PINNACLE HOLDINGS, LLC

Pinnacle Investment Advisors Brochure 3rd Quarter 2025 Quarter Ending September 30, 2025 1616 E. 15th St. Tulsa, Oklahoma 74120 (918) 582‐6864 www.PinnacleHoldings.net This brochure provides information about the quali(cid:976)ications and business practices of Pinnacle Investment Advisors. If you have any questions about the contents of this brochure, please contact us. The information in this brochure has not been approved or veri(cid:976)ied by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Pinnacle Investment Advisors is available on the SEC’s website at www.adviserinfo.sec.gov.  Pinnacle Investment Advisors Section I. Material Changes pg. 3 Section II. Investment Strategy pg. 4 Section III. Portfolio Strategies pg. 6 Section IV. Financial Planning Services pg. 15 Section V. Investment Consulting and External Manager Selection pg. 16 Section VI. Communication With Clients pg. 17 Section VII. Business Principles pg. 18 Section VIII. Composite Disclosure and Fee Schedule pg. 19 Section IX. Potential Con(cid:976)licts of Interest pg. 24 Page 2 Section X. Brochure Supplement—Personal Pro(cid:976)iles pg. 27  Pinnacle Investment Advisors Material Changes - since last annual update to the brochure produced December 31, 2024.  Mr. Ben McNulty resigned from the (cid:976)irm in September 2025. We recommend that you examine your potential investment advisor’s history on the SEC’s website: www.adviserinfo.sec.gov Page 3  Pinnacle Investment Advisors P innacle Investment Advisors was established in 1996 as a fee based money management (cid:976)irm, registered with the United States Securities and Exchange Commission, offering bond and equity portfolio manage- ment for individuals, foundations, corporations, trusts, pension and pro(cid:976)it sharing plans, and other business enti- ties. The (cid:976)irm also offers (cid:976)inancial analysis on a consulting basis for bank investment portfolios, corporate cash management, municipal debt defeasance, and liability hedging programs. We have a $250,000 minimum for our managed accounts, exceptions to this requirement are made on an individual basis. One principle pervades all our investment strategies: minimizing risk for a desired rate of return. The (cid:976)irm has seven speci(cid:976)ic investment strategies designed to bene(cid:976)it from distinct risk and return parameters. Each strategy is customized based on the client’s unique risk pro(cid:976)ile. First, we explain the risks involved in each strategy in terms of volatility, liquidity, and cash (cid:976)lows. Then we evaluate the client’s investment objectives, time horizon, income needs, and (cid:976)inancial situation. Finally, once an appropriate asset allocation is decided upon, we will man- age the client’s portfolio subject to their risk tolerance, the investment strategies selected, and any additional re- quests made by the client. Each of our investment strategies captures different risk/reward characteristics in the stock or bond markets. The risk of investing in stocks versus bonds is one of volatility in returns. Stock prices vary more than bond pric- es. It is extremely rare for the bond market to have negative returns for a year, but the stock market produces negative annual returns on a regular basis. Among our strategies, the Intermediate Bond Portfolio and the Inter- mediate Tax Exempt Portfolio focus on stability in returns. However, as one would expect, with greater risk of loss, comes greater potential returns. Historically, a diversi(cid:976)ied portfolio of large capitalization stocks has outper- formed a high grade bond portfolio, and both stocks and bonds have outperformed cash and in(cid:976)lation. The volatil- ity in historical returns, one measure of risk, is reduced for longer holding periods. If an investor is uncomforta- ble with the volatility of stock prices and returns, then the investor should consider (cid:976)ixed income investments where there is more security in returns. But for those investors who are comfortable with the risk of equities, because they can accept the argument that a long time horizon signi(cid:976)icantly increases the probability that they will achieve returns close to the long term historical average, the Blue Chip Strategy and the Small Cap Value Strategy are ideal. Our business principle of reducing risk for a given level of expected return guides all our investment strategies. The bond portfolio strategies limit risk as much as possible while providing competitive yields and total returns. Our bond strategies consider: 1) safety of principal, your investment in a bond; 2) liquidity, the minimization of transaction costs; and 3) total return, the cumulative price volatility and interest characteristics of a bond. Our stock portfolio strategies are based on proven methods for achieving returns consistent with a value strategy that has outperformed the broad market, historically. The large capitalization stock portfolio strategy seeks to match the broad market, while at the same time reducing portfolio expenses as much as possible. The small capitaliza- tion stock portfolio uses exhaustive methodology to reduce the risk of owning small cap stocks while simultane- ously providing the higher returns of small cap stocks. By applying our quantitative analytical approach to man- aging risk, the client’s potential for greater returns is enhanced. Page 4  Pinnacle Investment Advisors There are two features of our business approach which provide bene(cid:976)its to all our investment strategies. First, our low compensation costs are calculated as one-half percent (0.50% or (cid:976)ifty basis points) annually on the port- folio value for each of our strategies except the Small Cap Value Strategy which has an annual fee of one percent (1.00%) and our Convertible Securities Strategy which has a fee of three quarters of one percent (0.75%). Our fees are deducted in arrears and are calculated as a percentage of the market value of assets in the portfolio on the last day of the quarter. For example, under our Blue Chip strategy the management fee breaks down to 0.125% of the market value per quarter. We charge these fees on assets included in our strategies, for which we have authority and discretion to execute transactions in client accounts through a limited power of attorney. We may also charge fees on assets that are not part of our investment strategies, at rates to be negotiated with the client. Our incentive is in your best interest. As a fee-based money manager, we bene(cid:976)it only from increasing the total value of your portfolio. Second, we continuously seek to lower portfolio expenses. This gives our clients a greater probability of achiev- ing their investment goals. One way we reduce portfolio expenses is through very low turnover of investment positions. This is especially important for accounts subject to capital gains taxes because low portfolio turnover keeps you from suffering con(cid:976)iscatory tax rates on short term and long term gains. Allowing those gains to com- pound by earning gains on the increased portfolio value is a potent force in investing. Further, in order to provide the best service possible and to minimize your total portfolio expenses, we work with select brokers in the custo- dy and the execution of transactions. By working with these brokers, we are able to maintain greater control over the commission rates paid and we continuously seek to negotiate lower commission rates and transaction costs, especially through the use of block trades. Additional brokerage information is discussed in Section VII. Fee rates will be negotiable from time to time at our discretion and will be charged on the calendar quarter end for the prior quarter. If a client decides to terminate management of their portfolio prior to quarter end, fees ac- crued up to the termination date will be assessed based on the market value of the portfolio on termination date. A client may terminate their investment management contract at any time with written noti(cid:976)ication. For some client accounts for which mutual funds or exchange traded funds are recommended, the client may be charged management fees by the (cid:976)irm in addition to the management fee portion of the expense ratio of the mutual fund or ETF. Pinnacle provides consultation and employee education services for 401(k) plans and can provide asset alloca- tion analysis, portfolio analysis, and security analysis services for an hourly rate of $250.00. On December 31, 2024, the (cid:976)irm managed $444,271,972 on a discretionary basis and $10,899,660 for which we did not have full decision-making authority. Page 5  Pinnacle Investment Advisors P innacle Investment Advisors offers seven investment strategies to capture different market advantages. The composition of a portfolio amongst our strategies is based on the individual, their speci(cid:976)ic investment needs, (cid:976)inancial goals, and risk tolerance. »  The Short Term Bond Portfolio emphasizes liquidity and safety with very high quality securities with maturities less than one year. »  The Intermediate Bond Portfolio emphasizes total return with high quality securities. »  The Intermediate Tax Exempt Bond Portfolio obtains a high level of income that is exempt from regular federal income tax available from municipal bonds. »  The Convertible Securities/High Yield Strategy seeks to provide high total return from income producing securities with the potential for capital appreciation. »  The Blue Chip Strategy seeks to provide performance similar to the Dow Jones Industrial Average. »  The Small Cap Value Strategy invests in companies that are considered undervalued on an objective basis using price/earnings multiples, book value, and cash (cid:976)low measures. »  The Midstream Energy Strategy seeks to provide high levels of tax sheltered income and the potential for capital appreciation through investing in publicly traded master limited partnerships and pipeline companies. Each of the list above comprise the proprietary portfolio strategies offered by Pinnacle Investment Advisors. The strategies can be blended to construct a balanced portfolio to meet the individual client’s investment objectives. The majority of the (cid:976)irm’s clients invest in more than one of the (cid:976)irm’s portfolio strategies for diversi(cid:976)ication purposes and to meet their income and growth goals. Pinnacle’s performance disclosure statement is included with this material and available online. The (cid:976)irm will have full discretion to implement these strategies once the client’s asset allocation guidelines are agreed upon when the investment management relationship is established. The client may limit the (cid:976)irm’s use of speci(cid:976)ic securities or sectors based on their individual circumstances and objectives. Page 6  Pinnacle Investment Advisors The (cid:976)irm manages each asset class strategy internally. The Chief Investment Of(cid:976)icer oversees the research efforts, security analysis, and portfolio construction performed by the investment team which includes the equity trader, (cid:976)ixed income analyst and trader, and the Managing Partner. The (cid:976)irm has investment policies for each asset class that de(cid:976)ine the eligible securities for the asset class. The team seeks to identify potential portfolio positions by performing research on an ongoing basis and reviewing reports from sell side analysts and other outside sources. The (cid:976)ixed income analyst and trader is responsible for selecting potential positions for the Short Term Bond Portfolio, Intermediate Bond Portfolio and Intermediate Tax Exempt Bond Portfolio after consultation with the investment team. The Chief Investment Of(cid:976)icer and the investment team will determine the appropriate target duration and credit risk that is appropriate for the current economic environment. Within the investment policy guidelines and investment team recommended duration and credit quality, the (cid:976)ixed income analyst will seek offerings from his network of (cid:976)ixed income dealers through various forms of communication to achieve low cost execution of transactions. The Chief Investment Of(cid:976)icer manages the Small Cap Value Strategy and the Midstream Energy Strategy. The investment team generates ideas for potential positions for each strategy, which the CIO then researches, analyzes, and evaluates. Some candidates are added to the watchlist for the strategy and may be purchased for the portfolio when the CIO deems them eligible. The CIO instructs the equity trader when to purchase positions for the Small Cap Value Strategy and the Midstream Energy Strategy within certain parameters. The equity trader follows the (cid:976)irm’s trade execution policies to (cid:976)ill the positions for each client in the strategy. Management of the Convertible Securities/High Yield Strategy will be overseen by the Chief Investment Of(cid:976)icer in consultation with the Fixed Income Analyst and Trader and subject to the (cid:976)irm’s Investment Policy that limits position concentration, credit quality, and average maturity. The intent of the strategy is to provide performance consistent with the high yield (cid:976)ixed income sector with potential for greater appreciation due to the imbedded conversion option. The Chief Investment Of(cid:976)icer and the Fixed Income Analyst and Trader will jointly manage the strategy with input from the investment team. They will conduct fundamental analysis of the issuer’s underlying equity and credit quality prior or making a decision regarding a speci(cid:976)ic security for the portfolio. The (cid:976)irm seeks to minimize portfolio management costs using individual securities. By eliminating the costs of mutual funds or exchange traded funds, the (cid:976)irm reduces the ongoing expense of investing in securities. The risk of using individual securities in client portfolios is the potential for an individual security to substantially decline in value. Active management of equity portfolios typically incurs higher management fees than passive index funds. The (cid:976)irm relies on a small staff to oversee the management of the securities portfolios. Page 7  Document Title Document Title Document Title Document Title Pinnacle Investment Advisors Advantages: 1. Competitive Returns - relative to similar short-term investments 2. Safety - U.S. Government and Agency guaranteed securities 3. Quantitative Analysis - less price volatility and high credit quality translate into greater liquidity 4. Low Cost - management fees are lower than the average short-term bond mutual fund Investment Goal: The primary goal of Pinnacle’s Short Term Bond Portfolio is safety of principal with competitive returns as a secondary objective. The Portfolio invests in bonds backed by the Full Faith and Credit of the U.S. Government and its Agencies with a two-year maturity limit. Investor Pro(cid:976)ile: For the investor whose overriding objective is to preserve capital, Pinnacle’s Short Term Bond Portfolio offers the safety and credit quality of the U.S. Government in addition to the low price volatility of short-term bonds. The Portfolio has more price risk than a money market fund but the (cid:976)luctuation in the value of the Portfolio is expected to be very low when compared to long term bonds and stocks. Portfolio Strategy: Pinnacle’s Short Term Bond Portfolio invests in securities with a direct guarantee of the payment of principal and interest by the Federal Government of the United States and its Agencies. These securities are deemed to be the safest quality bonds available. The portfolio managers seek to provide competitive rates of return through management of the average maturity of the Portfolio between a range of one and two years. Management Fee: 0.25% (one-quarter percent) annually of the market value of assets in the portfolio. The average short-term bond mutual fund expense ratio is 0.71%. Current Yield: The portfolio currently yields over 4.50% during the fourth quarter of 2024. NOTES: * Returns for periods shorter than one year are not annualized, all other values shown are annualized  ** Past performance is no guarantee of future results. Please see our performance disclosure statement for more information. *** For comparison purposes, the composite is measured against US Govt. 1-3Yr. Index and 3 Month Treasury Index. Page 8 Page 8 Page 8 Page 8 Page 8  Document Title Document Title Document Title Document Title Pinnacle Investment Advisors Advantages: 1. Competitive Returns - relative to similar intermediate term in- vestments 2. Safety - core holdings in U.S. Government securities and high- grade corporate bonds 3. Liquidity - less price volatility and high credit quality translate into greater liquidity 4. Low Cost - management fees are lower than the average inter- mediate bond mutual fund Growth of $10,000 investment (gross of fees) since inception, June, 1995. Portfolio* (Period Ending 12/31/2024) Gross of Fees Net of Fees 1 Year 4.53% 4.03% 3 Years 2.40% 1.94% 5 Years 2.58% 2.14% 10 Years 2.52% 2.09% Inception 4.37% 4.00% US Govt/Credit Index 1-10 Yrs.** 3.21% -0.14% 0.87% 1.75% 4.06% Investment Goal: Pinnacle’s Intermediate Bond Portfolio seeks higher yields and total returns than are available with short-term bonds. The Portfolio invests in investment grade corporate bonds in addition to a core holding of bonds issued by the U.S. Treasury or Federal Agencies. Investor Pro(cid:976)ile: The Intermediate Bond Portfolio is for the investor who is looking for greater taxable income from a bond portfolio without taking the risk of low credit quality “junk bonds” or the price volatility risk of long-term bonds. The Portfolio has more price risk than a short-term bond portfolio but the (cid:976)luctuation in the value of the Portfolio is expected to be lower than long-term bonds and stocks. Portfolio Strategy: Pinnacle’s Intermediate Bond Portfolio invests in securities that are issued by the U.S. Government and its Agencies. These securities have the highest rating of bonds available in the market. Also, the portfolio managers seek to enhance the Portfolio’s return through the purchase of investment grade corporate bonds that offer yield advantages over government bonds. The average maturity of Pinnacle’s Intermediate Bond Portfolio is typically between 3-7 years. Management Fee: 0.50% (one-half percent) annually of the market value of assets in the portfolio. The average corporate bond mutual fund expense ratio is 0.73%. NOTES: Page 9 Page 9 Page 9 Page 9 Page 9 * Past performance is no guarantee of future results. Please see our performance disclosure statement for more information. **For comparison purposes, the composite is measured against US Govt/Credit Index 1-10 Yr. The index consists of investment grade corporate bonds, U.S. Treasury and Federal Agency bonds with maturities ranging from 1-10 years publicly traded in the United States .    Document Title Document Title Document Title Document Title Pinnacle Investment Advisors Advantages: 1. Competitive Returns - relative to similar intermedi- ate term investments 2. Safety - highest quality municipal bonds 3. Liquidity - less price vol- atility and high credit quality translate into greater liquidi- ty 4. Low Cost - management fees are lower than the aver- Growth of $10,000 investment (gross and net of fees) since inception in March 1996. Portfolio* (Period Ending 12/31/2024) 1 Year 3 Years 5Years 10 Years Inception Gross of Fees 1.94% 1.63% 1.66% 1.73% 3.14% Net of Fees 1.60% 1.28% 1.32% 1.33% 2.71% BofA ML 3-7 Muni Index** 1.58% 0.08% 1.21% 2.00% 3.71% Investment Goal: Pinnacle’s Intermediate Tax Exempt Bond Portfolio seeks a high level of income that is exempt from regular federal income tax available from municipal bonds. The Portfolio invests in high quality investment grade municipal bonds. Investor Pro(cid:976)ile: The Intermediate Tax Exempt Bond Portfolio is for the investor who is looking for greater after-tax income than is available from taxable bonds. In addition, the Portfolio will seek to purchase bonds that are exempt from state income taxes depending on the investor’s state income tax rate. The Portfolio has less price risk than municipal bond funds that invest in long-term bonds. Portfolio Strategy: Pinnacle’s Intermediate Tax Exempt Bond Portfolio invests in investment grade municipal bonds. The portfolio manager will purchase bonds that pass a stringent test for credit quality. High after-tax total return will be the objective of Pinnacle’s Intermediate Tax Exempt Bond Portfolio given an average maturity typically between three and ten years. Management Fee: 0.50% (one-half percent) annually of the market value of assets in the portfolio. The average municipal bond mutual fund expense ratio is 0.66%. Page 10 Page 10 Page 10 Page 10 Page 10 NOTES: * Past performance is no guarantee of future results. Please see our performance disclosure statement for more information. ** For comparison purposes, the composite is measured against Merrill Lynch 3-7 Yr. Insured Muni Index. The index consists of municipal bonds with a maturity ranging from 3-7 years traded in the U.S. dollar-denominated investment grade sold into the U.S. market and publicly traded in the United States .  Document Title Document Title Document Title Document Title Pinnacle Investment Advisors Advantages: 1. Competitive Returns - relative to similar convertible and high yield investments. 2. Safety - The de(cid:976)ined maturity of convertible bonds and the seniority of asset claims of bonds and pre- ferred stocks make them less sub- ject to loss of principal than com- mon stocks. 3. Quantitative Analysis - a funda- mental approach to lowering risk by calculating risk versus reward is used to select issues for the strategy. 4. Low Cost - management fees are lower than the average convertible Growth of $10,000 investment (gross of fees) since inception, May 1997. Portfolio* (Period Ending 12/31/2024) 1 Year 3 Years 5 Years 10 Years Inception Gross of Fees Net of Fees Merrill Lynch Convertibles** Merrill Lynch High Yield** 9.37% 8.87% 10.73% 8.04% 2.18% 1.76% 0.43% 2.89% 4.11% 3.68% 9.57% 4.02% 3.66% 3.24% 9.57% 5.07% 6.33% 5.83% 8.62% 6.43% Investment Goal: Pinnacle’s Convertible/High Yield Portfolio seeks to provide high total returns from income producing securities with the potential for capital appreciation. The Strategy invests in convertible corporate bonds and convertible preferred stocks of publicly traded companies. Convertible securities typically pay higher interest or dividends than common stocks and are exchangeable into the common stock of the issuing company. If the price of the common stock rises, the convertible security will increase in value also. If the price of the common stock falls, the convertible investor receives the higher income of a bond or preferred stock. Investor Pro(cid:976)ile: The Convertible/High Yield Portfolio is for the investor who desires high levels of income from their portfolio with the added potential for capital appreciation. Convertible securities, as an asset class, display more risk than bonds yet less risk than stocks. The returns associated with convertible securities, when adjusted for risk (as measured by price volatility) were higher than large capitalization stocks during the past (cid:976)ifteen years. Portfolio Strategy: Pinnacle’s Convertible/High Yield Strategy invests in a diversi(cid:976)ied portfolio of convertible securities. The portfolio manager seeks companies that are trading at a discount to book value, a low price to earnings multiple, or a low price ratio to projected cash (cid:976)low. This approach lowers the risk of a diversi(cid:976)ied portfolio while retaining the potential high returns of the underlying equities. Page 11 Page 11 Page 11 Page 11 Management Fee: 0.75% (three-quarters of one percent) annually of the market value of assets in the portfolio. The average convertible securities mutual fund expense ratio is 0.94% . NOTES: * Past performance is no guarantee of future results. Please see our performance disclosure statement for more information. ** For comparison purposes, the composite is measured against BofA Merrill Lynch Convertibles Index. The index consists of convertible bonds traded in the U.S. dollar-denominated investment grade and noninvestment grade convertible securities sold into the U.S. market and publicly traded in the United States. The Index constituents are market value weighted based on the convertible securities prices and outstanding shares, and the underlying index is rebalanced daily. For an additional comparison, the composite is measured against BofA Merrill Lynch U.S. High Yield Index. The index tracks the performance of below-investment- grade U.S. dollar-denominated corporate bonds publicly issued in the U.S. domestic market.  Document Title Document Title Document Title Document Title Pinnacle Investment Advisors Advantages: 1. Competitive Returns - the Dow has outperformed the S&P 500 by approximately 0.50% annually in the last (cid:976)ifteen years 2. Safety - diversi(cid:976)ied portfolio of the dominant companies in their respective industries 3. Global Exposure - these Blue Chips receive roughly 40% of their revenues from foreign oper- ations lower 4. Low Cost - management fees are the average than growth and income mutual fund. Growth of $10,000 investment (gross of fees) since inception, January 1997. Portfolio* (Period Ending 12/31/2024) Gross of Fees Net of Fees Standard & Poor's 500 Index** 1 Year 14.90% 14.44% 24.98% 3 Year 7.52% 7.11% 8.91% 5 Years 10.82% 10.39% 14.50% 10 Years 11.65% 11.23% 13.08% Inception 9.47% 9.02% 9.44% Investment Goal: Pinnacle’s Blue Chip Portfolio seeks to provide performance similar to the Dow Jones Industrials. The Dow has consistently produced the best returns among major market indices. This strategy has very low turnover and low transaction costs. Investor Pro(cid:976)ile: The Blue Chip Portfolio is for the investor that is seeking returns consistent with the long-term historical average of large capitalization stocks. This passively managed strategy should provide higher after tax returns than an actively managed growth and income fund due to low turnover and low transaction costs. Portfolio Strategy: Pinnacle’s Blue Chip Portfolio is structured to provide performance similar to the Dow Industrials. It is a passively managed strategy in which turnover is expected to average less than 10% annually. The low turnover allows capital gains to compound for a longer time period, resulting in higher after tax returns. Management Fee: 0.50% (one-half percent) annually of the market value of assets in the portfolio. The average growth and income mutual fund expense ratio is 1.22%. Page 12 Page 12 Page 12 Page 12 Page 12 NOTES: * Past performance is no guarantee of future results. Please see our performance disclosure statement for more information. ** For comparison purposes, the composite is measured against the S&P 500 Index, an unmanaged capitalization-weighted index of 500 stocks designated to measure the performance of the broad domestic economy through changes in the aggregate market value of 500 stocks representing all major industries.  Document Title Document Title Document Title Document Title Pinnacle Investment Advisors Advantages: 1. Competitive Returns - relative to similar small cap investments 2. Safety - portfolio diversi(cid:976)ication and a value approach lower the risk of small company stocks 3. Quantitative Analysis - a funda- mental approach to lowering risk by calculating risk versus reward 4. Low Cost - management fees are lower than the average small cap mutual fund Growth of $10,000 investment (gross of fees) since inception, December 1994. Portfolio* (Period Ending 12/31/2024) 1 Year 3 Years 5 Years 10 Years Inception Gross of Fees 6.17% 7.79% 14.22% 8.34% 9.67% Net of Fees 5.71% 7.36% 13.77% 7.87% 9.20% S&P Small Cap 600** 6.82% 0.15% 6.64% 7.32% 9.53% Investment Goal: Pinnacle’s Small Cap Value Portfolio seeks to provide returns consistent with the long-term historical average of small company stocks. Since 1926, small company stocks have outperformed large company stocks by approximately 2.0%. Investor Pro(cid:976)ile: The Small Cap Value Portfolio is for the investor who understands the relationship between risk and reward. Small company stocks as an asset class have more risk than large company stocks. However, this higher risk has produced higher long-term returns. Portfolio Strategy: Pinnacle’s Small Cap Value Portfolio invests in a diversi(cid:976)ied portfolio of small company stocks. The portfolio manager seeks companies that are trading at a discount to book value, a low price to earnings multiple, or a low ratio to projected cash (cid:976)low. This approach lowers the risk of a diversi(cid:976)ied portfolio while retaining the potential high returns of small company stocks. Management Fee: 1.00% (one percent) annually of the market value of assets in the portfolio. The average small cap stock mutual fund expense ratio is 1.10%. Page 13 Page 13 Page 13 Page 13 Page 13 NOTES:  * Past performance is no guarantee of future results. Please see our performance disclosure statement for more information. ** For comparison purposes, the composite is measured against the S&P Small Cap 600 Index, it measures the performance of the small-cap segment of the U.S. equity universe. The Index is constructed to provide a comprehensive and unbiased small-cap barometer and is completely reconstituted annually to ensure larger stocks do not distort the performance and characteristics of the true small-cap opportunity set.  Document Title Document Title Document Title Document Title Pinnacle Investment Advisors Advantages: 1. Competitive Returns - the sec- tor has produced annualized re- turns exceeding 10% 2. Income - high distribution yields relative to common stocks offer protection against market downturns, i.e. lower volatility 3. Diversi(cid:980)ication ‐ the Midstream sector does not closely correlate with other asset classes Growth of $10,000 investment (gross of fees) since inception, January 2001. Portfolio* (Period Ending 12/31/2024) Gross of Fees Net of Fees 1 Year 37.60% 37.01% 3 Year 26.28% 25.70% 5 Year 16.94% 16.43% 10 Year 4.76% 4.34% Inception 12.66% 12.09% Alerian MLP Index** Alerian Midstream Energy Index** 24.41% 44.53% 27.27% 26.05% 15.56% 16.27% 3.67% 6.47% 10.92% NA Investment Goal: Pinnacle’s Midstream Energy Strategy seeks to provide high levels of tax sheltered income and the potential for capital appreciation through investing in publicly traded master limited partnerships and pipeline companies. Investor Pro(cid:976)ile: The Midstream Energy Strategy is for the investor who desires high levels of income from their portfolio with the added potential for capital appreciation, while accepting the increased income tax preparation activities from partnership tax reporting. Midstream Energy and Master Limited Partnerships (MLPs): Master Limited Partnerships are similar in structure to traditional limited partnerships. The primary difference is that MLPs qualify to trade on public stock exchanges or over-the-counter. For tax purposes, MLPs are considered by the IRS to be pass-through entities so their operating results are passed through to the limited partners, called unit holders. The Revenue Act of 1987 required publicly traded MLPs to receive at least 90% of their income from specific sources, particularly mineral or natural resource activities including exploration, development, production, mining, refining, marketing, and transportation of oil, gas, minerals, geothermal energy, or timber. Recently, some MLPs have converted to corporations. Most midstream companies generate stable cash flows from operations which lead to a relatively stable distributions and dividends. They are involved in businesses that are considered mature with moderate growth prospects and substantial cash flow generation. The majority of MLPs do not take commodity price risk but act as transporters or distributors and take a fee for service, similar to a utility. Some of the more aggressively managed midstream companies have used their cost of capital advantage to make numerous acquisitions that are financed through debt and issuance of new equity. This strategy has led to significant increases in distributable cash flow and price appreciation for “growth MLPs” employing this strategy. Portfolio Strategy: Pinnacle’s Midstream Energy Strategy invests in MLPs and corporations that have the ability to increase their distributions/dividends on a consistent basis. “Growth” MLPs offer the best potential for capital appreciation and protection against rising interest rates. The strategy holds positions in various types of MLPs in order to diversify its asset base and midstream companies that pay tax- advantaged dividends. Management Fee: 0.75% (three-quarters of one percent) annually of the market value of assets in the portfolio. The average MLP stock mutual fund expense ratio is 1.53% Page 14 Page 14 Page 14 Page 14 NOTES:  * Past performance is no guarantee of future results. Please see our performance disclosure statement for more information. ** For comparison purposes, the composite is measured against Alerian MLP Index. This index provides a comprehensive benchmark for investors to track the performance of the energy MLP sector. The majority of MLPs currently operate in the energy infrastructure industry, owning assets such as pipelines that transport crude oil, natural gas, and other re(cid:976)ined petroleum products.  Pinnacle Investment Advisors I n addition to securities portfolio management, Pinnacle Investment Advisors offers comprehensive (cid:976)inancial planning services to our clients. Financial planning can help to achieve both greater wealth and (cid:976)inancial security. Inadequate or improper planning can be (cid:976)inancially disastrous. An uninsured loss can wipe out accumulated wealth; insuf(cid:976)icient savings for retirement can force a reduced lifestyle and/or postponement of retirement; and improper tax planning can result in higher than necessary taxes. A true (cid:976)inancial plan does not focus on one aspect or product, but instead seeks to take all areas of planning into consideration when making (cid:976)inancial decisions. They include:  Tax Planning and Management - This area focuses on the understanding of and application of federal and state income tax law, estate and inheritance taxes; and, when possible, minimizing these taxes.  Cash Flow Management - This aspect of planning deals with the day to day sources of income; and its effective use in paying current living expenses and in accumulating assets which will be used in meeting (cid:976)inancial goals.  Retirement Planning and Management: Financial Independence - By far the most common accumulation goal is the ability to become (cid:976)inancially independent. Retirement strategies encompass the understanding of the Social Security system; employer- sponsored retirement plans, IRA’s; and personal savings accumulation plans.  Investment Planning and Management - Almost everyone has accumulation goals for which investments must be made and managed. These could include buying a home; planning for college; or providing for retirement.  Estate Planning and Management - The (cid:976)inal phase of planning is for the transfer of assets to our heirs with minimization of taxes and other costs.  Risk Planning and Management - This area of planning deals with the risk of losing life, income, or property. It includes the use of insurance products and strategies.  Education Planning - This area of planning deals with capital needs and cash (cid:976)low management to direct capital in the most ef(cid:976)icient manner to meet the goals. Pinnacle Investment Advisors is a fee-only comprehensive (cid:976)inancial planning (cid:976)irm. We do not receive any compensation from commissions, reimbursed cost, or referral fees. Page 15  Document Title Document Title Document Title Document Title Pinnacle Investment Advisors Oak Creek Private Wealth Management (OCPWM) provides investment consulting and portfolio management services to help clients meet their investment objectives. Oak Creek works with the client to create an Investment Policy Statement which outlines the client’s current situation (income, tax levels, and risk tolerance). Portfolio management services include the following: Investment Strategy Asset Allocation Risk Tolerance     Personal Investment Policy  Asset Selection  Regular Portfolio Monitoring OCPWM evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. OCPWM will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. OCPWM seeks to provide that investment decisions are made in accordance with the (cid:976)iduciary duties owed to its accounts and without consideration of OCPWM’s economic, investment or other (cid:976)inancial interests. To meet its (cid:976)iduciary obligations, OCPWM attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, OCPWM’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is OCPWM’s policy to allocate investment opportunities and transactions it identi(cid:976)ies as being appropriate and prudent among its clients on a fair and equitable basis over time. Selection of Other Advisers OCPWM will direct clients to third-party investment managers. Before selecting other managers for clients, OCPWM will verify that all recommended managers are properly licensed, notice (cid:976)iled, or exempt in the states where OCPWM is recommending the manager to clients. OCPWM will speci(cid:976)ically direct clients to Envestnet Asset Management (Envestnet) CRD #111694. In general, Envestnet offers its services to OCPWM as sub-advisory services to be performed on Client’s account at the direction of OCPWM, and in certain limited instances, Envestnet works directly with the Client. In addition to the Envestnet sub- advisory services offered in the Programs, Envestnet also offers OCPWM many advisory service tools, whereby Envestnet provides only administrative and technology services and investment research and due diligence. OCPWM determines which services and Programs of Envestnet to utilize with its Clients and may utilize the services of other third- party services providers in conjunction with the Programs. Pension Consulting Services Oak Creek offers consulting services to pension or other employee bene(cid:976)it plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to:  Identifying investment objectives and restrictions  Providing guidance on various asset classes and investment options  Recommending money managers to manage plan assets in strategies designed to achieve investment objectives Management Fee: Fees are based on the size of the client’s portfolio, beginning at 1.0% annually of the market value of assets in the portfolio, declining to 0.40% (forty basis points) for larger portfolios. Page 16 Page 16 Page 16 Page 16  Pinnacle Investment Advisors information needs of our clients on a timely basis. We understand the necessity of P innacle Investment Advisors has the (cid:976)lexibility and experience to meet the maintaining open lines of communication with our clients at all times. Pinnacle offers a wide range of information to the client. The (cid:976)irm’s Black Diamond online portfolio management program is considered to be one of the best systems available to investment advisors. Our portfolio managers can customize a report for the client’s speci(cid:976)ic requirements or the client can choose from some of the following reports:  Unrealized Gains and Losses  Fixed Income Portfolio  Realized Gains and Losses Income and Expenses   Performance by Asset Class  Purchases and Sales  1099 Report  Performance By Asset Class (Time Weighted for Index Comparison)  Fixed Income Holdings Our goal is to provide the level of information necessary for the client to be comfortable with their portfolio management. The client will receive monthly statements from the custodian detailing portfolio positions, transaction summary, market value, and income and expenses. Pinnacle Investment Advisors provides written performance reports and market value summaries on a quarterly basis. If additional reports are necessary, the (cid:976)irm will provide them on a periodic basis as required by the client. All client accounts are reviewed on a quarterly basis by the managing partner. Account transactions are reviewed on a daily basis by the Portfolio Manager performing trade reconciliations. Any signi(cid:976)icant cash deposits (in excess of 5%), will trigger an account review. Any settlement problem will also incur an account review. Page 17  Pinnacle Investment Advisors management services and (cid:976)inancial analysis for our clients. The idea of relative val- P innacle Investment Advisors was established to provide competitive investment ue, the objective comparison of risk and return, guides both our approach to service and our investment decisions. Our investment philosophy is driven by the principle of mini- mizing risk while capturing the most competitive rates of return. Service Priorities  Provide competitive rates of return on a consistent, long term basis  Design unique investment strategies  Tailor each portfolio to the individual client’s objectives  Explore new (cid:976)inancial products  Communicate ef(cid:976)iciently and effectively with our clients  Link our incentive to the client’s best interest  Contribute to our community as the (cid:976)irm grows At Pinnacle Investment Advisors, we believe that relative value in (cid:976)inancial markets is bet- ter understood and attained through objective methods. We do not rely on our “market instincts” to guide investment decisions. Rather, we calculate risk versus reward through solid quantitative analysis of fundamental (cid:976)inancial ratios. Our competitive advantage lies in the experienced analytical abilities of our portfolio managers, grounded in their strong (cid:976)inancial and accounting backgrounds. At Pinnacle, superior investment performance is achieved by using this investment expertise to determine when to buy and when to sell, based on objective calculations of relative value. Page 18  Pinnacle Investment Advisors Pinnacle Investment Advisors Composite Disclosure Statement A complete list of (cid:976)irm composites, performance results, and investment policies is available upon request. Returns are denominated in U.S. dollars and in- clude domestic accounts only. Returns include reinvestment of dividends, interest, and other earnings, and include portfolio balances in cash and cash equiv- alents. Returns shown are gross of fees and after all trading expenses, calculated on a monthly basis using trade date reporting. Past performance is no guar- antee of future results. Returns prior to December 31, 2009 have not been veri(cid:976)ied by a third party. Performance from June 30, 1995 to March 31, 1996 is the same client’s portfolio from a prior (cid:976)irm continuously managed by the same management team. All other composites have been managed since inception by the same team at Pin- nacle Investment Advisors. Composites include fully discretionary separate accounts only. Each composite includes accounts that use that particular asset class strategy either solely or as part of a balanced portfolio approach.. Accounts are added to the composites at the end of the (cid:976)irst month under manage- ment. Terminated accounts are included in the composite. Returns are asset weighted. Non-discretionary accounts are de(cid:976)ined as accounts where client restrictions impede the full implementation of a particular asset class strategy. Non-discretionary accounts are not included in the following composites. Tax Exempt Bond Portfolio Composite (Inception and Creation Date: March 1996) Accounts Year Dispersion BofA/Merrill 3-7 3 Yr Std Dev (%) Firm Assets ($M) Assets ($M) Return (Gross) BofA/Merrill 3-7 Yr. Muni Index Composite 3 Yr Std Dev (%) 444 403 364 388 302 447 441 536 560 530 608 694 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 1.94 4.18 -1.16 1.24 2.18 3.05 1.60 1.81 0.77 1.82 3.54 0.17 1.58 4.56 -5.62 1.38 4.50 6.03 2.23 3.08 0.53 2.25 3.17 0.92 28 31 34 39 42 43 51 52 50 54 53 71 11.95 12.32 11.54 10.45 13.32 19.70 20.13 19.68 21.76 23.80 24.64 26.28 2.42-1.20 8.08-2.01 1.24-(3.13) 2.51-0.32 3.53-(1.09) 4.23-(-0.85) 2.97-(1.27) 5.11-0.47 4.35-(1.07) 2.53-0.64 6.25-0.80 1.95-(3.27) 2.19 2.18 1.72 0.74 1.56 1.48 1.55 1.43 1.51 1.74 1.96 2.17 4.27 4.25 4.92 1.93 1.98 2.01 2.03 2.08 1.91 1.61 1.58 1.85 Intermediate Bond Portfolio Composite (Inception and Creation Date: June 1995) Year Accounts Dispersion Firm Assets ($M) Return (Gross) Assets ($M) Composite 3 Yr Std Dev (%) 444 403 364 388 302 447 441 536 560 530 608 694 5.24-3.35 8.06-2.97 3.20-(3.43) 3.25- (1.56) 9.76-(9.28) 7.68-3.42 3.03-(1.20) 4.42-0.30 5.90-2.09 2.76-(1.21) 7.61-0.61 7.77-(3.52) 3.62 3.32 3.40 1.40 1.53 1.42 1.42 1.12 1.29 1.62 1.58 1.57 BofA/Merrill 1-10 Yr. US Gov./Corp. 3 Yr.Std Dev (%) 5.95 5.52 7.43 3.78 2.34 2.21 2.21 2.12 2.25 2.05 1.92 2.10 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 4.53 5.53 -2.60 1.60 4.13 4.89 1.20 1.44 3.58 1.26 2.15 2.39 BofA/Merrill 1- 10 Yr. US Gov./ Corp. 3.21 5.21 -8.30 -1.34 6.56 6.81 0.88 2.54 1.78 1.07 3.11 (0.78) 95 89 95 104 106 120 120 121 116 125 126 141 29.36 27.78 30.54 35.57 26.56 52.42 53.29 63.06 46.46 48.66 47.12 49.09 Page 19  Pinnacle Investment Advisors Blue Chip Strategy Composite (Inception and Creation Date: January 1997) S&P 500 Accounts Assets ($M) Dispersion Return (Gross) Firm Assets ($M) Composite 3 Yr Std Dev (%) S&P 500 3 Yr Std Dev (%) Year 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 14.90 16.08 -6.81 21.05 11.06 25.17 -3.25 27.61 16.43 0.09 9.89 28.42 24.98 26.24 -18.13 28.67 18.39 31.45 -4.39 21.80 11.93 1.38 13.70 32.44 80 81 80 83 79 80 88 80 80 89 87 78 47.66 48.50 47.41 57.87 46.31 77.08 64.03 63.52 41.34 40.45 44.51 35.83 444 403 364 388 302 447 441 536 560 530 608 694 15.56-12.89 18.50-13.36 (6.14)-(7.44) 28.33-19.66 23.65-(13.99) 26.6-22.09 6.69-(7.77) 30.24-0.19 20.8-14.31 1.72-(7.23) 11.93-4.28 32.24-19.71 10.52 12.13 14.11 5.92 10.93 10.68 10.98 10.75 11.03 10.44 8.83 10.71 20.62 21.51 24.59 5.62 10.34 10.15 10.32 10.06 10.96 10.45 9.00 12.02 Small Cap Value Strategy Composite (Inception and Creation Date: January 1994) Year Accounts Assets ($M) Dispersion 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 Return (Gross) 6.17 22.81 -3.94 40.09 10.78 20.27 -20.65 9.61 31.84 -16.94 9.24 54.44 S&P Small Cap 600 6.82 13.89 -17.42 25.27 9.57 20.86 -9.75 11.73 24.75 -3.36 4.44 39.65 90 83 84 92 90 110 110 73 69 68 71 95 19.43 20.82 18.37 22.75 16.51 16.06 15.98 16.80 17.77 14.10 19.18 22.96 Firm Assets ($M) 444 403 364 388 302 447 441 536 560 530 608 694 11.48-1.44 29.17-18.14 10.01-(9.44) 66.56-20.43 44.02-(48.28) 30.09-14.30 (15.31)-(25.81) 18.99-0.11 44.24-21.63 1.85-(23.95) 24.74-(0.05) 72.08-35.77 Composite 3 Yr Std Dev (%) 11.03 18.11 22.41 12.21 18.54 17.32 17.32 16.96 17.06 14.96 13.50 18.35 S&P Small Cap 3 Yr Std Dev (%) 13.41 18.05 21.59 6.61 15.68 14.66 14.66 14.06 14.51 22.91 18.09 20.10 Convertible Securities/High Yield Strategy Composite (Inception and Creation Date: May 1997) Year Dispersion Return (Gross) Accounts Assets ($M) BofA/Merrill Convertibles 3 Yr Std Dev (%) BofA/Merrill High Yield 3 Yr Std Dev (%) Firm Assets ($M) Composite 3 Yr Std Dev (%) 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 9.37 10.13 -11.20 25.40 -8.58 4.82 -5.78 14.12 26.59 -17.85 0.63 19.10 BofA/ Merrill Converti- bles 10.73 13.77 -19.58 4.12 52.05 22.89 0.65 15.70 11.87 -2.89 9.33 25.00 BofA/ Merrill High Yield 8.04 13.40 -11.11 5.29 6.20 14.40 -2.26 7.48 17.34 -4.55 2.45 7.38 70 73 72 83 84 94 94 78 75 78 80 98 17.75 18.06 17.81 22.38 21.89 24.71 23.63 27.79 26.63 21.58 25.08 30.79 444 403 364 388 302 447 441 536 560 530 608 694 12.43-5.88 14.25-7.74 (0.02)-(17.15) 35.13-10.89 38.89-(63.05) 7.18-(1.47) 3.99-(13.56) 19.97-(0.12) 42.82-10.80 (2.18)-(31.41) 15.82-(16.14) 26.18-8.70 9.88 15.01 17.70 13.97 12.75 11.98 11.98 11.62 12.02 8.76 8.32 8.05 15.06 14.01 19.29 19.72 5.84 5.73 5.73 5.66 6.09 5.26 4.41 6.33 10.52 10.19 11.08 4.10 9.21 8.77 8.77 8.14 9.10 8.23 7.52 8.96 Page 20  Pinnacle Investment Advisors Midstream Energy Strategy Composite (Inception and Creation Date: January 2001) Year Accounts Dispersion 2024 2023 2022 2021 2020 2019 2018 2017 2016 2015 2014 2013 Return (Gross) 37.60 19.22 22.74 52.33 -28.40 8.68 -13.74 -3.22 30.38 -38.43 -1.37 32.87 Alerian Index 24.41 27.33 30.12 40.17 -28.69 6.56 -12.42 -6.52 18.31 -32.59 4.80 27.58 58 60 54 57 63 72 72 76 72 78 82 94 Assets ($M) 11.65 10.20 8.56 7.69 5.27 10.08 10.25 13.34 14.82 11.52 38.26 98.89 Firm Assets ($M) 444 403 364 388 302 447 441 536 560 530 608 694 51.10-26.32 23.77-14.54 32.88-16.51 60.96-41.24 0-(93.96) 17.79-4.55 (0.05)-(24.08) 4.58-(11.37) 56.27-(17.28) 9.2-(52.75) 18.09-(8.29) 55.68-21.67 Composite 3 Yr Std Dev (%) 7.97 14.84 40.84 32.99 23.01 22.33 22.56 21.93 22.88 19.08 14.16 12.98 Alerian 3 Yr Std Dev (%) 2.33 5.51 37.20 28.11 19.84 19.52 19.68 19.05 19.95 18.49 13.54 13.43 Global Investment Performance Standards (GIPS) Compliance Pinnacle Investment Advisors does not claim compliance with the Global Investment Performance Standards (GIPS®) but has prepared and presented this report in compliance with the GIPS standards. Pinnacle Investment Advisors has been inde- pendently veri(cid:976)ied for the periods December 31, 2009 through December 31, 2018 by Alpha Performance Veri(cid:976)ication Services. The veri(cid:976)ication report is available upon request. A (cid:976)irm that claims compliance with the GIPS standards must establish policies and procedures for complying with all the applicable requirements of the GIPS standards. Veri(cid:976)ication provides assurance on whether the (cid:976)irm’s policies and procedures related to composite and pooled fund maintenance, as well as the calculation, presentation, and distribution of performance, have been designed in compliance with the GIPS standards and have been im- plemented on a (cid:976)irm-wide basis. Veri(cid:976)ication does not provide assurance on the accuracy of any speci(cid:976)ic performance report. GIPS® is a registered trademark of CFA Institute. CFA Institute does not endorse or promote this organization, nor does it warrant the accuracy or quality of the content contained herein. Notes: 1. The (cid:976)irm is de(cid:976)ined as Pinnacle Investment Advisors, a registered investment advisor responsible for management of all accounts included in the composites, including the accounts of Native American Fund Advisors. Pinnacle Investment Advi- sors is a balanced portfolio investment manager that invests solely in U.S.-based securities. Policies for valuing portfolios, calculating performance, and preparing GIPS reports are available upon request. 2. The Intermediate Bond Portfolio seeks higher yields and total return than are available with short term bonds. The Portfo- lio invests in investment grade corporate bonds in addition to core holdings of U.S. Treasury and Federal Agency securities with an average intermediate maturity of three to seven years. Creation date – June 1995. Minimum Size Threshold: $50,000 in asset class. 3. The Tax Exempt Bond Portfolio seeks to provide a high level of income that is exempt from regular federal income taxes. The Portfolio invests in high quality municipal bonds with an intermediate average maturity of three to seven years. Crea- tion date – June, 1995. Minimum Size Threshold: $50,000 in asset class. 4. The (cid:976)irm’s high yield strategy seeks to generate high total returns from income producing securities with the potential for capital appreciation. The strategy invests in convertible corporate bonds, convertible preferred stocks, and corporate bonds. The conversion option imbedded in the securities allows for capital appreciation potential should the issuer’s com- mon stock perform well. Many holdings in this strategy are rated below investment grade by the major ratings agencies or are unrated. Creation date – January 1997. Minimum Size Threshold: $100,000 in asset class. 5. The Midstream Energy Strategy invests in publicly traded partnerships and C-corporations that produce high levels of tax sheltered income with the potential for capital appreciation. Composite inception date – December 2000. Minimum Size Threshold: $50,000 in asset class. 6. Blue Chip Strategy - The large company stock strategy seeks to provide performance similar to the Dow Jones Industrials. The Dow Industrials offer attractive performance over long time periods with low turnover and low transaction costs. Cre- ation date – January 1996. Minimum Size Threshold: $50,000 in asset class. 7. The Small Cap Value Strategy seeks to provide returns consistent with the long term historical average of Page 21 small company stocks. Small company stock values tend to be more volatile than large company stocks but they have generated higher returns over long periods of time. Creation date – December 1994. Minimum Size  Pinnacle Investment Advisors Threshold: $30,000 in asset class. 8. Valuations are computed and performance is reported in U.S. dollars. 9. Gross-of-fees returns are presented before management and custodial fees but after all trading expenses. Net-of-fees re- turns are calculated based on actual fees.. The effect of management fees on the client’s return would reduce the total re- turn by the amount of the management fee according to the management fee schedule. (The (cid:976)irm reserves the right to ne- gotiate management fees.) The Firm may charge fees on non-discretionary assets or other assets not de(cid:976)ined in the catego- ries above at rates to be negotiated with the client. For some client accounts for which mutual funds or exchange traded funds are recommended, the client may be charged management fees by the (cid:976)irm in addition to the management fee por- tion of the expense ratio of the mutual fund or ETF. 10. A complete list of composite descriptions is available upon request. 11. Internal dispersion is calculated using the highest and lowest rate of annual gross returns of those portfolios that were included in the composite for the entire year. 12. The three-year annualized standard deviation measures the variability of the composite gross returns and the benchmark returns over the preceding 36-month period. 13. Non-fee paying accounts are excluded from the composites. 14. Accounts with significant cash flows (>10%) will temporarily be removed from the composite and excluded in performance presentation during the period of the significant cash flow. Page 22  Pinnacle Investment Advisors Management Fee Schedule Short Term Bond Portfolio Annualized Fee Rate: Equal to or Less than 0.25% Tax Exempt Bond Portfolio and Intermediate Bond Portfolio Market Value of Assets in Account Less Than $ 1,000,000 $ 2,000,000 $ 5,000,000 to to to $ 1,000,000 $ 2,000,000 $ 5,000,000 $ 10,000,000 Annualized Fee Rate 0.50% 0.45% 0.40% 0.35% $ 10,000,000 to $ 20,000,000 0.30% Over $ 20,000,000 0.25% Small Cap Value Strategy Market Value of Assets in Account Annualized Fee Rate Less Than $ 1,000,000 to $ 1,000,000 $ 2,000,000 1.00% 0.75% $ 2,000,000 to $ 5,000,000 0.625% $ 5,000,000 to $ 10,000,000 0.50% Over $ 10,000,000 0.50% Convertible Securities/High Yield Strategy and Midstream Energy Strategy Market Value of Assets in Account Annualized Fee Rate Less Than $ 1,000,000 0.75% $ 1,000,000 to $ 2,000,000 0.625% $ 2,000,000 to $ 5,000,000 0.55% to $ 5,000,000 Over $ 10,000,000 $ 10,000,000 0.50% 0.45% Blue Chip Strategy Market Value of Assets in Account Annualized Fee Rate Less Than $ 1,000,000 0.50% $ 1,000,000 to $ 2,000,000 0.45% $ 2,000,000 to $ 5,000,000 0.35% $ 5,000,000 to $ 10,000,000 0.25% Over $ 10,000,000 0.20% Page 23  Pinnacle Investment Advisors Pinnacle may recommend the Schwab Institutional Division of Charles Schwab & Co., Inc for cus- tody of the client’s account in order to reach greater economies of scale when purchasing and selling securities in large quantities. The services that Schwab provides include custody of the client’s assets, securities trading, research, access to mutual funds, and other investments that are otherwise generally only available to institutional investors or would require a signi(cid:976)icantly higher minimum initial investment. Schwab is compensated through commissions or other transaction related fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab makes available other products and services that bene(cid:976)it Pinnacle but may not bene(cid:976)it its clients’ accounts. These include software and other technology that provide access to client account data, facilitate trade execution, provide research, pricing information and other market data, facilitate payment of management fees, and assist with back-of(cid:976)ice func- tions, record keeping, and client reporting. The (cid:976)irm has a similar arrangement with J.P. Morgan Securities. The (cid:976)irm will attempt to negotiate low commission rates based on the size of the transaction, and that commission rate will apply to all clients. There will be no special arrangements with any particular broker. When block trades are executed, each client will receive the same average price on the security involved. More information regarding the (cid:976)irm’s portfolio management pol- icies is contained in the (cid:976)irm’s written compliance policies and procedures. Management fees can be deducted from the client’s account with written permission or billed directly to the client. The Small Cap Value Strategy, Convertible Securities/High Yield Strategy, and the Midstream Energy Strategy charge higher management fees than the Blue Chip Strategy and the (cid:976)ixed in- come portfolios. Therefore, the client should be aware that the (cid:976)irm has an incentive to recom- mend the higher fee strategies. Private Funds: Pinnacle acts as managing member of Pinnacle Acquisition Fund II, a private investment part- nership and has a proprietary interest in the fund. Pinnacle Acquisition Fund II is a limited liabil- ity company whose members consist solely of accredited investors. The company was formed to buy and sell publicly traded securities, using margin transactions for leverage, and using options on interest rate futures, options on common stocks, options on index futures, and short sale po- sitions for hedging purposes. Pinnacle receives a share of the pro(cid:976)its and losses of the company. Pinnacle receives performance fees for Pinnacle Acquisition Fund II in addition to management fees; we receive a 10% share of the net income from Pinnacle Acquisition Fund II. Pinnacle also acts as a managing partner for Pinnacle Income Partners II, an Oklahoma limited liability company that was formed to invest in publicly traded master limited partnerships. The fund pays a management fee to Pinnacle for acting as a managing partner. Membership in the companies is restricted to accredited investors only. Pinnacle has a proprietary interest in Pin- nacle Income Partners II and is eligible to receive a performance based fee (in addition to the management fee) of 1.0% of assets under management, if the annual return exceeds 12.0% in a Page 24  Pinnacle Investment Advisors given calendar year, after the normal management fee. Pinnacle acts as a managing member of Coronado Capital, an Oklahoma limited liability company formed to invest in publicly traded small and regional banks. Pinnacle is eligible to receive a 15% share of annual return in excess of the 12% hurdle rate. Due to the receipt of performance fees on the private funds, a potential con(cid:976)lict of interest exists between the (cid:976)irm and its separately managed client accounts. The (cid:976)irm could bene(cid:976)it by allocating pro(cid:976)itable trades to the private funds instead of to the separate client accounts. One way to avoid this con(cid:976)lict is through the timing of placement of orders as described in the paragraph below. More information about this potential con(cid:976)lict of interest is addressed in the (cid:976)irm’s written compli- ance policies and procedures and is available upon request. As a managing member, Pinnacle In- vestment Advisors solicits current and prospective clients for investment in Pinnacle Acquisition Fund II, Pinnacle Income Partners II, and Coronado Capital LLC. Since the (cid:976)irm receives perfor- mance fees, there exists a potential con(cid:976)lict of interest for the (cid:976)irm to recommend the private funds to potential clients. Related persons, including the private funds, will by policy be the last order (cid:976)illed when purchases and sales of recommended securities are executed for managed portfolios. The speci(cid:976)ic policies and procedures are de(cid:976)ined in the (cid:976)irm’s written compliance policies. Related persons will be re- quired to obtain prior approval from one of the Managing Partners before entering an order. Du- plicate copies of all related person transactions will be kept on (cid:976)ile with the (cid:976)irm’s books and rec- ords. Due to the risk of the (cid:976)irm having constructive custody of the assets of the private funds, the (cid:976)irm has developed policies and procedures to comply with the SEC’s Custody Rule. The assets of the private funds are held at quali(cid:976)ied independent custodians. Mysock, Chevaillier, and Birdsong of Tulsa, Oklahoma, receives brokerage statements directly from the fund custodians and produces the quarterly (cid:976)inancial statements and annual tax returns. The (cid:976)irm has engaged Briscoe, Burke & Grigsby LLP of Tulsa, Oklahoma, to provide surprise examinations of fund assets and verify ac- count balances with the fund investors for Pinnacle Income Partners II. The (cid:976)irm has retained Briscoe, Burke, and Grigsby of Tulsa, Oklahoma to audit the (cid:976)inancial statements of the other pri- vate funds. Pinnacle Holdings controls the operational management of Pinnacle Investment Advisors. Pinnacle Investment Advisors has an operations agreement with Native American Fund Advisors, a Regis- tered Investment Advisor. Pinnacle Investment Advisors acts as the sub-advisor to the managed accounts of Native American Fund Advisors. The client accounts of Native American Fund Advisors are managed in strategies that are similar to Pinnacle Investment Advisors. Mr. Joel Kantor, a supervised person of the (cid:976)irm, is a partner with Mimosa Tree Capital Partners, a private equity investment (cid:976)irm. Mr. Kantor allocates approximately 40% of his work hours to Mi- mosa responsibilities and receives compensation from Mimosa. The investments Mimosa makes are in private companies, therefore they do not con(cid:976)lict with the recommended securities for Pin- nacle Investment Advisors clients. The (cid:976)irm has referral agreement with Mr. James A. Posey, Jr., a registered representative with USI Page 25  Pinnacle Investment Advisors Insurance Services. Under this agreement, Mr. Posey receives a 20% management fee split for all clients he refers to Pinnacle for investment management. These clients must sign a disclosure statement in order for Mr. Posey to receive their share of fees. As a registered advisor, Pinnacle has adopted a code of ethics, based on the CFA Institute Asset Manager Code, pursuant to SEC Rule 204A-1 which is available upon request. Pinnacle is responsi- ble for voting the proxy materials of supervised assets. The (cid:976)irm’s written proxy voting policy and voting history is available upon request. The (cid:976)irm disclaims responsibility for voting the proxies for unsupervised assets. Clients may instruct the (cid:976)irm how to vote their unsupervised securities at their discretion. Pinnacle Investment Advisors founded the Tulsa Fiduciary Fund in the fourth quarter of 2021. Tulsa Fiduciary Fund is a non-pro(cid:976)it, 501(c)-3 corporation, formed to provide transparent invest- ment management and administration for donor advised funds that bene(cid:976)it non-pro(cid:976)it organiza- tions in Tulsa and northeast Oklahoma. The (cid:976)irm receives a share of the fees charged to the Fund for administration and management of the investment accounts, therefore a potential con(cid:976)lict of interest is present. The (cid:976)irm may be incentivized to direct clients to contribute to the Tulsa Fiduci- ary Fund rather than other non-pro(cid:976)it organization endowments. The (cid:976)irm will fully disclose the potential revenues received from contributions to the fund. The Fund will have an independent board of directors responsible for oversight and management of the Fund. Mr. Jayme Fowler joined the (cid:976)irm in 2023. Mr. Fowler performs investment consulting and portfo- lio management services for clients through Oak Creek Private Wealth Management, a subsidiary of Pinnacle Holdings. Mr. Fowler primarily uses external investment managers and funds and per- forms due diligence on recommended managers through Envestnet. Please see Oak Creek’s disclo- sure statement for additional information. Page 26  Pinnacle Investment Advisors This Brochure Supplement, dated December 31, 2024, contains information about the following supervised persons that supplements the Pinnacle Investment Advisors brochure. You should have received a copy of that brochure. Please contact David Poarch if you did not receive a copy of Pinnacle Investment Advisors’ brochure or if you have any questions about this supplement. 1. R. Brett Kramer, CFA, Managing Partner 2. David M. Poarch, Managing Partner 3. Joel B. Kantor 4. Aimee N. Boyer, CFP® Jayme D. Fowler, CIMA®, ChFC 5. Toby Moore, CIMA® 6. 7. Benjamin G. McNulty All members of the staff can be contacted at the Firm’s principal place of business. Pinnacle Investment Advisors 1616 East 15th Street Tulsa, Oklahoma 74120 (918) 582‐6864 Investment advice provided to clients is supervised by Mr. Poarch and Mr. Kramer. Additional information about Pinnacle Investment Advisors is available on the SEC’s website at www.adviserinfo.sec.gov. Page 27  Pinnacle Investment Advisors All representatives of the (cid:976)irm that offer investment advice are required to have a degree from an accredited college or university and must have passed the NASD Investment Advisors examina- tions as required by law. R. Brett Kramer, CFA ‐ Managing Partner Brett Kramer, age 63, is a Registered Investment Advisor and the Chief Investment Of(cid:976)icer. With 32 years experience in the investment industry, Mr. Kramer is a Chartered Financial Analyst (CFA) and a former Certi(cid:976)ied Public Accountant (CPA). Mr. Kramer’s primary responsibilities include overseeing the investment selection process, research, and trading. He co-founded Pinnacle in 1996 with Mr. Poarch. Mr. Kramer began his career with The City of Tulsa, developing an investment policy, coordinating and developing a cash management process, and managing a bond portfolio in excess of $300 mil- lion. After two years, he joined Liberty Bank where he managed over $1 billion in (cid:976)ixed income se- curities and was responsible for the asset/liability analysis. In addition to his extensive experience in the (cid:976)ixed income markets, Mr. Kramer has been heavily involved with the equity markets for many years. Having worked in both the public sector and the private sector, he has perspectives, including investment policies, asset allocation, cash management, and total return to enhance portfolio management, for a broad range of clients. Mr. Kramer earned a B.S. from the University of Oklahoma in Chemical Engineering and an M.B.A. from the University of Tulsa emphasizing (cid:976)inance. Mr. Kramer returned to the University of Tulsa to earn the 30 hours necessary to sit for the CPA exam. David Poarch ‐ Managing Partner David Poarch, age 63, is a Registered Investment Advisor and Managing Partner. His primary re- sponsibilities include assisting with investment policy and execution, supporting the marketing effort, developing new investment strategies and products, client reporting, and administration of the (cid:976)irm’s business affairs. He was a co-founder of Pinnacle in 1996. Mr. Poarch has 41 years experience in the investment industry including twelve years in (cid:976)ixed in- come trading and 29 years in investment portfolio management. Mr. Poarch managed the taxable securities trading efforts for Liberty Bancorp prior to joining Pinnacle. In his career, Mr. Poarch has completed the Series 7, Series 63, Series 65, and Series 24 examinations. Mr. Poarch received a B.B.A. in Economics from the University of Oklahoma in 1983 where he was Page 28  Pinnacle Investment Advisors a University Scholar, an Alumni Scholar, and a member of Beta Gamma Sigma. He earned an M.B.A. from Oklahoma City University in 1985. Mr. Poarch has served on the board of the Tulsa Day Center for the Homeless since 1995, (cid:976)illing the roles of Vice President, President and Treasurer, successively. Additionally, he recently served on the board of Collegiate Hall Charter School, and Calvary Cemetery. Joel B. Kantor ‐ Partner, Financial Planner Joel Kantor, age 68, is a Registered Investment Advisor and former Certi(cid:976)ied Financial Planner de- signee. His primary responsibilities include (cid:976)inancial planning, portfolio management, and new business development. Mr. Kantor has over 32 years experience in the investment industry with various brokerage (cid:976)irms, including over 20 years as a (cid:976)inancial planner and investment advisor. Mr. Kantor joined Pinnacle in 2005. He received a B.B.A. in Accounting from the University of Oklahoma in 1978. He complet- ed the Certi(cid:976)ied Financial Planner examination in 2000. His former board memberships include the Tulsa Jewish Retirement Center, the Tulsa Jewish Federation, Tulsa Metropolitan Ministries, the Day Center for the Homeless, Federation of Fly(cid:976)ishers, and Trout Unlimited. Mr. Kantor is a partner with Mimosa Tree Capital Partners, a private equity (cid:976)irm, that is more fully described in the Potential Con(cid:976)licts of Interest section. Aimee N. Boyer, CFP® ‐ Financial Planner Ms. Boyer, age 40, joined Pinnacle in January, 2011 as a Financial Advisor. Prior to joining the (cid:976)irm she worked as a retail manager at Williams-Sonoma. Her primary responsibilities include (cid:976)inancial planning, client service, database management, marketing and business development, and manag- ing securities trading and fund trading. Ms. Boyer has received a B.S.B.A in Marketing and Business Management and her J.D. from the Uni- versity of Tulsa. She has completed both the Series 65 examination and the Certi(cid:976)ied Financial Planner examination. Ms. Boyer has served on the board of the Tulsa Campaign to Prevent Teen Pregnancy and current- ly serves on the board of the Tulsa Health Department. She (cid:976)ills a volunteer role as the Executive Director of the Tulsa Fiduciary Fund. Robert (Toby) Moore, CIMA®, Financial Analyst/Trader Toby Moore, age 55, Registered Investment Advisor whose responsibilities include (cid:976)ixed income analysis and trading. Mr. Moore has over 25 years experience in the investment industry. Most of Page 29  Pinnacle Investment Advisors that time was spent as an analyst with an investment consulting (cid:976)irm. Mr. Moore performed asset allocation, manager selection and performance analytics of investment managers the (cid:976)irm recom- mended to foundations, endowments and other clients. Mr. Moore received a B.S.B.A. in Finance from the University of Tulsa in 1991 and an MBA from the University of Oklahoma in 1992. Jayme D. Fowler, CIMA®, ChFC ‐ Financial Advisor Jayme Fowler, 66, is a Registered Investment Advisor, Certi(cid:976)ied Investment Management Ana- lyst, and Chartered Financial Consultant with over thirty years of experience in the invest- ments business. Mr. Fowler has worked for numerous multi-billion dollar asset management (cid:976)irms including Nicholas Applegate, Trust Company of the West, and Oppenheimer. He has completed the Program on Investment Decisions & Behavioral Finance at Harvard University. Mr. Fowler received a B.S.B.A. in Finance from the University of Arkansas. He recently served on the Tulsa City Council. Benjamin G. McNulty ‐ Financial Analyst Ben McNulty, age 27, is a Registered Investment Advisor who has worked in the investments business since 2022. Mr. McNulty worked in securities operations for BOK Financial after completing post-graduate education. He has a B.B.A. in Finance and an M.B.A. from the Uni- versity of Oklahoma. Mr. McNulty supports the database management and equity trading for the (cid:976)irm. Page 30