored on an ongoing basis by the client’s IAR. Accounts are reviewed at the firm-level on a regular and continuous basis by the Compliance Department. Formal firm-level reviews are performed at least annually and can be more frequent when market conditions dictate. Review Triggers Other conditions may trigger a review, including changes in regulations, including tax laws, new investment information, and changes in a client’s own situation. Regular Reports PSCM can provide quarterly reports to advisory households reflecting market values of the client’s account(s). The statements also detail the client's beginning and ending balances and any withdrawals or deposits during the period. PSCM provides these reports for illustrative purposes only. Clients should ultimately rely upon the statements provided by the custodian (where your assets are actually held) and use those statements to verify the information provided to you in the reports generated by PSCM. Item 14. Client Referrals and Other Compensation Incoming Referrals PSCM has been fortunate to receive many client referrals over the years. The referrals came from current clients, estate planning attorneys, accountants, employees, personal friends of employees and other similar sources. The firm does not compensate referring parties that are not registered with PSCM for these referrals. For information regarding our promoters, please refer to the section, “Promoter Arrangement”. Outgoing Referrals PSCM can, on occasion, recommend the services of other professionals (i.e. lawyers, accountants, insurance agents, etc.). However, any such professionals are engaged directly by the client on an as-needed basis. Conflicts of interest will be disclosed to the client in the unlikely event they should occur. PSCM does not accept referral fees or any form of remuneration from other professionals that are not registered with PSCM when a client is referred to them without being specifically registered as a promoter for that firm. For information regarding our promoters, please refer to the section, “Promoter Arrangement”. Page 16 of 17  Promoter Arrangement PSCM utilizes the services of promoters who are paid a percentage of advisory fees as compensation for referring clients to the firm. If the promoter is not an IAR or employee of PSCM, any such fee-sharing arrangements are fully disclosed to the client. The role of a promoter is different from that of an IAR and does not include providing investment and/or financial planning advice to clients. A promoter can also be a Registered Representative of an affiliated broker-dealer firm, but this does not mean or imply that said promoter is an IAR of PSCM. PSCM establishes relationships with a select group of third-party money managers (TPMMs), each of whom is required to pay us a portion of the advisory fee they charge to you. As a result, our IARs face a conflict of interest, as they are incentivized to recommend only those TPMMs that agree to provide compensation. Additionally, the advisory fee structures and actual rates charged to clients can differ between TPMMs recommended by an IAR. This creates an incentive for the IAR to recommend TPMMs offering higher compensation, whether due to elevated advisory fee rates or other factors. Given these potential conflicts of interest and the limited scope of these recommended services, we strongly encourage you to carefully review and compare the advisory fee rates and compensation terms associated with any TPMM recommended by an IAR. You are under no obligation to utilize a TPMM recommended by an IAR. Item 15. Custody Custody PSCM is deemed to have limited custody of client funds or securities when clients consent in advance to the direct debiting of their advisory fees from their account(s). PSCM is also deemed to have custody of client funds or securities if it has the authority to withdraw client assets maintained with a qualified custodian upon the advisor's instruction to the custodian when clients have utilized a standing letter of instruction or other similar asset transfer authorization arrangement (“SLOA”) established by the client and the qualified custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. Account Statements and Performance Reports All assets are held at qualified custodians, which means the custodians also send account statements directly to clients electronically or at their address of record at least quarterly. Clients who do not receive a statement from their qualified custodian at least quarterly should notify PSCM. Clients are urged to compare the account statements received directly from their custodians to the report statements provided by PSCM. PSCM provides reports for illustrative purposes only. Clients should ultimately rely upon the statements provided by the custodian and use those statements to verify the information provided to you in the reports generated by PSCM. Page 17 of 18  Item 16. Investment Discretion Discretionary Authority for Trading PSCM accepts discretionary authority to manage securities accounts on behalf of clients. PSCM has the authority to determine, without obtaining specific client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client approves the custodian to be used. PSCM does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades. Discretionary trading authority facilitates placing trades in a client’s accounts on their behalf so that IARs may promptly implement the client’s investment objectives. PSCM places trades for clients in accordance with its Investment Management Agreement. An Investment Management Agreement provides the trading authorization for this purpose. A client signs an Investment Management Agreement so that IARs may execute trades in pursuit of the investment objectives that the client has approved but the client always maintains asset control. Item 17. Voting Client Securities Proxy Votes PSCM does not vote proxies on securities. Clients are expected to vote their own proxies. You will receive proxies directly from the custodian firm. When assistance on voting proxies is requested, PSCM will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client. Item 18. Financial Information Financial Condition PSCM does not have any financial impairment that will preclude the firm from meeting contractual commitments to clients. A balance sheet is not required to be provided because PSCM does not serve as a custodian for client funds or securities due to taking the required steps to be in compliance with the Custody Rule criteria as outlined in the Securities and Exchange Commission’s ("SEC") No- Action Letter and does not require prepayment of fees of more than $1,200.00 per client, more than six months in advance. Business Continuity Plan PSCM has a detailed plan directing the steps our firm will take in response to unforeseeable disasters such as a fire, a natural disaster, or the loss of technical systems. If you would like a copy of the detailed plan, please contact us via email at info@perstirling.com or call us directly at (512) 628-2300 to request a copy. Page 18 of 19  Privacy Policy PSCM is committed to maintaining the confidentiality, integrity and security of the personal information that is entrusted to us. Investment Advisers are required by law to inform their clients of their policies regarding privacy of client information. We are bound by professional standards of confidentiality that are even more stringent than those required by law. Federal law gives the client the right to limit some but not all sharing of personal information. It also requires us to tell you how we collect, share, and protect your personal information. TYPES OF NONPUBLIC PERSONAL INFORMATION (NPI) WE COLLECT The categories of nonpublic information (NPI) that PSCM collects from you are in connection with establishing your account and providing investment advisory services. We collect nonpublic personal information about you that is either provided to us by you or obtained by us with your authorization. This can include but is not limited to your Social Security Number, Date of Birth, Banking Information, Financial Account Numbers and/or Balances, Sources of Income, and Credit Card Numbers or Information. When you are no longer our client, we may continue to share your information only as described in this notice. PARTIES TO WHOM WE DISCLOSE INFORMATION All Investment Advisers may need to share personal information to run their everyday business. In the section below, we list the reasons that we may share your personal information:  For everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus;  For our marketing – to offer our products and services to you;  For joint marketing with other financial companies;  For our affiliates’ everyday business purposes – information about your transactions and experiences and information about your creditworthiness; or  For affiliates and non-affiliates to market to you. If you are a new client we may begin sharing your information on the day you sign our agreement. When you are no longer our client, we may continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing. PROTECTING THE CONFIDENTIALITY OF CURRENT AND FORMER CLIENT’S INFORMATION To protect your personal information from unauthorized access and use, we use security measures that comply with federal law, including computer safeguards and secured files and building. FEDERAL LAW GIVES YOU THE RIGHT TO LIMIT SHARING – OPTING OUT Federal law allows you the right to limit the sharing of your NPI by “opting-out” of the following: sharing for affiliates’ everyday business purposes – information about your Page 19 of 20  creditworthiness; or sharing with affiliates or non-affiliates who use your information to market to you. State laws and individual companies may give you additional rights to limit sharing. Please notify us immediately if you choose to opt out of these types of sharing. Information about how PSCM collects, uses, stores, shares and protects your information in connection with services offered by PSCM as a data controller and/or processor including, but not limited to, services provided at or using the domain www.perstirling.com or tools or applications including, but not limited to, mobile and other software applications is accessible on our web site at https://perstirling.com/disclosures. DEFINITIONS: Affiliates – companies related by common ownership or control. They can be financial and non-financial companies; Non-affiliates – companies not related by common ownership or control. They can be financial and non-financial companies; Joint marketing – a formal agreement between non-affiliated financial companies that together market financial products or services to you. We are required by law to deliver our Privacy Policy to you at the beginning of your business relationship with PSCM and annually thereafter. Periodically we may revise this policy and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. Your privacy, our professional ethics, and the ability to provide you with quality financial services are very important to us. Please contact us via email at info@perstirling.com or call us directly at (512) 628-2300 if you have any questions. Page 20 of 20