PNC INVESTMENTS LLC

Form ADV Part 2A Appendix 1 801‐66195 Disclosure Document for the Capital Directions Program An Investment Advisory Service of PNC Wealth Management LLC 300 Fifth Avenue Pittsburgh, Pennsylvania 15222 (800) 622‐7086 www.pnc.com October 17, 2025 This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of PNC Wealth Management LLC and the Capital Directions Program (the “Program”). If you have any questions about the contents of this Brochure, please contact us at (800) 622‐7086. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. PNC Wealth Management LLC, a registered investment adviser and broker‐dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), is a wholly owned subsidiary of The PNC Financial Services Group, Inc. Registration does not imply a certain level of skill or training. Additional information about PNC Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. • NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, PNC BANK, N.A. OR ANY OF ITS AFFILIATES • SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED  MATERIAL CHANGES ADV Part 2A dated October 17, 2025 The following change(s) have been made to the PNC Wealth Management Capital Directions Flex UMA Program Brochure since the last Brochure dated July 16, 2025: On or about October 17, 2025, our firm’s legal and business name will change from PNC Investments LLC to PNC Wealth Management LLC. This change is administrative in nature and does not affect the ownership, management, operation, services, or fees of the firm. All references to PNC Investments LLC within the Brochure will be updated to PNC Wealth Management LLC. No other material changes have been made since our last Form ADV 2A Brochure was filed on July 16, 2025. Capital Directions Program October 17, 2025 Page 2 of 36  Table of Contents About PNC Wealth Management LLC ............................................................................................ 4 SERVICES, FEES AND COMPENSATION The Capital Directions Program Automatic Rebalancing Account Statements Account Termination Review of Accounts Securities Transferred into an Account Withdrawals from an Account Taxes Fees and Expenses Calculation of Account Fees Additional Fees for Brokerage Services Deduction of Account Fees Other Expenses Cash Balances Financial Advisor Compensation ................................................................................................................ ..................................................................................................................... .................................................................................................................... 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............................................................................................................................... .................................................................................................. 4 ............................................................................................... ...................................................................................................... 5 13 13 13 14 14 15 15 15 20 20 21 21 24 25 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients Collateral Accounts ........................................................................ ..................................................................................... ....................................................................................................................... 26 26 27 PORTFOLIO MANAGER SELECTION AND EVALUATION Fund and Model Provider Selection and Evaluation PNC Wealth Management and Other Service Providers to the Program Risks of Investing in the Capital Directions Program Trading Practices Proxy Voting .................................................................... .................................................................... .................................... ................................................................... .......................................................................................................................... ................................................................................................................................. 28 28 29 29 30 31 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ....................................................... 32 CLIENT CONTACT WITH PORTFOLIO MANAGERS ............................................................................. 32 ADDITIONAL INFORMATION Disciplinary Information Other Financial Industry Activities and Affiliations Affiliate Transactions Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Client Reports Client Referrals and Other Compensation Financial Information ............................................................................................................ ............................................................................................................... ...................................................................... .................................................................................................................... ............... ............................................................................................................................... ................................................................................... ................................................................................................................... 32 32 34 35 35 35 36 36 Capital Directions Program October 17, 2025 Page 3 of 36  About PNC Wealth Management LLC PNC Wealth Management LLC (“PNC Wealth Management” or the “Firm”) is an investment adviser and also a registered broker‐dealer and member of FINRA and SIPC. The Firm offers retail brokerage and investment advisory services. PNC Wealth Management serves as the sponsor of, and in some cases as a portfolio manager for, wrap fee investment programs. PNC Wealth Management is a wholly owned subsidiary of PNC Bank, National Association (“PNC Bank”) and is a part of The PNC Financial Services Group, Inc. (“PNC”) which is a diversified financial services institution with roots in commercial banking and investment management dating back to the early 1800s. Throughout this document, the terms “client,” “you,” and “yours” are used to refer to the individual(s), institution(s) or organization(s) who contract with us for the services described here. “PNC Wealth Management,” “we,” “our,” “us” and “the firm” refer to PNC Wealth Management LLC, together (as applicable) with our affiliates, including but not limited to, PNC and its agents with respect to any services provided by those agents. Our affiliates include any entity that is controlled by, controls or is under common control with PNC Wealth Management, including but not limited to our parent company, The PNC Financial Services Group, Inc. Each affiliate is a separate legal entity and not responsible for the obligations of any other affiliate. “Account” means each brokerage and/or advisory account you open with us that is subject to the Capital Directions Program investment management agreement (the “Investment Management Agreement”), including any and all mutual funds, exchange traded funds, money, securities, financial instruments and/or other property you have funded in such accounts. “Business Day” means Monday through Friday, excluding New York Stock Exchange holidays. “Wrap” refers to an Account that charges a quarterly or annual fee based on the average assets under management, where such fee covers administrative, commission, execution and management expenses. SERVICES, FEES AND COMPENSATION . Other advisory services are This Brochure is being provided pursuant to Section 204 of the Investment Advisers Act of 1940, as amended, and deals solely with our Capital Directions Program. In addition to the Program, PNC Wealth Management offers a variety of investment advisory services. These include the Portfolio Solutions Program, the PNC Directions Program, the Portfolio Solutions Strategist Program, the Capital Directions Annuities Program, and the Guided Solutions Program. More information about these programs and services is contained in the applicable PNC Wealth Management brochure and is available upon request from PNC Wealth Management or through the SEC’s website at https://adviserinfo.sec.gov/. For more information about these or other services that are available from PNC Wealth Management, please contact your Financial Advisor1 offered by our affiliates. 1 We use the term “Financial Advisor” to refer to PNC Wealth Management’ branch‐based and wealth Financial Advisors, as well as Advisor Direct Financial Advisors and Investment Services Consultants. Capital Directions Program October 17, 2025 Page 4 of 36  The Capital Directions Program The Program is a unified investment advisory platform that provides clients an integrated set of diversified portfolios through a single brokerage account. We will help you formulate an investment strategy, which will be implemented through use of investment manager models, mutual funds and/or exchange traded funds (collectively “Funds”) that are a part of the Program. PNC Wealth Management, as the investment adviser to the program, will exercise its discretion to invest your Account in all or a combination of equities, fixed‐income securities, Funds, and other securities and investment products made available through the Program now or in the future. Additional model investment strategies provided by professional investment managers are also available in a variety of investment types and styles. PNC Wealth Management uses asset allocation models, each associated with a distinct risk profile and comprised of a unique mix of investment assets that leverage guidance from PNC Bank’s Private Bank (the “Private Bank”), as well as other external Research Partners, and approved by PNCWM’s Investment Due Diligence Committee (IDD). Furthermore, PNC Wealth Management may also conduct its own research, including gaining insights from non‐affiliated third parties, to be used in making asset allocation decisions for the Allocation Models, which from time‐to‐time may diverge from models developed by the Private Bank. In all cases, PNCWM has sole discretion in approving Allocation Models for the program. These models are summarized below:  Ultra-Conservative. The primary objective of this asset allocation model is the preservation of the purchasing power of the portfolio. A secondary objective is to generate a modest amount of current income to offset the effects of inflation. An Ultra‐Conservative portfolio is constructed to provide stability of invested capital by allocating a higher percentage of assets to cash and fixed income securities. A small percentage is allocated to Funds focused primarily on large cap domestic equities to generate a modest amount of the asset’s total return potential. The portfolio assumes reinvestment of all interest and dividend income to help maintain the portfolio’s value. The recommended time horizon of the portfolio is one to three years. You should be aware that over long time periods, the Ultra‐Conservative model is unlikely to grow in value, after accounting for the effect of inflation and advisory fees. Risks include the fact that fixed income securities may lose value in a rising interest rate environment, and are subject to credit risk if the issuer’s ability to repay its debts should become doubtful.  Conservative. The primary objective of the Conservative model is to generate a modest amount of current income, and secondarily to provide a modest amount of long‐term capital growth, which should help offset some of the effects of inflation. Long‐term growth of principal will be aided by income reinvestment. While the goal is to maintain a low‐risk posture, investors should be willing to accept periodic declines in portfolio value. Although past performance is no guarantee of future results, generally any such decline should be less severe than declines in the broader equity markets. The portfolio’s allocation between equity and fixed income securities, with the allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program Capital Directions Program October 17, 2025 Page 5 of 36  throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Moderate. The objective of the Moderate model is to generate a moderate amount of current income with the potential for longer‐term capital growth. The portfolio is split between equity and fixed income securities, with a small allocation to cash, and is constructed to provide both long‐term capital appreciation in excess of inflation and a moderate amount of current income. While the current income generated could be available to meet your day‐to‐day expenses, reinvestment of income will increase the portfolio’s ability to exceed inflation over the long‐term. The portfolio’s allocation between equity and fixed income securities, with an allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Balanced. The primary objective of the Balanced model is to provide long‐term capital growth in excess of inflation, with a modest amount of current income as a secondary objective. The portfolio is allocated between equities and fixed income securities, with a higher allocation to a variety of equity securities. The portfolio also contains a small allocation to cash. While the current income generated could be available to meet your day‐to‐day expenses, income reinvestment will increase the portfolio’s ability to exceed inflation over the long‐term. This portfolio maintains a somewhat aggressive risk posture, and you should be willing to accept periodic declines in portfolio value. Because the portfolio is largely invested in equities, it can experience fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Growth. The primary objective of the Growth model is long‐term capital growth. It may secondarily generate a minimal amount of current income by including some fixed income securities. The portfolio is concentrated in equity investments in order to earn returns exceeding the rate of inflation over the long‐term. A small allocation to fixed income securities, as well as cash, is included primarily to help dampen volatility over the long‐ term. This portfolio maintains an aggressive risk posture, and you should be willing to accept potentially significant declines in portfolio value that may be similar to or exceed declines in the broader equity markets. Because the portfolio is predominantly invested in equities, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Aggressive. The primary objective of the Aggressive model is long‐term capital growth. An Aggressive portfolio is concentrated in equity investments for long‐term growth. Returns in excess of the underlying rate of inflation are necessary to increase both principal and purchasing power. Capital Directions Program October 17, 2025 Page 6 of 36  This portfolio maintains a highly aggressive risk posture, and you should be willing to accept potentially significant declines in portfolio value, similar to or greater than declines in the broader equity markets. The portfolio may contain a small allocation to fixed income securities as well as cash. Because the portfolio is predominantly invested in equity securities, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective. PNC Wealth Management also makes available a series of multi‐asset income focused models that focus on both capital appreciation and higher distribution yields. These models are designed to emphasize asset class exposures and fund selections that seek to achieve higher levels of income. The portfolio’s allocation to fixed income has the risk of rising interest rates and its allocations to high yield fixed income exposes it to credit risk. The equity allocation to the portfolio has a higher concentration in value style stocks which can lag in strong growth markets. In addition to the asset allocation models, the Program offers two income models that have been developed by PNC Wealth Management based on input from PNC’s Investment Policy Committee. Each income model is associated with a distinct risk profile and comprised of a unique mix of investment assets. These income models are summarized below:  Core Fixed Income. The primary objective of this portfolio is total return comparable to a portfolio of investment grade domestic bonds. Capital preservation is a secondary objective. The minimum recommended time horizon for this portfolio is three to five years. This portfolio has a strategic allocation to U.S. investment grade bonds and tactical allocations to other non‐investment grade securities. The portfolio’s allocation to 100% fixed income securities exposes it to the risk of rising interest rates. Any decline experienced in this portfolio should be significantly less severe than declines in a portfolio that has significant equity exposure.  Core-Plus Fixed Income. The primary objective of this portfolio is total return incrementally higher than a portfolio of investment grade domestic bonds achieved through slightly more aggressive tactical decision making. A secondary objective is capital preservation. The suggested time horizon for this portfolio is at least three to five years. This portfolio invests in fixed income securities with an emphasis on total return and portfolio yield. This portfolio uses a broader range of credit quality securities which emphasizes slightly more tactical decision making. The portfolio’s allocation to 100% fixed income exposes it to the risk of rising interest rates and its allocations to high yield fixed income exposes it to credit risk. The alternative models include an allocation to alternative strategy Funds (“Alternative Funds”) that are registered with the SEC under the Investment Company Act of 1940 (the “Investment Company Act”). Alternative Funds can use one of many different strategies including, but not limited to, long/short, managed futures, market neutral, or derivative income. PNC Wealth Management will select the Funds and allocation in the alternative models, but you will have the ability to modify the Funds or allocation selected. When alternative models are selected, the traditional asset classes in each model will be reduced on a pro rata basis. Capital Directions Program October 17, 2025 Page 7 of 36  Alternative Funds seek to provide additional diversification benefits beyond those of a traditional portfolio of stocks and bonds. However, Alternative Funds are accompanied by risks that might be different from those associated with traditional investments. When used as part of an overall solution, alternatives may help to meet a client’s investment needs. Because Alternative Funds are regulated under the Investment Company Act, there are several ways in which they are structured to mitigate some liquidity risk, which may occur during severe market conditions, and differ from unregistered hedge funds and other alternative investments. You should carefully review the prospectus for any Alternative Fund you are considering for details on liquidity and other risks associated with them and review the manager’s ability to place limitations on liquidity. Alternative Funds are subject to: Limits on illiquid investments including a maximum of 15% of assets in illiquid investments; Limits on leveraging of no more than 33% of assets;    Diversification requirements including a maximum of 25% of assets invested in one issuer; and  Daily pricing and redeemability of fund shares. Alternative Funds are also prohibited from charging the types of management and performance based fees (e.g., a “2/20” fee) charged by some hedge funds. Before you open an Account in the Capital Directions Program, you should carefully review our Client Relationship Summary (“Form CRS”) and consider whether an advisory relationship is right for your situation and circumstances. You may discuss any questions you have regarding our Form CRS or whether an advisory account is right for you with your Financial Advisor. Some things you may wish to consider are: your preference for a fee‐based versus a commission based relationship; your desire for on‐going support and advice from your Financial Advisor; how much trading activity you expect to take place in your account; and the anticipated total costs. You should know that your Financial Advisor benefits when you open a Capital Directions account, as described in more detail in the Financial Advisor Compensation section of this Brochure, and has a conflict of interest when recommending an advisory account to you. Once you decide that the Program is right for you, your Financial Advisor will help you determine which of the flexible asset allocation or income models (“Allocation Models”) described above is appropriate for you. Based on your needs, circumstances, and investment goals your Financial Advisor will help you complete either an investor questionnaire or a goals‐based retirement income analysis provided by an unaffiliated third‐party (“Retirement Tool”). The investor questionnaire provides us with an understanding of your financial situation, investment objectives, risk tolerance and investment time horizon. Based on the information collected in the investor questionnaire and other information you share with your Financial Advisor, your Financial Advisor will recommend an Allocation Model appropriate to your situation. Your Financial Advisor will help you understand the risk and return characteristics of the selected Allocation Model and help you evaluate the Allocation Model’s return potential in relation to your investment goals and objectives. The Retirement Tool utilizes your current and future savings and time horizon to estimate potential retirement income based on a sample investment selection. Your Financial Advisor will help you evaluate which of the Allocation Models provide the highest likelihood of meeting your targeted level of retirement income. You should be aware that the Retirement Tool analysis is based on PNC Wealth Management’ default Allocation Capital Directions Program October 17, 2025 Page 8 of 36  Models, which may vary from the investment portfolio ultimately recommended to you in an investment proposal as discussed further below. You should also know that certain Allocation Models discussed above are not available in the Retirement Tool. Whether your Financial Advisor utilizes an investment questionnaire or the Retirement Tool, your Financial Advisor will assist you to select from a variety of approved funds and investment models (“Investment Models”) offered by professional third‐party asset managers (“Model Providers”) as further described below, available through the Program. We will present our investment strategy recommendation to you in the form of a proposal (the “Proposal”), which will include the actual initial investment portfolio recommended to you, for your acceptance and approval. It is very important that you understand the risks associated with the Allocation Model you select and should discuss this with your Financial Advisor if you have any questions. From time‐to‐time your Financial Advisor may recommend changes to your Allocation Model or to the Funds or Investment Models you have selected. You may also request changes to your Allocation Model or your selected Funds or Investment Models, subject to certain restrictions described in this brochure. PNC Wealth Management has delegated certain portfolio management services to Envestnet Asset Management, Inc., an unaffiliated investment adviser (the “Investment Delegate”) for Program Accounts. The Investment Delegate will implement Model Providers’ Investment Models (excluding Manager Traded Models as described below) and will facilitate the execution of trades in your Account as instructed by PNC Wealth Management. Manager Traded Models are fixed income Models, and trades for those Models are implemented by the Model Provider rather than by PNC Wealth Management or the Investment Delegate. Finally, PNC Wealth Management will periodically exercise its discretion to adjust Allocation Models or remove Funds or Investment Models from our approved list. In all of these circumstances, PNC Wealth Management will update your Allocation Model and/or the Funds or Investment Models you have selected accordingly and, if necessary to align your account to the new investment model, will execute transactions in your account. Note that you will not be sent a new Proposal in these circumstances, unless requested through your Financial Advisor. Furthermore, PNC Wealth Management may, at its discretion, remove an asset allocation model from the schedule of available models and replace it with another model, without any prior notice to you. PNC Wealth Management retains the authority to limit the availability of any investment model offered by a Model Provider, or Fund, and/or to terminate or change investment models or Funds when circumstances are such that PNC Wealth Management believes a change is in your best interest. If an investment model or Fund is terminated, PNC Wealth Management will select a replacement investment without any prior notice to you. Certain of these changes will result in an increase/decrease to the fees discussed further herein (see Services, Fees and Compensation – Fees and Expenses). Although you will not be sent an updated Proposal in some circumstances described above, any changes to the Account’s fees will be reflected on future Account statements summarizing the activity in your Account. Before you may establish a Capital Directions Account, you must establish a brokerage account with PNC Wealth Management and agree to the terms and conditions of the PNC Wealth Management Brokerage Account Customer Agreement. By accepting and signing the Investment Management Agreement, you grant discretion over your Account to PNC Wealth Management and you authorize us to invest and reinvest the assets in your Account in a combination of equity securities, fixed income securities, Funds, and other financial instruments in accordance with the Allocation Model that you have selected. The scope of any investment advisory relationship Capital Directions Program October 17, 2025 Page 9 of 36  we have with you is defined in the Investment Management Agreement. When you are enrolled in the Program, we will act as your introducing broker and we will also act as your investment advisor, but only for your Program Account and not for any other assets or accounts, unless otherwise separately agreed to by us in writing. As discussed in more detail below, we earn certain fees and other revenue in connection to our capacity as introducing broker to your account. This is a conflict of interest because we would not earn such fees or revenue if we did not serve as your introducing broker. Our Capital Directions Program advisory relationship with you begins when we enter into an Investment Management Agreement with you, which occurs at the later of the date of acceptance of the signed Investment Management Agreement by PNC Wealth Management or the date on which you have contributed the required minimum level of assets to your Account. Preliminary discussions or recommendations before we enter into an Investment Management Agreement with you are not intended as investment advice under the Investment Advisers Act and should not be relied on as such. The Capital Directions Program is designed for investors who wish to give PNC Wealth Management full discretion to invest the assets in their Accounts according to the asset allocation model selected. Once you are approved for the Program, you will not have the ability to directly buy or sell individual securities in your Account, or to direct your Financial Advisor or any Model Provider to buy or sell securities in your Capital Directions Account. You will not be able to obtain a margin loan using the securities in your Account as collateral. You will retain, however, the ability to place reasonable restrictions on the securities that may be purchased for or held in your Account, subject to the review and approval of PNC Wealth Management as the manager of the Account and based on the investment model selected. In general, you may impose individual security restrictions, including Funds, and specific equity securities or industry restrictions. You may also have the ability to restrict certain bond characteristics, such as years to maturity, credit quality or duration. PNC Wealth Management will determine which specific securities fall within an industry restriction and will implement any industry restrictions in a manner it determines in its sole discretion from time‐to‐time. If an individual security restriction is reasonable, PNC Wealth Management will generally allocate assets that would have been invested in a restricted security to cash or one or more substitute securities, which may include ETFs, on a pro rata basis. Any restrictions you impose on individual securities will not apply to the underlying holdings of Funds. PNC Wealth Management will be responsible for monitoring and maintaining the asset allocation models available through the Capital Directions Program and will have the discretion to buy and sell securities for your Account. Depending on the asset allocation model chosen, PNC Wealth Management will make investments in, without limitation, equity securities, fixed income securities, cash (and/or short‐term investments including, but not limited to, money market funds), Funds, and other financial instruments. PNC Wealth Management may, at its discretion, remove an asset allocation model from the schedule of available models and replace it with another model, without any prior notice to you. If you elect to, you may enroll two or more of your related Program Accounts in a multi‐account management relationship (“MAM”). When you enroll two or more of your Program Accounts in MAM (collectively “MAM Accounts”) PNC Wealth Management will apply a single Allocation Model across all MAM Accounts. All MAM Accounts will be managed pursuant to a single household‐level Allocation Model as shown on your Proposal. Only accounts that you would like managed pursuant to the Allocation Model should be included in the MAM. If you have other managed accounts at PNC Wealth Management that have a different time horizon or risk tolerance, they should not be included in MAM. You will receive a single Quarterly Report for all associated Capital Directions Program October 17, 2025 Page 10 of 36  MAM Accounts. You should be aware that deposits or withdrawals made into a MAM Account will in most cases cause substantial trading in both that account as well as other MAM Accounts in order to keep them allocated pursuant to the Allocation Model in the aggregate. Similarly, adding or removing a Program Account from MAM will in most cases cause substantial trading in all MAM Accounts. Such trading may also result in you incurring redemption fees from certain mutual funds and will result in tax consequences in taxable Program Accounts. MAM is designed to allow flexibility with respect to the placement of assets in different account types for tax efficiency and to use a tax‐aware strategy when making trades in MAM Accounts. If both qualified and non‐ qualified accounts are included in MAM, MAM will utilize an asset location preference where Investment Options are allocated to non‐qualified or qualified accounts based on their relative tax inefficiency (calculated based on the pre‐tax and post‐tax returns that are reported by Fund companies). Some assets tend to be more tax efficient, such as equities and equity‐based Funds, and generally represent greater investment risk. Taxable MAM Accounts generally carry a disproportionate amount of the investment risk in a MAM relationship. You should only combine non‐qualified and qualified accounts in a single MAM relationship if you understand this and are comfortable with this allocation between accounts. You may choose to discontinue MAM with respect to one or more MAM Accounts. In addition, PNCWM may in its discretion elect to discontinue offering MAM. In such event or if any MAM Account’s IMA is terminated for any reason, unless you provide different instructions ahead of the termination, each remaining MAM Account will be rebalanced to individually meet the target Allocation Model. This may cause significant tax impacts to any non‐qualified account. You are urged to discuss MAM with your tax professional. You may also select an optional tax‐overlay service for your non‐qualified Program Account (“Tax‐Overlay Service”). When you select the Tax‐Overlay Service, your Financial Advisor will work with you to establish short and long‐term tax budgets and the Investment Delegate will attempt to manage your Program Account in such a way as to prevent realized short and long‐term taxable gains from exceeding agreed upon budgets. The Investment Delegate will do this by timing the purchase and sales of equity securities in such a way as to attempt to minimize the tax impacts to your Program Account. The Investment Delegate will also actively seek opportunities to realize taxable losses in your non‐qualified Program Account by selling equity securities that have depreciated in value. These realized losses can be utilized to offset realized gains in your Program Account or other taxable accounts. Note that the Investment Delegate will actively seek to realize losses only in equity positions held in Investment Models and will not actively realize losses in Funds held in your Program Account. Additionally, the Tax‐Overlay Service will cause the holdings in your Program Account to deviate from holdings of other accounts utilizing the same Model Provider. Finally, you should be aware that no strategy, including the Tax‐Overlay Service, will prevent the realization of taxable gains from your investments. The Tax‐Overlay Service seeks to minimize the current impact of taxes on your Program Account but will not eliminate the eventual realization of imbedded gains from your Program Account. If you elect to terminate the Tax‐Overlay Service for your Program Account, you need to be aware that any unrealized embedded taxable gains will likely be realized as a result. You should carefully review the unrealized embedded taxable gains in your Program Account before electing to terminate the Tax‐Overlay Service. Withdrawals from your Program Account will likely force the Investment Delegate to liquidate securities and exceed the short and/or long‐term tax budgets. When you select the Tax‐Overlay Service, PNC Wealth Management will review and must approve your Program Account for the service. You may not utilize the Tax‐Overlay Service on any accounts associated in a MAM relationship. PNC Wealth Management, your Financial Advisor and the Investment Delegate do not provide tax advice. If you are considering the Tax‐Overlay Service, you should review your tax situation with your independent tax adviser Capital Directions Program October 17, 2025 Page 11 of 36  to fully evaluate how you may benefit from it. The annual fee for the Tax‐Overlay Service is 0.15% (the “Tax Overlay Fee”) which is calculated and charged similarly to the Program Fee, described in detail below. In certain circumstances, the Tax Overlay Fee may exceed the tax benefit, in any given tax year. You should be aware, although, the Investment Delegate will actively manage taxes only with respect to the equity positions in your Program Account, the Tax‐Overlay Service fee will apply to the full account balance, including assets held in cash, Funds or other non‐equity positions. You may also select one of several responsible investing models (collectively the “RI Models”) made available by PNCWM. In the RI Models, PNCWM seeks to incorporate various responsible investing characteristics as part of the investment selection process. Responsible investing can be defined very differently by individuals, however, at PNCWM, we implement this through our approach to Fund selection. PNCWM utilizes data from Morningstar to assist in assessing the responsible investing characteristics of Funds. PNCWM will seek to include Funds in the RI Models that are intentionally managed using environmental, social, or governance (“ESG”) screening or other values‐based criteria or based on their scores for ESG Risk or Controversy Level, as measured by Sustainalytics, a Morningstar Company. Funds are ranked based on scoring of each Fund’s mandate or investment process as it relates to various responsible investing approaches as well as Morningstar’s analysis of Funds’ holdings, proxy voting history, and performance. In general, Funds exhibiting the following responsible investing characteristics are favored: clear incorporation of ESG criteria in their security analysis and investment decision‐making; seek to have an impact on thematic issues; utilize negative screening to avoid investments that violate norms‐based, faith‐based, or other values‐based criteria; practice a form of active ownership through which they engage with corporate management on ESG issues; have actively supported ESG arrangements through their proxy voting; holding companies with lower risk related to ESG issues or misconduct, as scored by Sustainalytics. Note that funds may exhibit any one or more of the preceding characteristics. Responsible investing priorities are a matter of personal preferences, and there is no assurance that criteria utilized by PNCWM will match your personal responsible investing priorities. You should carefully review the prospectus, Form ADV, or other offering documents for Funds available in the RI Models and evaluate if the Funds’ ESG or other values‐based criteria and strategy match your own priorities. Additionally, you should know that, while Funds may apply responsible investing or ESG criteria to their proxy voting decision making process, where PNCWM votes proxies on your behalf, discussed further below, PNCWM, through its delegate Envestnet, will apply our standard proxy voting policies and will not apply any responsible investing or ESG related criteria to proxies we vote on your behalf in the RI Models. PNCWM expects that the RI Models will typically include one or more Funds without a specific responsible investment mandate. PNCWM will include Funds without a specific responsible investing mandate when we are unable to identify suitable responsible investing Funds to fulfil a particular portfolio allocation. PNCWM does not set a minimum percentage allocation to Funds with a responsible investment mandate for the RI Models. In addition, even if you elect to invest pursuant to an RI Model, you may elect to include certain non‐RI Model Funds in your Program account. Finally, all investment strategies, including responsible investing related strategies, carry the risk of loss, and there is no assurance that a responsible investing strategy can guarantee a profit or protect against loss. In addition, there is no assurance that any responsible investing related strategy, including the RI Models, will provide any investment benefit relative to similarly constructed non‐responsible investing related strategies. In addition to RI Models, PNCWM offers values‐based investments, with categories such as gender, minority, religion, sustainability or environment, which seek to reflect a customer’s values by avoiding or increasing exposure to specific companies, sectors or practices. Certain religious values‐based investment managers invest Capital Directions Program October 17, 2025 Page 12 of 36  in companies that generate income and returns inconsistent with a particular religion’s philosophies. In cases where this occurs, it is the customer’s responsibility to determine the amount, if any, of non‐compliant generated income and/or gains. For more information about how to address these types of non‐compliant income or returns, please refer to the religious values‐based investment’s prospectus or disclosure agreement. Automatic Rebalancing The Capital Directions Program provides automatic rebalancing to ensure that the investments in your Account continue to conform to the selected allocation model. Asset allocations are monitored on a quarterly basis, and generally, we will rebalance an Account if any asset class varies by more than 3% from its target allocation within the model. In lieu of the Program’s default practice of rebalancing on a quarterly basis, you may request that periodic rebalancing for your Account occur on a less frequent basis of either semi‐annually or annually. You should consider, however, that less frequent periodic rebalancing, could cause your Account to diverge from the selected allocation percentages and such divergence could potentially negatively or positively impact performance. In addition to periodic automatic rebalancing, we will also rebalance your Account if you change your investment model, or when contributions to or withdrawals from your Account cause the cash balance to exceed 5% or be less than 0.5%, respectively, of the portfolio value. Occasionally, the total cash balance of your Account can exceed 5% or be less than 0.5%, respectively, of the portfolio value. Occasionally, the total cash of your Account can exceed 5% when Model Providers utilized in your Account hold significant cash in their Investment Model or a Dollar Cost Averaging ("DCA”) method funding has been selected (as further explained below). Further, you may also request, subject to approval by PNC Wealth Management, that an ad hoc rebalance be executed. In order to avoid the expense of inefficient rebalancing, we reserve the right, in our sole discretion, to from time‐to‐time change timeframes for effecting rebalances to your Account as well as the thresholds that must be exceeded before any rebalancing will occur. To rebalance an Account, we buy or sell, as relevant, shares of the individual Funds in an Account until its holdings match the Fund weight percentage specified for the applicable model. Rebalancing transactions are subject to short‐term trading policies, described more fully below, of Funds held in your Account, and, if your account is taxable, will create tax consequences for your Account. Account Statements You will receive a monthly statement following any month in which there is investment activity in your Account, confirming all transactions in your Account, including additions, disbursements, purchases, sales, and advisory fees paid to PNC Wealth Management combined, if applicable with fees paid to Model Providers. For periods in which there is no investment activity in your Account, statements will be provided quarterly. You will also receive a quarterly performance report that tracks the performance of your portfolios against relevant benchmarks. You will be reminded quarterly to contact your Financial Advisor if you should have any questions, or if there have been material changes in your financial goals or needs that would affect your investment strategy. Account Termination Either party may terminate the Investment Management Agreement on 30 days’ written notice to the other party. You are also entitled to terminate such agreement within five (5) business days of your execution of it without incurring a Program Fee, defined below; you may, however, be subject to certain other fees incurred with respect to the Account for the relevant period. Upon the termination of the Investment Management Capital Directions Program October 17, 2025 Page 13 of 36  Agreement, PNCWM will be under no obligation to provide advice on any holdings in your Account. Any transactions executed by you after the termination of the Investment Management Agreement will be subject to fees and commissions described in the PNC Wealth Management Overview of Products and Services (the “Overview of Products and Services”). You may obtain a copy of our current Overview of Products and Services, at any time, by contacting your Financial Advisor, by contacting us at (800) 622‐7086 or online at www.pnc.com/investments‐relationship‐summary. In addition, upon learning of the death of any account owner, PNCWM will immediately terminate the Investment Management Agreement. You should be aware that any transactions executed by your heirs or beneficiaries after your death will be subject to fees and commissions described in the Overview of Products and Services, unless waived by us in our sole discretion. Please see the agreement governing your Capital Directions Program Account for more information. The Investment Management Agreement will continue in effect until terminated by you or PNC Wealth Management upon 30 days’ written notice to the other party. Review of Accounts When you open a Capital Directions Program Account, we review and must approve your investment objectives and strategy for consistency with Capital Directions Program guidelines. Thereafter, we will monitor the Account on an ongoing basis, including its performance, the appropriateness of the individual securities in it, and any investment restrictions that might apply. We will attempt to contact you at least annually, including by mail or email (if you have authorized us to send you electronic communications), to request that you review your Account and inform us of any changes to your financial profile or investment objectives. You should inform your Financial Advisor of any changes to your financial profile or investment objectives as they occur. Your Financial Advisor will communicate any changes about you to PNC Wealth Management. If you elect to utilize an investment model offered by a Model Provider, you will have very limited, if any, direct contact with the Model Provider selected for your Account. Therefore, it is very important that you maintain contact and communication with your Financial Advisor. You should direct any inquiries about your Account, the allocation model or any Model Providers to your Financial Advisor. Finally, your Financial Advisor will be reasonably available to you for consultation about the Account. We encourage you to please contact your Financial Advisor if you have any questions. Securities Transferred into an Account You should be aware that if you transfer securities into a Capital Directions Account, any transferred securities that are not part of the recommended investments for your Account will be liquidated upon or shortly after transfer. Typically, this means that we will liquidate all of the securities you transfer into your account prior to investing your Account in the recommended investments. If your account is not tax‐exempt, you will incur tax consequences as a result of these transactions. You should consult with your tax adviser to review these consequences. Additionally, if you liquidate securities prior to transferring your account to PNC Wealth Management or liquidate your securities prior to establishing your Capital Directions account, you will likely incur transaction costs for those transactions. PNC Wealth Management will not reimburse you for transactions executed at another firm. Please note that if you transfer illiquid securities into a Capital Directions Account, it will delay management of that Account until such securities are transferred out or otherwise removed. You may, at your election, chose an optional Dollar Cost Averaging Capital Directions Program October 17, 2025 Page 14 of 36  (“DCA”) feature when adding funds to your Program Account. With the DCA feature, you have the ability to deploy free cash to your Allocation Model over a defined period and in pre‐determined amounts. The DCA feature can enable clients to slowly invest excess cash over time, rather than make one lump‐sum investment. You have no obligation to complete scheduled DCA transactions and may terminate the DCA feature at any time, by providing notice to us, at least 5 business days prior to the next scheduled DCA transaction. You should know that if sufficient cash is not available in your Account at the time of a scheduled DCA transaction, that transaction, and all future scheduled DCA transactions will be canceled. You should also be aware that cash pending investment under an optional DCA plan will be treated as unallocated cash and swept to a deposit account at our affiliate bank, as described below. The parameters of DCA requests are subject to our approval. Withdrawals from an Account You should also be aware that if you request a withdrawal from a Capital Directions Account, PNC Wealth Management as investment manager, may need to liquidate a portion of the Account to cover the requested withdrawal amount. This will happen, for example, when the cash in your Account is insufficient to accommodate the requested withdrawal. If your account is taxable, you will incur tax consequences as a result. These transactions are subject to short‐term trading policies of Funds held in your account. Liquidation requests are processed according to our standard procedures and your liquidation request may not be completed on the day it was submitted. This is more likely if your request is submitted late in the day or during periods of severe market volatility. Cash is available for distribution three to five business days after the initial request is made, however, you should also be aware that liquidation transactions are at the discretion of the investment manager and could exceed this timeframe. Taxes You need to be aware that the Program operates in a manner that is not a tax efficient investment strategy, especially in taxable accounts, and will likely cause non‐retirement Capital Directions accounts to more frequently experience taxable gains and losses than a brokerage account holding individual securities for the same amount of time. When we, at our discretion, sell securities to rebalance your asset allocation or to adjust your program model, the transaction will likely create a capital gain or loss for you. Additionally, any securities that you sell in order to raise cash to open and or be deposited into your account will likely create a capital gain or loss. These capital gains and losses are in addition to dividends and capital gains paid by the securities in the account. You should consider and discuss the potential tax implications of opening and maintaining a Capital Directions account with your tax adviser. Fees and Expenses You will pay both a program fee (the “Program Fee”) and, if you elect to utilize an investment model offered by a Model Provider, a separate model provider fee (the “Model Provider Fee”) for the services provided under the Capital Directions Program. The Program Fee, Tax Overlay Fee (if the Tax Overlay Service as described above is selected) and Model Provider fee, if applicable, will be combined and reflected on your account statement as the management fee (the “Management Fee”). You should be aware that your account is subject to the Management Fee whether you make or lose money on the investments. Each fee is calculated as a percentage of assets under management and will vary depending on the services provided to you. Generally, you will be charged commissions or service charges for transactions executed prior to establishing your Capital Directions account; you should discuss your options for funding your account with your Financial Advisor. The Program Fee is based on the total assets under management, including any portion of the Account Capital Directions Program October 17, 2025 Page 15 of 36  maintained in cash or in short‐term vehicles including, but not limited to, unallocated cash swept to a deposit account at our affiliate, PNC Bank, or money market funds. As the aggregate market value of the Program Account and if applicable, other managed accounts in the billing household reach a higher tier, as shown in the table below, the assets within that higher tier are charged a lower rate. Our standard Program Fee schedule is as follows: Assets Under Management Maximum Program Fee First $250,000 2.00% Next $250,000 1.75% Next $500,000 1.50% Next $1,000,000 1.25% Next $2,000,000 1.00% Over $4,000,000 Negotiable From time‐to‐time, we offer discounted pricing programs at our discretion. For example, current employees of PNCWM and their immediate family members are eligible for employee pricing. Your Financial Advisor has discretion to negotiate a Program Fee that varies from the standard schedule above. This can depend on certain factors, including the type and size of your Account, the range of services provided and the total amount you or other members of your household have invested with PNC Wealth Management. The Program Fee for your Account is referenced in the fee schedule included as part of the Proposal completed and accepted by you. The Program Fee you pay to PNC Wealth Management for the Capital Directions Program is charged quarterly in advance and will be based on the average daily balance in your Capital Directions Account over the prior calendar quarter or portion thereof (except in the case of a new Capital Directions Account). The Program Fee covers the cost of brokerage commissions and other transaction fees only for transactions executed through National Financial Services LLC (“National Financial”) on an agency basis. With respect to Investment Models, the Investment Delegate will typically route trades to National Financial for execution. From time‐to‐time, the Investment Delegate will trade through broker dealers other than National Financial when the Investment Delegate determines, in its sole discretion that this is in your best interest. Trades executed away from National Financial are described as “trading away” or “step‐out trades.” Model Providers will typically trade away for all trades when implementing trades in a Manager Traded Model. You will bear the cost of any brokerage commissions incurred on transactions executed through other brokers, dealer markups, markdowns and spreads when the Investment Delegate or a Model Provider trades away from National Financial. See the Additional Fees for Brokerage Services and Trading Practices section below for details. In addition to the Program Fee, if you elect to utilize an investment model offered by a Model Provider, you will pay a separate Model Provider Fee for the services provided by the investment manager(s) that provide the investment model(s) you have selected. The Model Provider Fee is based on the average daily balance of assets under advisement invested pursuant to the applicable investment model(s), including any portion of the Account maintained in cash, or in short‐term vehicles including, but not limited to, unallocated cash swept to a Capital Directions Program October 17, 2025 Page 16 of 36  deposit account at our affiliate, PNC Bank, or money market funds, over the prior calendar quarter, or portion thereof. PNCWM will bill Program Accounts on behalf of Model Providers and will remit payment to the appropriate Model Providers on behalf of Program Accounts. PNCWM does not anticipate retaining any portion of the Model Provider Fee. Current Model Provider Fees are set forth in the table below and are subject to change, without notice: Annual Fee 0.4 Annual Fee 0.4 Model Provider Mar Vista Strategic Growth 0.4 0.4 0.4 0.45 0.45 Martin Currie Emerging Markets MFS Large Cap Growth Morningstar All‐Cap Equity Morningstar Dividend Managed Morningstar Dividend Non‐MLP 0.6 0.43 0.5 0.5 0.5 Model Provider AB Concentrated International Growth Equity AB Concentrated US Growth Alger Capital Appreciation Alger Mid Cap Growth Aristotle Value Equity Baird Chautauqua International Growth Equity Baird Mid‐Cap Growth Equity Baird Small/Mid Cap Growth BlackRock Capital Appreciation 0.4 0.4 0.38 0.5 0.5 0.55 0.38 0.27 Morningstar Hare Non‐MLP Morningstar Tortoise Non‐MLP Neuberger Small Cap Intrinsic Value (SCIV) Neuberger Berman International ADR Nuveen Dividend Growth 0.45 0.38 0.4 0.17 0.28 0.27 Nuveen Intermediate Municipal Fixed Income Nuveen Limited Maturity Municipal 0.27 Nuveen Long Term Municipal 0.28 0.15 Nuveen Municipal Ladder 10‐25 Years 0.17 0.15 Nuveen Municipal Ladder 1‐10 Years 0.17 0.17 0.17 0.15 0.38 Nuveen Municipal Ladder 1‐15 Years Nuveen Municipal Ladder 1‐7 Years 0.27 Nuveen Municipal Ladder 5‐15 Years 0.17 0.27 PIMCO 1‐5 yr Corporate Ladder 0.23 0.27 PIMCO Low Duration 0.4 0.5 0.4 PIMCO Municipal Income Opportunity PIMCO Total Return 0.28 0.4 BlackRock Equity Dividend BlackRock Fundamental Core Taxable Fixed Income BlackRock Intermediate Municipal Fixed Income BlackRock Intermediate Taxable Fixed Income BlackRock Laddered Municipal (10‐20 Year) Fixed Income BlackRock Laddered Municipal (1‐10 Year) Fixed Income BlackRock Laddered Municipal (1‐5 Year) Fixed Income BlackRock Large Cap Value BlackRock Long‐Term Municipal Fixed Income BlackRock Short‐Term Municipal Fixed Income BlackRock Short‐Term Taxable Fixed Income BNYM Walter Scott International Stock ADR Boston Partners All Cap Boston Partners International Equity ADR Capital Directions Program October 17, 2025 Page 17 of 36  0.45 0.4 Polen Capital Focus Growth 0.3 Polen U.S. Small Company Growth 0.6 0.45 0.45 0.3 0.3 0.3 Poplar Forest Contrarian Value Partners 0.4 Principal US Small Cap Equity Principal US Small Cap Value 0.38 0.4 Boyd Watterson All ETF Ultra Enhanced Core Boyd Watterson Investment Grade Intermediate Boyd Watterson Limited Duration* Boyd Watterson Ultra Enhanced Core* Brown Advisory Large‐Cap Sustainable Growth Causeway Global Value ADR Causeway International Value ADR 0.45 0.4 ClearBridge Appreciation ESG ClearBridge Dividend ESG Strategy 0.4 0.48 0.25 0.25 ClearBridge Dividend Strategy 0.48 0.15 ClearBridge International Value ADR 0.43 0.15 0.43 0.2 ClearBridge Large Cap Value ClearBridge Small Cap Growth 0.43 0.2 Columbia Contrarian Core 0.48 0.2 Columbia Dividend Income 0.4 0.2 0.2 Dana Large Cap Equity 0.4 Dana Municipal Bond* 0.45 0.2 Dana Small Cap Core Equity 0.3 0.2 Dean Capital Mid Cap Value 0.45 0.2 0.2 Diamond Hill Large Cap 0.4 EARNEST Partners Mid Cap Core 0.48 0.2 EARNEST Partners Mid Cap Value 0.48 0.45 0.3 Earnest Partners Small Cap Core 0.5 QRG QP: Market Series Emerg Mrkts ADR** QRG QP: Market Series Emerg Mrkts ADR ‐ Low Minimum** QRG QP: Market Series Intl ADR** QRG QP: Market Series Intl ADR ‐Low Minimum** QRG QP: Market Series Large Cap Core** QRG QP: Market Series Large Cap Core ‐ Low Minimum** QRG QP: Market Series Large Cap Dividend Income** QRG QP: Market Series Large Cap Dividend Income ‐ Low Minimum** QRG QP: Market Series Large Cap Growth** QRG QP: Market Series Large Cap Growth ‐ Low Minimum** QRG QP: Market Series Large Cap Value** QRG QP: Market Series Large Cap Value ‐ Low Minimum** QRG QP: Market Series Mid Cap Growth** QRG QP: Market Series Mid Cap Value** QRG QP: Market Series Small Cap Core** QRG QP: Market Series Small Cap Core ‐ Low Minimum** QRG QP: Sustainable Emerging Markets ADR Portfolio** QRG QP: Sustainable International ADR** Capital Directions Program October 17, 2025 Page 18 of 36  EARNEST Partners Small Cap Value 0.5 0.3 Federated Core Plus 0.35 0.25 Federated International Strategic Value 0.45 0.25 Federated Strategic Value Dividend 0.4 0.25 0.2 0.2 0.3 0.45 0.095 0.095 0.3 0.3 Franklin Intermediate Fixed Income Franklin Intermediate Muni* GW&K Core Bond* Harding Loevner International Equity ADR Invesco Tax Free Limited Term 0.23 0.45 Ithaka Growth 0.4 0.45 Janus Henderson Mid Cap Growth 0.44 0.45 0.48 0.4 Jennison International Equity Opportunities Jennison Large Cap Growth Equity 0.4 0.48 Jensen Quality Growth Discipline 0.45 0.38 John Hancock US Small Cap Core 0.5 0.38 0.4 0.5 JP Morgan Equity Income Kayne Anderson Rudnick Small Cap 0.5 0.4 0.5 0.4 0.42 Lazard Emerging Markets Equity Select ADR Lazard US Equity Select Tax‐Aware Leeward Mid Cap Value Leeward Small Cap Value 0.4 0.4 0.4 Loomis Sayles Large Cap Growth 0.45 0.55 0.27 0.45 0.27 QRG QP: Sustainable Large Cap Core ‐ Catholic Values** QRG QP: Sustainable Large Cap Core‐ Gender and Diversity** QRG QP: Sustainable Large Cap Core Portfolio ‐ ESG** QRG QP: Sustainable Small Cap Core Portfolio ‐ ESG** QRG: 1‐10 Yr Corp Ladder QRG: 1‐10 Yr Muni Ladder RNC Genter Muni Quality Intermediate Sage Advisory Tactical ETF Core Plus Fixed Income Managed Account Schafer Cullen International High Dividend ADR Managed Account Schroders International Alpha ADR Managed Account Segall Bryant & Hamill Small Cap Growth Managed Account Suncoast Large Cap Growth Managed Account T. Rowe International Core Equity Managed Account T. Rowe Price US Growth Stock Managed Account T. Rowe Price US Value Equity Managed Account T. Rowe US Large‐Cap Core Equity Managed Account The London Company Income Equity Managed Account The London Company SMID Managed Account Tributary Small Cap Core TS&W Mid Cap Value Managed Account 0.4 0.4 Vaughan Nelson Select Managed Account WCM Focused Growth International Managed Account Westfield Mid Cap Growth Equity Managed Account Westwood Small Cap Managed Account 0.45 Lord Abbett Intermediate Tax‐Exempt Fixed Income Lord Abbett Long Tax Exempt Fixed Income Madison Mid‐Cap Equity 0.45 Westwood SMidCap Managed Account 0.45 Capital Directions Program October 17, 2025 Page 19 of 36  *Strategist Traded Model **Tiered Fee Schedule ‐ Maximum Rate is Displayed Calculation of Account Fees The Program Fee and the Model Provider Fee will be paid in advance following the end of each calendar quarter for the upcoming quarter and will be calculated on the last business day of the quarter as follows. The Program Fee is calculated based upon the average daily market value of the total assets in the Account over the prior calendar quarter, including cash holdings. Cash holdings in excess of 7.5% (operational cash purposes i.e., trading and account maintenance needs) will be excluded from the average daily market value calculation when the Program fee is calculated. The Model Provider Fee is calculated based on the average daily market value of assets in the Account invested pursuant to the applicable investment model(s), including any portion of such assets maintained in cash, money market funds or other short‐term vehicles pursuant to the applicable investment model(s), over the prior calendar quarter. Because the Model Provider Fee differs based upon the investment options selected for the Account, the actual aggregate fees charged to the Account will be based upon the fees attributable to the investment options included in the Account at the time of the fee calculation (i.e., the last business day of the calendar quarter). Accordingly, it is important to note that changes in the Account’s asset allocation caused by rebalancing, as well as changes among the types of investment options, during a particular calendar quarter will cause the aggregate of the Program Fee and the Model Provider Fee to be higher or lower than such aggregate amount would have been if calculated based on the composition of the investment options actually held in the Account during the relevant calendar quarter. Upon your request, we will provide you with a detailed explanation of the fee calculation which will allow you to recalculate the fees should you so desire. If your Account is new, you will pay an initial fee after the date that National Financial, the custodian, receives the initial assets of your Account. An adjustment to the next quarterly fee will be made for any significant contributions or distributions that occur during the inception quarter of your Account. With your initial contribution and for any additional contribution or distribution adjustments, your fee will be calculated for that portion of the ongoing quarterly Program Fee that relates to the number of days remaining in the calendar quarter as of the date your Account becomes subject to the Investment Management Agreement or that you make the additional contribution or distribution, as applicable. This Program Fee will be based on the total market value of assets in your Account on that date. If your Account is terminated by you or PNC Wealth Management during a calendar quarter, the fee for that quarter will be prorated over the number of days that the Account was open during the quarter. Any overpayment will be refunded to you after the Account is closed. Fees are not prorated for contributions or withdrawals made during a calendar quarter, except in the case of a new or terminated Account, as outlined above. If you terminate your Capital Directions account within 90 calendar days of initial investment, PNC Wealth Management reserves the right to charge you commissions, according to the Overview of Products and Services, for transactions executed on your behalf during the time your account was managed, less any pro‐ rated advisory fee paid by you. Additional Fees for Brokerage Services PNC Wealth Management will charge its standard fees for additional brokerage account services that are not Capital Directions Program October 17, 2025 Page 20 of 36  included in the Program. Such fees include, but are not limited to, account termination/transfer fees (i.e., account transfer), wire transfer fees, IRA fees and stop payment fees. You should be aware that in some cases, PNCWM retains this entire fee or marks up the fee our clearing firm, National Financial, charges to PNCWM for these services. This is a conflict of interest for us because PNCWM has an incentive to utilize a clearing firm that allows us to mark‐up designated fees. PNCWM also has incentive to recommend to you services that have been marked‐up. Please refer to the Account Level Fees section of the Overview of Products and Services for details. Deduction of Account Fees All fees incurred by the Account will be paid from the cash balance or by selling shares of a money market mutual fund. If the Account does not have a sufficient cash balance or enough money market mutual fund shares to cover the fees, we will liquidate other securities as necessary to pay them. Selling securities to pay fees is subject to the short‐term trading policies of Funds and, if your account is taxable, will create tax consequences for you. You may contact your Financial Advisor if you have any questions regarding the fees charged to your Account. Clients who opened accounts in the Capital Directions Program prior to January 2, 2015 and who have not previously authorized PNC Wealth Management to adjust your Program Fee may be subject to a Legacy Fee Arrangement which varies from the schedule above (“Legacy Fee Arrangement”). Please note that the authorization to adjust the Program Fee may have been obtained via negative consent. The Legacy Fee Arrangement, if applicable, is outlined in your investment management agreement. At the sole discretion of PNC Wealth Management, certain other Accounts converted from the Strategic Directions or Premier Directions Programs as of October 1, 2015 may also be subject to a Legacy Fee Arrangement. Other Expenses Each Fund in which your Account is invested charges its own separate fund‐level fees and operating expenses, including, for example, administrative, custody, transfer agent, legal and audit fees and expenses, investment advisory or management fees, shareholder servicing fees, omnibus accounting fees, fees for sub‐administration, recordkeeping, print mail services and other expenses. These fees and operating expenses are ultimately borne by the shareholders invested in the Fund, including you, and will reduce your investment returns. Other classes of mutual funds have lower fund‐level fees and expenses than those used in this Program. Please review the relevant Funds’ prospectuses for a full explanation of fund expenses and charges. PNC Wealth Management includes in the Program only “Approved Share Classes” of mutual funds, which are share classes that generate revenue sharing payments, as described below, to PNCWM. PNCWM will select Approved Share Classes that are either (i) share classes that trade on our custodian’s Institutional No‐ Transaction Fee platform (“INTF Eligible” share classes); or (ii) if no such INTF Eligible share class is available, the least expensive non‐INTF Eligible share class eligible for inclusion in the Program. PNC Wealth Management uses INTF Eligible share classes in order to reduce PNC Wealth Management’ overall program trading costs, which costs would otherwise be payable by PNC Wealth Management. These selection criteria represent a conflict of interest for us because they enable PNC Wealth Management to avoid costs, but also may result in you purchasing a share class that is more expensive than other share classes of the same fund for which you are eligible. You acknowledge that when you establish a Program Account, you authorize and direct PNC Wealth Management to purchase for your Account only Approved Share Classes using the criteria described above and you waive any obligation of PNC Wealth Management, if applicable, to purchase any other share classes for your Capital Directions Program October 17, 2025 Page 21 of 36  Account, even if less expensive share classes are available. A higher cost share class will adversely affect the investment performance of your account. INTF Eligible share classes do not typically charge shareholders 12b‐1 fees or pay those fees to us or our custodian, which reduces costs to you, as compared to share classes that do pay 12b‐1 fees. As described more fully below, money market funds held in your Account typically charge 12b‐1 fees, but we will rebate any such fees we receive. Please note that the mutual funds included in the Program may provide compensation such as fees for omnibus accounting, sub‐administration, shareholder services, recordkeeping, print mail services or other related fees (“Mutual Fund Compensation”). While we do not expect to receive such fees, PNC Wealth Management will credit to your Account any Mutual Fund Compensation or 12b‐1 fees paid to us in connection with the holdings in your Account. Our custodian or other entities not affiliated with PNC Wealth Management may receive Mutual Fund Compensation. PNC Wealth Management is not a party to such arrangements and we will not credit your Account for Mutual Fund Compensation received by such entities. You should be aware that any Mutual Fund Compensation paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. Exchange‐traded funds, or ETFs, are similar to mutual funds in that they invest in a basket of securities, such as stocks, bonds, or other asset classes. Unlike mutual funds, however, ETFs trade on an exchange and their price can change throughout the day and may vary from the value of the underlying assets in the investment portfolio. There are three different types of ETFs: Index based or Passive – which track a specified index such as the S&P 500 or NASDAQ Composite Index, Smart beta – which invest in factors through a rules‐based index (low‐ volatility, equal‐weight, etc.), and actively managed – which are not tied to an index and offer portfolio manager flexibility and security selection with the intent to outperform a benchmark. Most ETFs publish their holdings daily. ETFs have internal operating expenses that reduce investment returns. Active ETFs generally, have higher internal operating expenses than other ETF types. ETFs typically have lower expenses than mutual funds that are actively managed. However, even though a mutual fund in the same asset class as an ETF may be more expensive, other factors such as ETFs that trade less frequently could make a mutual fund more advantageous. PNC Wealth Management receives an annual credit from National Financial (the “ETF Revenue Share Credit”). The ETF Revenue Share Credit is projected based on future sales of actively managed ETFs through National Financial. PNCWM's receipt of the ETF Revenue Share Credit is dependent on National Financial sharing a portion of its actively managed ETF revenue. With the receipt of the ETF Revenue Share Credit, we are incentivized to recommend actively managed ETFs over other ETFs and products in which we either receive less or no revenue share as compared to the ETF Revenue Share Credit. We are also incentivized to select and continue our relationship with National Financial to receive the ETF Revenue Share Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. We will retain the ETF Revenue Share Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the ETF Revenue Share Credit. You should be aware that any ETF Revenue Share Credit paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. PNC Wealth Management receives an annual credit from National Financial (the “Business Development Credit”). PNCWM is incentivized to select and continue its relationship with National Financial to receive the Business Development Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. The Business Development Credit is not related to the sale or offer of any specific Capital Directions Program October 17, 2025 Page 22 of 36  products or services, nor is it dependent upon assets under management. If received, we will retain the Business Development Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the Business Development Credit. Additionally, if under certain circumstances our clearing arrangement with National Financial is terminated prior to the expiration of our agreement, PNCWM is subject to certain contractual fees and penalties (collectively, the “Termination Fee”). The Termination Fee creates a strong disincentive for PNCWM to consider clearing relationships other than National Financial. This creates a conflict of interest for us as we expect to benefit from the continued recommendation of National Financial as our clearing firm. Additionally, PNCWM is further incentivized to continue the relationship with National Financial as we may not receive the same incentives from other clearing firm arrangements, such as receiving particular credits from National Financial or having the ability to mark‐up certain fees to clients. PNC Wealth Management receives additional compensation, referred to as revenue sharing, from the advisors or distributors of the mutual funds offered in the Program, which compensates us for administrative services we provide to them and is based on the amounts our customers invest in those mutual funds in the Program. Our independent due diligence process for selecting mutual funds and ETFs for the Program is designed so that products are selected based on objective, investment related criteria and does not take into account compensation to PNC Wealth Management. However, only funds for which we receive revenue sharing are considered for inclusion in this due diligence process. This is a conflict of interest for us because mutual funds and or certain ETFs that may otherwise meet our investment criteria are not included in the Program because their advisors or distributors do not offer revenue sharing to PNC Wealth Management. In addition, we receive a higher revenue share amount on mutual funds than ETFs. This is a conflict of interest for us when there are similar products offered in both product categories as we will be paid more revenue share when recommending mutual funds than if an ETF is recommended. We will not credit your Accounts for any revenue sharing payments we receive. Although we include only mutual funds and certain ETFs whose sponsors pay PNCWM revenue sharing, we believe this conflict is mitigated by the large and diverse universe of Funds we make available in our programs which meet our clients’ needs. Your Financial Advisor is not paid any part of the revenue sharing arrangements. You should also be aware that we will liquidate mutual funds and or certain ETFs held in your Account if the advisors or distributors of those funds discontinue their participation in our revenue sharing program. If your Account is taxable, you will have tax consequences as a result of such liquidations. PNC Wealth Management offers other advisory programs that include Funds whose advisors and distributors do not participate in revenue sharing. You can discuss our other advisory program options with your Financial Advisor if you wish to invest in Funds outside our revenue sharing program. We will not credit your Account for any revenue sharing payments we receive. For details on revenue sharing received by PNC Wealth Management from mutual fund and certain ETF advisors or distributors, please see the following link: https://www.pnc.com/content/dam/pnc‐com/pdf/personal/wealth‐management/Additional‐Compensation‐ Disclosure.PDF For more information around the compensation a particular mutual fund or ETF provider may pay, please refer to the Fund’s prospectus and/or Statement of Additional Information. Additionally, some Funds impose redemption fees depending on the share class, if they are redeemed within a specified time period, to discourage short‐term trading or for other reasons. The relevant Fund company retains these redemption charges from the proceeds of the redemption for the benefit of the remaining shareholders of the Fund. Refer to the prospectus or Statement of Additional Information of relevant Funds for details on each Capital Directions Program October 17, 2025 Page 23 of 36  Funds’ short‐term trading policies. The amount of such fees and charges retained will be reflected on your account trade confirmations. Purchasing securities in the Program may cost you more or less than purchasing the securities directly from the funds or through agents of the funds without enrolling in the Program, including through a brokerage account at PNC Wealth Management. By purchasing mutual funds outside of the Program, you may invest in a single fund family and obtain “breakpoints” that could lower the cost of the Funds. However, if you purchase mutual fund shares directly, you may not receive the asset allocation and account monitoring services available via the Program and may not qualify to invest in share classes available to investors through the Program. In addition, mutual funds purchased outside the Program may charge commissions, front‐end or back‐end sales charges, and redemption fees, depending on the share class. Finally, your Account may be invested in Funds for which PNC Wealth Management or one of our affiliates acts as an advisor, sub‐advisor, or administrator, and receives a fee for such services. Therefore, PNC Wealth Management or an affiliate receives fees for the services provided to the Funds. The level of advisory or sub‐ advisory fees paid to PNC Wealth Management or its affiliates by such Funds, is disclosed in the Prospectus and/or Statement of Additional Information of such Funds. The maximum amount of your Account assets that may be invested in Funds, which pay advisory or sub‐advisory fees to PNC Wealth Management or its affiliates will depend on many factors, but in certain circumstances may reach 100% of your Account assets. You should ask your Financial Advisor about these advisory or sub‐advisory fees, and you may terminate your Investment Management Agreement with PNC Wealth Management at any time if you have any concerns about the level of these fees or the incentives that they create. PNC Wealth Management has an obligation to invest your assets in a manner that considers your best interest. To that end, PNC Wealth Management will take steps to minimize potential conflicts of interest that arise from investing with Funds that pay PNC Wealth Management or its affiliates advisory or sub‐advisory fees, to the extent required by applicable federal or state laws. PNC Wealth Management evaluates the appropriateness of investing your assets in Funds managed by affiliates of PNC Wealth Management, in the same manner as it evaluates all other Funds available through the Program. Cash Balances Unallocated cash will be automatically swept through the Bank Deposit Sweep Program (“BDSP”) into an interest‐bearing deposit account (“Deposit Account”) at our affiliate, PNC Bank (and, as noted above, are included in the assets on which Management Fees are charged). The interest rate (“BDSP interest rate”) for BDSP assets held in the Deposit Account is determined by PNC Bank with input from PNC Wealth Management such as objective competitive market data. BDSP is the only cash sweep option available to your Program Account. The only exception is in very limited situations where your account type is not eligible for BDSP (such as participant accounts of employer sponsored qualified plans) and your funds will be invested in a money market mutual fund selected by us. You should be aware that although assets held in the Deposit Account are protected by FDIC insurance neither PNC Wealth Management nor PNC Bank will monitor whether BDSP deposits, individually or in combination with other deposits you hold at PNC Bank, exceed FDIC insurance limitations. You should review your cash balance held in the Deposit Account and other PNC Bank accounts to ensure that cash balances do not exceed FDIC insurance coverage levels, or alternatively, in the event your cash balance exceeds FDIC insurance limitations, that you are comfortable with the risks associated with having uninsured cash. The rate of return you receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to such cash Capital Directions Program October 17, 2025 Page 24 of 36  balances. PNC Bank uses the BDSP program assets to fund its lending activities, allowing PNC Bank to earn revenue based on the difference between the rate paid to you and the higher rate of interest earned by lending the assets to its customers. Moreover, PNC Wealth Management receives revenue from PNC Bank based on the assets in the BDSP, this revenue amount varies depending on market conditions, but will not exceed the current Federal Funds Target Rate Range – Upper Limit rate (available online at https://fred.stlouisfed.org/series/DFEDTARU) plus 0.50%. This means PNC Wealth Management benefits in two ways from placing assets in the BDSP (i.e., the Management Fee and the revenue share from our affiliate). We will not credit any portion of this revenue to your Program Account. Note that the revenue earned by PNC Wealth Management and our affiliate PNC Bank will significantly exceed the interest credited to your Program Account from the allocation to BDSP. The revenue we receive is a conflict of interest for us, because we, and our affiliate, PNC Bank, obtain a financial benefit when your unallocated cash is held through the BDSP in a Deposit Account. This financial benefit is greater than the financial benefit we would receive if your unallocated cash was invested through a different cash sweep vehicle such as a money market fund. For information pertaining to the interest rate spread earned by PNC on all loans, including those generated from BDSP assets, please see the Net Interest Margin discussion in the most recent Annual Report on Form 10‐K and subsequent Quarterly Reports on Form 10‐Q for The PNC Financial Services Group, Inc., available at, https://investor.pnc.com/financial‐information/financial‐results. Account assets invested through the BDSP typically will pay you less interest – and in some market conditions, much less interest – than they would if invested in alternative cash sweep vehicles that are available to PNC Wealth Management such as a money market fund. Accordingly, you should not participate in the Program if you wish to hold your unallocated cash in another sweep vehicle. (Please note that while BDSP is used as the sweep option to hold unallocated cash, if your account has an investment allocation to cash, that allocation will typically be held in money market mutual funds or other short duration securities.) The rate of return you receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to such cash balances. You should also know that Model Providers utilized in your Program Account will have discretion to select the vehicle (BDSP, money market mutual fund or other short duration security) for any cash in the Investment Model. For more information regarding BDSP, including information about FDIC insurance limitations, please see the PNCWM BDSP Disclosure Document, you may also review the current BDSP interest rate at the following link: https://www.pnc.com/en/personal‐banking/investments‐and‐retirement/sweep‐program‐ rates.html. Additionally, information about FDIC insurance can be found on https://www.fdic.gov/resources/deposit‐insurance/ Financial Advisor Compensation A portion of the fees charged for Program services generally will be paid to your Financial Advisor in connection with opening your Account, as well as for providing client‐related services within the Program. This compensation may be more or less than a Financial Advisor would receive if you transacted in a brokerage account, rather than a managed account in the Capital Directions Program, and paid separately for investment advice, brokerage and other services covered by the Program Fee. Therefore, your Financial Advisor may have Capital Directions Program October 17, 2025 Page 25 of 36  greater financial incentive to offer a managed product over a brokerage product. As disclosed above, certain of our Programs charge a negotiable Program Fee and others charge a negotiable Program Fee plus a Model Provider Fee, which in certain circumstances may be waived but is not negotiable. Differences in fees for Model Providers in Programs with a third‐party manager, or the absence of such fees in any Program, create a conflict of interest as such differences provide an opportunity for Financial Advisors to negotiate a higher Fee for a strategy with lower or no separate Model Provider Fees than they would for strategies that charge a higher Model Provider Fee. The opportunity to negotiate a higher fee also creates a financial incentive for Financial Advisors to recommend such Programs and/or Model Providers. The ability of the Financial Advisor to negotiate a higher Program Fee in these circumstances also provides a financial benefit to PNC Wealth Management, which retains a portion of the Program Fee. Occasionally, Program Accounts may be reassigned from the originating Financial Advisor to a new Financial Advisor because the originating Financial Advisor leaves our firm, takes a new position, or for other reasons. Financial Advisors receive less compensation for accounts reassigned to them (“Reassigned Accounts”) than accounts they originated and therefore have a conflict of interest because they have a financial incentive to provide better service to accounts that they have originated versus Reassigned Accounts. Financial Advisors receive additional compensation when clients add funds to Reassigned Accounts and have incentive to encourage additional deposits to Reassigned Accounts. PNC Wealth Management has established policies and procedures reasonably designed to ensure that any recommendation made is suitable for your unique circumstances. PNC Wealth Management may advance to Financial Advisors a portion of the first year’s estimated fees for clients who invest in the Program. In addition, certain Financial Advisors who typically work with higher net worth clients can earn enhanced upfront compensation when customers establish a new advisory account or add new assets into an existing advisory account with us. This compensation creates a conflict of interest because these Financial Advisors have an additional incentive to encourage clients to place their funds in investment advisory accounts. From time‐to‐time, PNC Wealth Management initiates incentive programs for its employees including Financial Advisors. These programs include, but are not limited to, programs that compensate them for attracting new assets and clients, or for referring business to our affiliates (such as referrals for mortgages, trusts, or insurance services); programs that reward them for promoting investment advisory services, in some circumstances by enhancing revenue credits paid to them in connection with new advisory accounts or additions to existing advisory accounts, for participating in advanced training, and for improving client service; and programs that reward Financial Advisors who meet total production criteria. Financial Advisors who participate in these incentive programs are rewarded with cash and/or non‐cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. These programs may be partly subsidized by external vendors or our affiliates, such as mutual fund companies, insurance carriers or money managers. Therefore, our Financial Advisors have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services that we offer. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients The minimum account size for the Capital Directions Program is $50,000. We may terminate the advisory services on any Account that falls below minimum account value guidelines established by the firm on 30 days’ Capital Directions Program October 17, 2025 Page 26 of 36  written notice to the Account holder. To avoid termination, you may be required to deposit additional assets in your Account to remain in the Capital Directions Program. Under certain limited circumstances, we may waive the minimum account size requirement. If your Account was opened prior to October 1, 2015, the minimum account size for your Account prior to October 1, 2015 will continue to apply to your Account. In addition, Model Providers utilized for the Program typically impose their own investment minimums and may limit or terminate the availability of their model for Accounts that fall below this minimum with 30 days’ notice to PNC Wealth Management. Upon receipt of such account minimum notices from a Model Provider, PNC Wealth Management will use commercially reasonable efforts to identify another Model Provider that is consistent with or substantively similar to the model and/or Model Provider that has terminated the availability of their model and resume a continuous investment program for the Account. PNC Wealth Management will have limited or no ability to waive Model Provider minimums. Collateral Accounts Under certain circumstances you may elect to pledge the assets in your non‐IRA/ERISA Account as collateral for a general purpose loan with our affiliate, PNC Bank, or other financial institution (collectively the “Lending Arrangements”). When your Account assets are pledged or otherwise used as collateral in connection with Lending Arrangements, you give the lender certain rights and powers over the assets in the Account. Importantly, lenders have the right to direct PNC Wealth Management to sell or redeem any and all assets pledged as collateral for the loan. In the event of a collateral call on the Account, securities will be liquidated from the Account, which may be contrary to your interests and/or inconsistent with the investment strategy for the Account because positions may be redeemed or liquidated more rapidly (and/or at significantly lower prices) than might be desirable. You or your Financial Advisor may not be provided with prior notice of the liquidation of the securities in the Account. Furthermore, you and your Financial Advisor may not be entitled to choose the securities to be liquidated. After the execution of a collateral call, any remaining securities in the Account may be lower in value than the investment minimums required for the Capital Directions Program and the Account may be subject to termination as described above. You may wish to discuss with your Financial Advisor how a collateral call could impact you if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. Any action taken by us, or an affiliate, with respect to the assets held in your Account pursuant to the Lending Arrangements will not constitute a breach of our fiduciary duties as an investment adviser to you under the Capital Directions Program. The costs associated with the Lending Arrangements are not included in the Program Fee you pay under the Program. Your transaction costs may rise as a result of a collateral call, because securities may be liquidated under unfavorable market conditions. You should consult with your own independent tax adviser in order to fully understand the tax implications associated with the Lending Arrangements. The securities subject to the collateral call will not be liquidated in a manner that considers tax efficiency. PNC Wealth Management does not provide legal, tax or accounting advice. You are encouraged to speak with your Financial Advisor to the extent you have questions about the Program, the Lending Arrangements and how they may impact the management of your Account. You should be aware that PNC Wealth Management and your Financial Advisor have a conflict of interest because PNC Wealth Capital Directions Program October 17, 2025 Page 27 of 36  Management and your Financial Advisor’s compensation is based on the assets held in your account and benefits if you enter into a Lending Arrangement instead of withdrawing funds from your account. In addition, you should be aware that PNC Wealth Management and your Financial Advisor will be compensated based on the amounts you draw on the credit line. This is a conflict of interest for your Financial Advisor because he or she has an incentive to recommend Lending Arrangements as opposed to other potential funding sources, because your Financial Advisor is not compensated for other options. In addition, PNC Bank generates revenue by charging interest on any loan underwritten by PNC Bank, which represents a further conflict of interest for PNC Wealth Management. Qualification criteria and requirements, including but not limited to, approval criteria, underwriting standards, loan to value requirements, maintenance requirements and asset eligibility vary by program. You should refer back to the Lending Arrangements and associated documents for the specific terms governing the Lending Arrangements. PORTFOLIO MANAGER SELECTION AND EVALUATION The Capital Directions Account is managed to diversify your investments and may include investments in equity and fixed‐income securities, options, Funds and money market instruments. Accounts are managed on an individual basis, and our asset allocation and investment recommendations are determined by and based on our understanding of your financial situation, investment objectives and risk tolerance. You may impose further reasonable restrictions and guidelines on your Account, but these will affect the composition and performance of your portfolio. Fund and Model Provider Selection and Evaluation We select the investments and Model Providers that are available in the program. The factors influencing the inclusion of any investment model or Fund on our list of recommended investments may include, among other things, past performance, management style, quality of the relevant Model Provider or Fund manager, its investment process, the number and continuity of investment professionals, and its client servicing capabilities. While PNC Wealth Management is the sole sponsor of the Program, we receive research and assistance in selecting and reviewing Model Providers, investment models, mutual funds and ETFs from the Private Bank division (the “Private Bank”) of our affiliate PNC Bank and Morningstar, Inc. as well as other non‐affiliated third parties (collectively, “Research Partners”). If applicable, expenses for these services are paid by PNC Wealth Management. We also rely on the Research Partners for research and assistance in selecting and reviewing investment models, mutual funds and ETFs for the Program. These services may include products of non‐ affiliated Research Partners which creates a conflict of interest since the Research Partner would benefit when its products are included in the Program. In order to help mitigate this conflict, our independent due diligence process for selecting mutual funds and ETFs for the Program is designed so that products are selected based on objective, investment related criteria and does not take into account any sort of compensation to PNC Wealth Management. We or the Private Bank may ask a relevant Model Provider to provide us with a completed questionnaire, database information on the firm and statistical analysis of the Model Provider or Fund manager’s track record. We, Morningstar or the Private Bank may also conduct interviews with members of the Model Provider or Fund manager’s management. This process is an ongoing one, and investment models and Funds are added or removed from the Program based on many factors, either internal or external to a Model Provider or Fund manager’s management. Returns reported by Model Providers are derived from sources believed to be reliable, but we make no representations or warranties as to the accuracy of such performance Capital Directions Program October 17, 2025 Page 28 of 36  information. The Program and other wrap programs we recommend includes products managed by investment management affiliates of PNC Wealth Management, which receive compensation for their investment advisory and other services. The services provided by our affiliates and the fees they collect for these services vary and generally are disclosed in each Fund’s prospectus. These fees are paid directly by the Fund and affect the total return of a shareholder’s investment. We will not treat those entities and Funds any differently from investment managers and Funds that are not affiliated with PNC Wealth Management. PNC Wealth Management and Other Service Providers to the Program PNC Wealth Management was formed in 2003, and is a direct, wholly owned subsidiary of PNC Bank. PNC Bank is a wholly owned subsidiary of The PNC Financial Services Group, Inc., a financial holding company. PNC Wealth Management is registered with the SEC as an investment advisor and a broker‐dealer. PNC Wealth Management is a member of FINRA and SIPC and serves as the sponsor of the Program. PNC Wealth Management does not receive performance‐based fees calculated as a share of capital gains on, or capital appreciation of, the funds or any portion of the funds or other investments in a client’s Account. National Financial provides trading, custody and operational services for the Program. National Financial carries client Accounts, is the custodian for the investments in your Account, reports all the trades in your Account and effects many such trades. National Financial will provide you with trade confirmations, monthly statements, and income tax reporting. PNC Wealth Management has also engaged a service provider to perform certain support services in connection with the Program, including account rebalancing for the asset allocation models. This service provider is also responsible for calculating and preparing quarterly performance reports for client accounts. Risks of Investing in the Capital Directions Program Investing in securities, including the investments offered through the Program, involves risk of loss that you should be prepared to bear. There is no guarantee that the elements of the Program, including the asset allocation models, selection of investment manager models and/or research recommendations will protect against such loss. Other risks include:  Market Risk. Market risk is the risk that the price of securities will fall over short or extended periods of time. Historically, the prices of equity securities have moved in cycles, and the value of an Account’s investments will fluctuate from day to day. When individual companies are negatively impacted by industry or economic trends or report poor operating results, the price of securities issued by those companies will typically decline in response. These factors contribute to price volatility.  Allocation Risk. A client Account is subject to the risk that asset allocation decisions will not anticipate market trends correctly. For example, weighting an Account too heavily in equities during a stock market decline may cause a loss of value. Conversely, investing too heavily in fixed income securities during a period of stock market appreciation may result in lower total returns.  Credit Risk. The value of debt securities is affected by the ability of issuers to make principal and interest  payments. If an issuer cannot meet its payment obligations or if its credit rating is lowered, the value of its debt securities will typically fall. Interest Rate Risk. The value of fixed‐income investments will typically decline because of an increase in Capital Directions Program October 17, 2025 Page 29 of 36   market interest rates. In addition, in certain low‐yield interest rate environments, some short‐term investments may produce negative yield, after accounting for fees, inflation and other expenses. Liquidity Risk. The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in unusually wide bid‐ask spreads or large price movements (especially to the downside).  Stock-Specific (Unsystematic) Risk. Unsystematic risk is unique to a specific company or industry. Also known as “nonsystematic risk,” “specific risk,” “diversifiable risk” or “residual risk,” in the context of an investment portfolio, unsystematic risk can be reduced through diversification. The Program is intended to be a long‐term investment program and does not support market‐timing or frequent trading. You will be limited to one model change per calendar quarter, except as warranted by changes to your financial situation as agreed by you and your Financial Advisor. In addition, you will be limited to one investment manager model change per asset class per quarter, except as may be agreed by you and your Financial Advisor. Frequent or excessive trading in Capital Directions accounts is grounds for account termination, with 30 days’ written notice, by PNC Wealth Management, even if the rules above are not violated. The determination of frequent and/or excessive trading is solely at the discretion of PNC Wealth Management. Trading Practices PNC Wealth Management is an introducing broker‐dealer, clearing transactions related to the Program Accounts through National Financial. PNC Wealth Management has a best execution committee (“BEC”) that meets regularly to rigorously review data for equity orders executed by National Financial including those orders that are sent by the Investment Delegate. Such data includes, among other things, speed of execution and price improvement provided by the execution venues selected by National Financial. PNC Wealth Management does not receive any payment for order flow from the execution venues. The BEC also reviews data for fixed income trades executed through trading systems used by PNC Wealth Management to ensure that the net prices obtained are reasonable under the circumstances. The Program Fee includes the costs of trades executed only for transactions executed through National Financial on an agency basis. The Program Fee does not include any additional trading expenses incurred when the Investment Delegate determines to trade away from National Financial, for trades executed in Manager Traded Models (as decided by the Model Providers) or for transactions where National Financial acts as principal. The Investment Delegate will trade away from National Financial when the Investment Delegate determines it is in your best interest to do so. This can occur when the Investment Delegate is implementing a model change simultaneously across accounts with many different introducing firms, such as PNC Wealth Management. In these instances, the Investment Delegate may group together trades from several different introducing firms and execute those trades through a single broker‐dealer. This process is known as Block Trading (“Block Trading”). Block Trading is intended to reduce the market impact of executing large transactions in a particular security and can allow clients to get better overall execution prices than if the trades were placed individually. The Investment Delegate may also trade away from National Financial when it determines that a broker‐dealer other than National Financial is capable of obtaining a better execution price for the trade. This can typically occur in thinly traded securities or in fixed‐income securities. Additionally, Manager Traded Models are implemented directly by the Model Provider rather than by PNC Wealth Management or the Investment Delegate. A Model Provider of a Manager Traded Model may trade away from National Financial for the same reasons as described above. Model Providers historically implement substantially all trades in Manager Traded Models away from National Financial. Model Providers for Manager Traded Models typically trade fixed income Capital Directions Program October 17, 2025 Page 30 of 36  securities away from National Financial. These trades will incur additional costs per bond or on a per transaction basis. These costs are embedded in the net price you receive and are not separately disclosed by the executing broker in your confirmation or statement. PNCWM does not receive any benefit when the Investment Delegate or Model Providers elect to trade away. In either case, it is important that you understand that you will pay any commissions, mark‐ups or mark‐downs incurred, in addition to the Program Fee when the Investment Delegate or a Model Provider elects to trade away from National Financial or for transactions where National Financial acts as principal. For additional information on the trading practices of the Investment Delegate and the Model Providers, please see the following link: https://www.pnc.com/content/dam/pnc-com/pdf/personal/wealth-investments/PNCWM/Trade- Practice-Disclosure.pdf. Information regarding Investment Delegate and Model Provider trading practices is based upon data provided to us by both the Investment Delegate and the Model Providers. We make no representations regarding the accuracy of the information presented and cannot guarantee that the trading practices reflected in the information presented will be followed by the Investment Delegate or Model Providers in the future. You should be aware that certain Model Providers provide their model portfolio updates to the Investment Delegate after they make changes to accounts that they manage directly. In these instances, this will impact execution prices for your Account relative to other accounts in the same investment strategy that are managed directly by the Model Provider. Depending on various factors, including price movements and variations in trade execution, the performance of your Account will differ from, and be better or worse than, the performance of such other accounts managed directly by the Model Provider. You should also review the Form ADV Part 2 for the Investment Delegate and, if applicable, the Model Provider you have selected, for additional information regarding that firm’s execution practices. Proxy Voting PNC Wealth Management will vote all proxies for securities held in the Program Account on your behalf, unless you direct otherwise. PNC Wealth Management has retained and delegated our proxy voting power to Envestnet, a third‐party service provider, to receive proxy statements and to vote shares. Envestnet votes proxies based on the recommendations of Glass‐Lewis & Co. (“Glass‐Lewis”), an independent third‐party research provider. Glass‐Lewis issues voting recommendations based on its own internal guidelines, which assist in limiting possible conflicts of interest in voting your proxies. We will not vote proxies in accordance with voting instructions received from you. PNC Wealth Management has adopted policies and procedures to address any conflicts that arise in connection with voting proxies. PNC Wealth Management may depart from its stated guidelines in order to avoid voting decisions believed to be contrary to the best interests of its clients. More information regarding our policies and procedures regarding proxies can be obtained by contacting your Financial Advisor or by calling PNC Wealth Management at (800) 622‐7086. If you choose, you may request to vote your own proxies by providing us with written instructions to deliver all proxy related materials directly to you for consideration and execution. If you choose this option, proxy materials typically will be forwarded to you by the custodian for your Account. If this option is selected, PNC Wealth Management, or its third‐party service provider, will no longer be in a position to vote proxies for any securities for your Account, including securities over which PNC Wealth Management has investment discretion. Capital Directions Program October 17, 2025 Page 31 of 36  PNC Wealth Management will not advise or act for you with respect to any legal matters for securities held in your Account, including class actions or bankruptcies. Documents received with respect to such matters will be forwarded directly to you for your consideration. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS As part of the acceptance and approval process, and by signing the Investment Management Agreement, you grant us discretionary trading authority over your Account. PNC Wealth Management utilizes information regarding your financial circumstances, investment goals and objectives and any special written instructions you may wish to give regarding your Account. CLIENT CONTACT WITH PORTFOLIO MANAGERS Your Financial Advisor will communicate any changes about you to PNC Wealth Management. You will have very limited, if any, direct contact with the individuals responsible for making investment decisions for the Program and will have no direct contact with the provider of any Manager Model you might select. You should direct any inquiries regarding the investment manager to your Financial Advisor. ADDITIONAL INFORMATION Disciplinary Information  On April 11, 2016, PNC Wealth Management entered into a settlement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that it failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales and failed to apply such waivers to mutual fund purchases by certain retirement plan customers that were eligible to purchase Class A shares in certain mutual funds without a front‐end sales charge. The findings also stated that PNC Wealth Management failed to maintain adequate written policies and procedures or to provide adequate training to assist financial advisors in determining when sales charge waivers were available for retirement plan customers. PNC Wealth Management was not required to pay a fine, but consented to be censured and to pay restitution to eligible customers who did not receive sales charge waivers for fund purchases since July 1, 2009.  On April 6, 2018, PNC Wealth Management entered into a settlement (“Order”) with the Securities and Exchange Commission (“SEC”). Without admitting or denying the findings, PNC Wealth Management consented to the findings that, as a result of the conduct described below, PNCWM willfully violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)‐ 7 thereunder. The Order finds that the violations resulted from the following conduct of PNCWM: (1) PNCWM, without adequate disclosure of the associated conflicts of interest, invested advisory clients in mutual fund share classes with 12b‐1 fees instead of available lower‐cost share classes of the same funds without 12b‐1 fees; (2) PNCWM did not disclose a conflict of interest regarding marketing support payments paid on such mutual fund share classes that charged 12b1 fees; (3) PNCWM improperly charged advisory fees to client accounts where the investment adviser representative departed the firm (“Orphaned Accounts”) and where PNCWM failed to assign a new investment adviser representative within thirty days; and (4) PNCWM failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices and treatment of Orphaned Accounts. Capital Directions Program October 17, 2025 Page 32 of 36  The Order requires PNCWM to cease and desist from committing or causing any violations and any future violations of Advisers Act Sections 206(2), 206(4), and 207 and Rule 206(4)‐7; censures PNCWM; and requires PNCWM to pay disgorgement of $5,234,856, and prejudgment interest of $612,344, to compensate advisory clients who were affected by certain conduct detailed in the Order. PNCWM will pay, in addition to the disgorgement and prejudgment interest described above, disgorgement of $497,144 in marketing support fees and prejudgment interest thereon of $63,426 to the SEC for the transfer to the general fund of the United States Treasury. Lastly, PNCWM will pay a civil monetary penalty of $900,000.  On April 22, 2024, PNC Wealth Management signed a Final Order with the State of North Carolina Department of the Secretary of State Securities Division. Without admitting or denying the findings, PNCWM was ordered to pay civil penalties in the amount of $7,500 and costs of investigation in the amount of $1,000 resulting from the following conduct: (1) PNCWM and one investment adviser representative (“IAR”) failed to comply with North Carolina’s IAR registration requirements in violation of N.C.G.S. §78C‐16(a1) in which the IAR transacted advisory business in North Carolina from on or about December 2021 through on or about October 2023 without being IAR registered; (2) PNCWM was in violation of N.C.G.S. §78C‐18(b) and 18 NCAC 06A .1801(a)(18) by employing the IAR in North Carolina without the appropriate registration and by not furnishing this information to the IAR’s PNCWM advisory clients; and (3) PNCWM failed to supervise the IAR’s acts, practices and conduct to ensure adherence with North Carolina’s IAR registration provisions in violation of N.C.G.S. §78C‐19(a)(2)(j) and 18 NCAC 06A .1808.  On April 24, 2024, PNC Wealth Management signed a Consent Agreement and Order with the Pennsylvania Department of Banking and Securities. The Department alleged that from on or about December 2018 until December 2023, PNCWM failed to register at least one employee as an investment adviser representative in Pennsylvania in violation of Section 301(c.1)(1)(ii) of the Pennsylvania Securities Act of 1972 (“the 1972 Act”), 70 P.S. § 1‐301(c.1)(1)(ii). Without admitting or denying the findings in the Order, PNCWM agreed to pay a monetary fine of $100,000 and to comply with the relevant provision of the 1972 Act.  On September 3, 2024, PNC Wealth Management signed a Settlement Order with the Commonwealth of Virginia Division of Securities and Retail Franchising. The Division alleged that from on or about February 2019 to June 2024, PNCWM failed to register an investment advisor representative in Virginia in violation of § 13.1‐504 C (ii) of the Virginia Securities Act. Without admitting or denying the findings in the Order, PNCWM paid $10,000 in monetary penalties and $1,000 in investigation costs.  On September 18, 2024 PNC Wealth Management entered into an Administrative Consent Agreement and Order with the District of Columbia’s Department of Insurance, Securities and Banking alleging that from on or about August 2012 through February 2024, PNCWM failed to register three investment advisor representatives in D.C. in violation of D.C. Official Code §§ 31‐5602(b)(2) and 31‐5605.01(4). PNCWM paid $162,500 as a civil penalty and $1,080 in unpaid registration fees.  On June 16, 2025, PNC Wealth Management entered into an agreement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings Capital Directions Program October 17, 2025 Page 33 of 36  that from at least June 2021, it violated FINRA rules by failing to establish and maintain a reasonably designed supervisory system, including written supervisory procedures, for the surveillance and supervision of rates of deferred variable annuity exchanges. PNC Wealth Management was required to pay a $200,000 fine and to implement a supervisory system and written supervisory procedures reasonably designed to achieve compliance in surveilling registered representatives’ rates of deferred variable annuity exchanges consistent with applicable securities laws and regulations, and with applicable FINRA rules. Other Financial Industry Activities and Affiliations PNC Wealth Management’ principal business is that of a full‐service, general securities broker‐dealer and investment adviser, registered with the SEC and as a member of FINRA. Our primary retail brokerage activities include the sale of corporate equities, corporate debt, municipal securities and funds, mutual funds, ETFs and annuities. PNC Wealth Management is part of a broad financial services organization and is therefore affiliated with other entities engaged in a variety of financial services businesses. In some cases, the firm has business arrangements with its affiliates that are material to its advisory business or to its clients. These are described in more detail below and, in some cases, cause PNC Wealth Management’ or a related person’s interests to diverge from the best interests of our clients. PNC Wealth Management is affiliated with the following financial services entities through its parent, The PNC Financial Services Group, Inc.:  PNC Bank, National Association is a wholly owned subsidiary of The PNC Financial Services Group, Inc., and is a full‐service bank engaged in traditional lending, cash and/or treasury management and other services.  PNC Capital Advisors, LLC is a wholly owned subsidiary of PNC Bank and provides discretionary fixed income investment advisory services to institutional accounts.  PNC Capital Markets LLC is an indirect, wholly owned subsidiary of The PNC Financial Services Group, Inc. and offers loan syndication, public finance underwriting and advisory services, securities underwriting and trading, private placements, asset securitizations and merger and acquisition advisory services.  PNC Insurance Services, LLC is a wholly owned subsidiary of PNC Wealth Management and a licensed insurance agency. It provides a variety of insurance products and advice. Selected conflicts of interest that exist between PNC Wealth Management and its affiliates are discussed below. Although PNC Wealth Management is committed to acting in the best interests of our clients, in some situations there are conflicts of interest between the firm’s interests and a client’s interests, or there are conflicts in the interests of multiple clients. Many of these conflicts of interest are inherent in operating an investment advisory business. For example, PNC Wealth Management may have an incentive to resolve a matter in favor of clients that are affiliates of the firm over clients that are not affiliates of the firm. PNC Wealth Management has adopted policies and procedures that it believes are reasonably designed to help mitigate these conflicts of interest. Affiliates of PNC Wealth Management provide advice to their clients with respect to investment strategies that Capital Directions Program October 17, 2025 Page 34 of 36  are similar to or the same as strategies offered by PNC Wealth Management. Those advisory affiliates may purchase on behalf of their clients the same securities that PNC Wealth Management may purchase for our clients. As a result, the interests of PNC Wealth Management’ clients may conflict with the interests of the clients of these affiliated advisors. For example, if an investment advisor affiliate implements a portfolio management decision for its client ahead of, or contemporaneously with, a decision PNC Wealth Management makes for its client(s), the market impact of the decision made by the firm’s advisory affiliate could result in one or more of PNC Wealth Management’ clients receiving less favorable trading results than they otherwise would. PNC Wealth Management’ trade allocation and trade aggregation procedures do not typically apply to portfolio management decisions and trading executed by investment advisory affiliates for their clients that are not clients of PNC Wealth Management. Affiliate Transactions PNC Wealth Management or its affiliates may from time‐to‐time recommend investments in transactions in which PNC Wealth Management or its affiliates act as financial advisor or a broker‐dealer, or in securities which are underwritten, issued, packaged or serviced by an affiliate. Moreover, PNC Wealth Management may act as a broker in executing your purchase or sale for your account of a debt security from or to PNC Capital Markets, a brokerage affiliate. Additionally, your Financial Advisor may recommend you purchase a mutual fund advised by PNC Capital Advisors, an affiliated registered investment adviser. These affiliates receive compensation as a result of these transactions, if these transactions were to occur. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PNC Wealth Management has adopted a Code of Ethics, which consists of certain general principles, including the following:  Advisory personnel must place client interests before their own  The personal securities transactions of our personnel must avoid even the appearance of a conflict with client interests  Our personnel must avoid actions or activities that allow, or appear to allow, them to profit or benefit from their position with respect to clients, or that would otherwise bring into question their independence or judgment   From time‐to‐time, PNC Wealth Management personnel may accept training, business entertainment or gifts of de minimis value from product vendors. PNC Wealth Management has adopted policies and procedures reasonably designed to ensure any such activity does not impact our personnel’s ability to act in the best interests of our clients In addition, the Code of Ethics requires our employees to report their personal securities transactions and holdings. A copy of our Code of Ethics will be provided to any client or prospective client upon request. Our employees are also subject to the PNC Employee Conduct Policies, which cover matters including compliance with law, conflicts of interest, insider trading, outside activities and safeguarding confidential information. Client Reports Capital Directions Program October 17, 2025 Page 35 of 36  As part of the Capital Directions Program, we will provide periodic reports to assist you in monitoring and assessing the performance of your Account. These reports will contain information regarding trades, investment return, and selected benchmark comparisons. These reports may also contain letters, notices and other important information regarding the Model Managers and any changes to the Account during the period. Client Referrals and Other Compensation Your Financial Advisor may refer you to PNC Bank or other PNC Wealth Management affiliates for additional products or services and will generally receive compensation for such referrals. A portion of the fees charged for the Capital Directions Program services described in this Brochure are paid to your Financial Advisor in connection with the introduction of Accounts as well as for providing client‐related services within the Programs. This compensation may be more or less than a Financial Advisor would receive if you paid separately for investment advice, brokerage and/or other services. Certain employees of PNC Bank’s Wealth Management and or Private Client Group receive compensation in connection with referrals to PNC Wealth Management. PNC Wealth Management has related persons who are investment advisors who act as general partners in partnerships in which our clients may be solicited. PNC Wealth Management would not have knowledge of such solicitations should they occur, and consequently, would not be a participant in them, nor would we receive any compensation for them. Financial Information In certain circumstances, PNC Wealth Management would be required to provide you with financial information or disclosures about our financial condition. Currently, no such circumstances exist for PNC Wealth Management. PNC Wealth Management has no financial commitments that impair our ability to meet our contractual and fiduciary commitments to our clients and has never been the subject of a bankruptcy proceeding. Capital Directions Program October 17, 2025 Page 36 of 36 

Form ADV Part 2A Appendix 1 801‐66195 Disclosure Document for the Capital Directions Annuities Program An Investment Advisory Service of PNC Wealth Management LLC 300 Fifth Avenue Pittsburgh, Pennsylvania 15222 (800) 622‐7086 www.pnc.com October 17, 2025 This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of PNC Wealth Management LLC with respect to the Capital Directions Annuities Program (the “Program”). If you have any questions about the contents of this Brochure, please contact us at (800) 622‐7086. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. PNC Wealth Management LLC, a registered investment adviser and broker‐dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), is a wholly owned subsidiary of The PNC Financial Services Group, Inc. Registration does not imply a certain level of skill or training. Additional information about PNC Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. • NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, PNC BANK, N.A. OR ANY OF ITS AFFILIATES • SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED  MATERIAL CHANGES ADV Part 2A dated October 17, 2025 The following change(s) have been made to the PNC Wealth Management Capital Directions Annuities Program Brochure since the last Brochure dated July 16, 2025: On or about October 17, 2025, our firm’s legal and business name will change from PNC Investments LLC to PNC Wealth Management LLC. This change is administrative in nature and does not affect the ownership, management, operation, services, or fees of the firm. All references to PNC Investments LLC within the Brochure will be updated to PNC Wealth Management LLC. No other material changes have been made since our last Form ADV 2A Brochure was filed on July 16, 2025. Capital Directions Annuities Program October 17, 2025 Page 2 of 23  Table of Contents About PNC Wealth Management LLC ............................................................................................................ 4 SERVICES, FEES AND COMPENSATION .............................................................................................................. ........................................................................................................... .......................................................................................................... ...................................................................................................... .............................................................................................................. ..................................................................................................... ............................................................................................................. ........................................................................................... ......................................................................................................... ............................................................................................................................................................ ............................................................................................................................................... ........................................................................................................................ ........................................................................................... ......................................................................................................................... ............................................................................................................................................ .............................................................................................................................................. ................................................................................................................................... ................................................................................................................. Capital Directions Annuities Program Account and Related Program Details Allocation Models (IOVA Products Only) Liquid Alternative Allocation Model Model/Investment Options Adjustments Automatic Rebalancing/Reinvesting Securities Transferred into an Annuity Account Withdrawals from an Annuity Account Taxes Program Fees Calculation of Program Fees Additional Fees for Annuity/Insurance Carrier Deduction of PNCWM Fees Other Expenses Cash Balances Account Termination Financial Advisor Compensation 5 5 6 7 8 9 9 9 9 10 10 11 11 11 12 13 15 15 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................................ .................................................................................................... Account Minimums and Types of Clients 16 16 PORTFOLIO MANAGER SELECTION AND EVALUATION .................................................................................... ................................................... .................................................................. ................................................................................................................................................ PNC Wealth Management and Other Service Providers to the Program Risks of Investing in the Capital Directions Annuities Program Proxy Voting 16 16 17 18 ...................................................................... CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS 18 ............................................................................................ CLIENT CONTACT WITH PORTFOLIO MANAGERS 18 ............................................................................................................................ .............................................................................................................................. ..................................................................................... ............................... ..................................................................................................................................... .................................................................................................. .................................................................................................................................. ADDITIONAL INFORMATION Disciplinary Information Other Financial Industry Activities and Affiliations Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Review of Accounts Client Referrals and Other Compensation Financial Information 18 18 20 21 22 23 23 Capital Directions Annuities Program October 17, 2025 Page 3 of 23  About PNC Wealth Management LLC PNC Wealth Management LLC (“PNC Wealth Management,” “PNCWM” or the “Firm”) is an investment adviser and also a registered broker‐dealer and member of FINRA and SIPC. The Firm offers retail brokerage and investment advisory services. PNC Wealth Management serves as the sponsor of, and in some cases as a portfolio manager for, wrap fee investment programs. PNC Wealth Management is a wholly owned subsidiary of PNC Bank, National Association (“PNC Bank”) and is a part of The PNC Financial Services Group, Inc. (“PNC”) which is a diversified financial services institution with roots in commercial banking and investment management dating back to the early 1800s. Throughout this document, the terms “client,” “you,” and “yours” are used to refer to the individual(s), institution(s) or organization(s) who contract with us for the services described here. “PNC Wealth Management,” “PNCWM,” “we,” “our,” “us” and “the firm” refer to PNC Wealth Management LLC, together (as applicable) with our affiliates, including but not limited to, PNC and its agents with respect to any services provided by those agents. Our affiliates include any entity that is controlled by, controls or is under common control with PNC Wealth Management, including but not limited to our parent company, The PNC Financial Services Group, Inc. Each affiliate is a separate legal entity and not responsible for the obligations of any other affiliate. “Annuity,” “Annuity Account” or “Capital Directions Annuities” refers to the annuity PNCWM recommended and you authorized PNC Wealth Management to purchase on your behalf through the Capital Directions Annuities Program with an Insurance Carrier. You will complete a separate Insurance Carrier Application to establish the Annuity. “Insurance Carrier” refers to a non‐affiliated PNCWM company that offers annuity products such as variable annuities, registered index‐linked annuities and other insurance products that will maintain your Annuity in the form of an “Annuity Contract.” An Annuity Contract is a written agreement between the Insurance Carrier and you outlining each party’s obligations related to your Annuity. “Investment Strategy” is our recommendation for structuring your Allocation Model (defined below), subaccounts and/or index segments (the “Investment Options”) within the Annuity. “Brokerage Account” means each brokerage and/or advisory account you open with us that is subject to the Capital Directions Annuities Program investment management agreement (the “Investment Management Agreement”), including any and all mutual funds, exchange traded funds, money, securities, financial instruments and/or other property you have funded in such accounts. It does not include the Annuity Account. “Account” or “Accounts” refers to both your Annuity Account and Brokerage Account. “Business Day” means Monday through Friday, excluding New York Stock Exchange holidays. Capital Directions Annuities Program October 17, 2025 Page 4 of 23  “Wrap” refers to an Account that charges a quarterly or annual fee based on the average assets under management, where such fee covers administrative, commission, execution and management expenses. SERVICES, FEES AND COMPENSATION This Brochure is being provided pursuant to Section 204 of the Investment Advisers Act of 1940, as amended, and deals solely with our non‐discretionary Capital Directions Annuities Program in which we recommend annuity contracts and provide investment advice to clients. In addition to the Program, PNC Wealth Management offers a variety of other investment advisory services. These include the Portfolio Solutions Program, the PNC Directions Program, the Portfolio Solutions Strategist Program, the Capital Directions Program, and the Guided Solutions Program. More information about these programs and services is contained in the applicable PNC Wealth Management brochure and is available upon request from PNC Wealth Management or through the SEC’s website at https://adviserinfo.sec.gov/. For more information about these or other services that are available from PNC Wealth Management, please contact your Financial Advisor 1. Other advisory services are offered by our affiliates. Capital Directions Annuities Program The Capital Directions Annuities Program is an advisory program offering clients the option to invest in annuity products through a selection of allocation models, subaccounts and/or index segments. We will help you formulate an Investment Strategy related to the Investment Options offered through the Insurance Carriers to be implemented through your Annuity Contract within the Capital Directions Annuities Program. Please consult your Annuity’s prospectus and Annuity Contract for specific details, features and fees charged by your Annuity. Available annuity products for the Capital Directions Annuities Program include Investment Only Variable Annuity (“IOVA”), Traditional Variable Annuity with Living Benefit Rider (“Traditional VA”) and Registered Indexed Linked Annuity (“RILA”).  IOVAs are tax deferred annuity products that provide a wide variety of subaccount investments with a simplified structure, featuring limited death benefit options and a lower cost than a Traditional VA.  Traditional VAs feature the same tax deferred benefits of the IOVA, but include a return of premium death benefit and optional riders like death benefit enhancements and income features that can allow the client to build a guaranteed income stream without annuitization.  RILAs are annuity products that provide investment returns based on the performance of a market‐ based index with downside protection generally, ranging between 5 – 30% depending on the index selected for the RILA. As part of opening a Capital Directions Annuities Program, you will complete an investor questionnaire which will provide us with an understanding of your financial situation, investment objectives, risk tolerance and investment time horizon. Based on the information collected in the investor questionnaire and other information you share with your Financial Advisor; your Financial Advisor will recommend an Investment Strategy appropriate to your situation. Your Financial Advisor will help you understand the risk and return characteristics of the Investment Strategy and help you evaluate the Investment Strategy’s return potential in relation to your investment goals and objectives. We will present our initial annuity subaccount and/or index segments recommendations to you in the form of a proposal (the “Proposal”) for your acceptance and approval. It is very important that you understand the risks associated with the Investment Options (i.e., annuity sub‐ Page 5 of 23 Capital Directions Annuities Program October 17, 2025  accounts and/or index segments) that we recommend for you to select, and we encourage you to discuss any questions with your Financial Advisor. 1 We use the term “Financial Advisor” to refer to PNC Wealth Management’ branch‐based and wealth Financial Advisors, as well as Advisor Direct Financial Advisors and Investment Services Consultants. Account and Related Program Details Before opening a Capital Directions Annuities Account, you must establish a Brokerage Account with PNC Wealth Management and agree to the terms and conditions of the PNC Wealth Management Brokerage Account Customer Agreement. Additionally, your Financial Advisor will recommend and assist you in establishing an Annuity Contract directly with an Insurance Carrier to facilitate the purchase of your Annuity. By accepting and signing the Investment Management Agreement, you authorize the Insurance Carrier to invest and reinvest the Investment Options in your Annuity Account in accordance with the Allocation Model or Investment Strategy that you have selected. The scope of any investment advisory relationship we have with you is defined in the Investment Management Agreement. As discussed in more detail below, we also earn certain fees and other revenue in connection to our capacity as introducing broker to your Accounts. This is a conflict of interest because we would not earn such fees or revenue if we did not serve as your introducing broker for the Accounts. Our Capital Directions Annuities Program advisory relationship with you begins when we enter into an Investment Management Agreement with you, which occurs at the later of the date of acceptance of the signed Investment Management Agreement by PNC Wealth Management or the date on which you have contributed the required minimum account value to your Annuity. Preliminary discussions or recommendations before we enter into an Investment Management Agreement with you are not intended as investment advice under the Investment Advisers Act and should not be relied on as such. As a direct owner for the Annuity Contract, it is your obligation to review all contract materials at the time of purchase. Contract materials will include, but are not limited to, the entire Annuity Contract, the product prospectus and any additional product disclosures provided by the Insurance Carrier. For more information regarding fees earned by the Insurance Carrier, please review your Annuity Contract and the Insurance Carrier’s prospectus. Within the Annuity Contract, you will not have the ability to directly buy or sell individual securities or to direct your Financial Advisor to buy or sell securities. You will not be able to obtain a margin loan using the securities in your Annuity Account as collateral. When invested in a Capital Directions Annuities Account, you will not have the ability to impose restrictions on any specific Investment Options, or any specific securities within subaccounts. PNC Wealth Management will be responsible for monitoring and maintaining the Allocation Models available through the Capital Directions Annuities Program and will have the ability through the Insurance Carrier to reallocate the Investment Options within your Annuity Account. PNC Wealth Management will not retain discretion to buy or sell annuities directly with the carrier on your behalf. PNC Wealth Management may, at its discretion, remove an Allocation Model from the schedule of available models and replace it with another model, without any prior notice to you. Before you open an Account in the Capital Directions Annuities Program, you should carefully review our Client Relationship Summary (“Form CRS”) and consider whether an advisory relationship is right for your situation and Capital Directions Annuities Program October 17, 2025 Page 6 of 23  circumstances. You may discuss any questions you have regarding our Form CRS or whether an advisory account is right for you with your Financial Advisor. Some things you may wish to consider include: your preference for a fee‐based versus a commission‐based relationship; your desire for on‐going support and advice from your Financial Advisor; how much trading activity you expect to take place in your Account; and the anticipated total costs. You should know that your Financial Advisor benefits when you open a Capital Directions Annuities Program and has a conflict of interest when recommending an advisory account to you, as described in more detail in the Financial Advisor Compensation section of this Brochure. Allocation Models (IOVA Products Only) PNC Wealth Management uses five core asset allocation models (“Allocation Models”). References to Allocation Models throughout this Brochure will apply only to IOVA products. Each Allocation Model is associated with a distinct risk profile and comprised of a unique mix of investment assets that have been developed by PNC Bank’s Private Bank (the “Private Bank”) and approved by PNCWM’s Investment Due Diligence Committee (IDD). Furthermore, PNC Wealth Management may also conduct its own research, including gaining insights from non‐affiliated third parties, to be used in making asset allocation decisions for the Allocation Models, which from time‐to‐time may diverge from models developed by the Private Bank. In all cases, PNCWM has sole discretion in approving and modifying the Allocation Models for the Program. These models are summarized below:  Conservative. The primary objective of the Conservative model is to generate a modest amount of current income, and secondarily to provide a modest amount of long‐term capital growth, which should help offset some of the effects of inflation. Long‐term growth of principal will be aided by income reinvestment. While the goal is to maintain a low‐risk posture, investors should be willing to accept periodic declines in the Annuity’s value. Although past performance is no guarantee of future results, generally any such decline should be less severe than declines in the broader equity markets. The allocation between subaccounts with equity and fixed income objectives exposes this model to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Moderate. The objective of the Moderate model is to generate a moderate amount of current income with the potential for longer‐term capital growth. The portfolio is split between equity and fixed income securities, with a small allocation to cash, and is constructed to provide both long‐term capital appreciation in excess of inflation and a moderate amount of current income. While the current income generated could be available to meet your day‐to‐day expenses, reinvestment of income will increase the portfolio’s ability to exceed inflation over the long‐term. The portfolio’s allocation between equity and fixed income securities, with an allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective. Capital Directions Annuities Program October 17, 2025 Page 7 of 23   Balanced. The primary objective of the Balanced model is to provide long‐term capital growth in excess of inflation, with a modest amount of current income as a secondary objective. The model is allocated between subaccounts with equity and fixed income objectives, with a higher allocation to a variety of equity subaccounts. While the current income generated could be available to meet your day‐to‐day expenses, income reinvestment will increase the ability to exceed inflation over the long‐  term. This model maintains a somewhat aggressive risk posture, and you should be willing to accept periodic declines in the Annuity’s value. Because the model is largely invested in equity subaccounts, it can experience fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the long‐term investment objective.  Growth. The primary objective of the Growth model is long‐term capital growth. It may secondarily generate a minimal amount of current income by including some subaccounts with equity and fixed income objectives. The model is concentrated in equity subaccounts in order to earn returns exceeding the rate of inflation over the long‐term. A small allocation to fixed income subaccounts is  included primarily to help dampen volatility over the long‐term. This model maintains an aggressive risk posture, and you should be willing to accept potentially significant declines in the Annuity’s value that may be similar to or exceed declines in the broader equity markets. Because the model is predominantly invested in equity subaccounts, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the long‐term investment objective.  Aggressive. The primary objective of the Aggressive model is long‐term capital growth. An Aggressive model is concentrated in subaccounts with equity objectives for long‐term growth. Returns in excess  of the underlying rate of inflation are necessary to increase both principal and purchasing power. This model maintains a highly aggressive risk posture, and you should be willing to accept potentially significant declines in the Annuity’s value, similar to or greater than declines in the broader equity markets. The model may contain a small allocation to fixed income subaccounts. Because the Annuity is predominantly invested in equity subaccounts, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the long‐term investment objective. Liquid Alternative Allocation Model An alternative version of select asset allocation models is also available. The liquid alternative allocation model (“alternative model”) includes an allocation to alternative strategy subaccounts. The alternative model can use one of many different strategies including, but not limited to, long/short, managed futures, or market neutral. PNC Wealth Management will select the available subaccounts for the Financial Advisor to recommend to clients in the alternative models, based on the availability of the subaccounts offered by the Insurance Carrier. Capital Directions Annuities Program October 17, 2025 Page 8 of 23  When alternative models are selected, the traditional asset classes in each model will be reduced on a pro rata basis. An alternative model seeks to provide additional diversification benefits beyond those of traditional models. However, alternative models are accompanied by risks that might be different from those associated with traditional subaccounts. When used as part of an overall solution, alternative subaccounts may help to meet a client’s investment needs. You should carefully review the prospectus for any alternative subaccounts you are considering for details on liquidity and other risks associated with them. Model/Investment Options Adjustments From time‐to‐time your Financial Advisor may recommend changes to your Allocation Model and/or Investment Options you have selected. You may also request changes to your Allocation Model and/or Investment Options subject to certain restrictions described in this Brochure or described in your product’s prospectus. Additionally, PNC Wealth Management will periodically exercise its discretion to adjust Allocation Models. Your Financial Advisor will consult with you before directing the Insurance Carrier to execute transactions updating your Investment Options to align your Annuity Account to the new Allocation Model. Note that you may not be sent a new Proposal in these circumstances, unless requested through your Financial Advisor. Automatic Rebalancing/Reinvesting The Insurance Carrier is responsible for rebalancing and reinvesting (applicable to RILAs) Investment Options within your Annuity Account. You authorize the Insurance Carrier to rebalance and/or reinvest your investments in the Investment Options periodically if the Investment Options’ weighting is greater or less than the weighted percentage specified for each Investment Option within the Investment Strategy. Generally, the Insurance Carrier may rebalance and/or reinvest your Annuity Account based on your Annuity Contract, however, you may request, via your annuity application, a less frequent timeframe for affecting rebalances/reinvestments. You may also request, subject to approval by the Insurance Carrier, that an ad hoc rebalance and/or reinvestment be affected. You also understand and acknowledge that rebalancing/reinvesting may involve fees depending on your Annuity Contract requirements. For more information regarding rebalance and/or reinvestment frequency and product specific rules, please review the Annuity’s prospectus and/or your Annuity Contract. Securities Transferred into an Annuity Account You may, at your election, chose an optional Dollar Cost Averaging (“DCA”) feature investing in your Annuity. With the DCA feature, the Insurance Carrier will hold a portion of your premium in a conservative account, generally a Cash Account, Fixed Account, or Money Market Account, and deploy the premium over a defined period and in pre‐determined amounts. The DCA feature can enable clients to slowly invest into the Investment Options over time, rather than make one lump‐sum investment. DCA may not be available in all annuity contracts offered by PNCWM, and features of the program will vary between Insurance Carriers. Please refer to your Annuity Contract and product prospectus for details regarding the DCA availability within your Annuity. Withdrawals from an Annuity Account All withdrawals from your Annuity are completed at the Insurance Carrier and may be subject to additional requirements prior to distribution. All transaction requests are subject to Insurance Carrier rules and requirements. Disbursements made from your Annuity Account may take longer than a standard brokerage account. For more information on disbursements, please contact your Financial Advisor. Capital Directions Annuities Program October 17, 2025 Page 9 of 23  Taxes Annuity Accounts are invested in tax‐deferred annuity products. Transactions that occur within the Annuity Contract will not be subject to taxation until the assets are removed from the Annuity Contract. Depending on whether it is a qualified or nonqualified annuity, you may have to pay income taxes on the entire amount or you may only pay taxes on the money your annuity has earned. You should consider and discuss the potential tax implications of purchasing an Annuity and maintaining an Annuity Account with your tax adviser. Program Fees You will pay a program fee (the “Program Fee”) for the services provided under the Capital Directions Annuities Program. The Program Fee will be reflected on your Brokerage Account statement as the management fee (the “Management Fee”). Your Brokerage Account and Annuity Account are subject to the Management Fee whether you make or lose money on the investments. The Program Fee is calculated as a percentage of assets under management based on the value of the Brokerage Account and Annuity Account and will vary depending on the services provided to you. Generally, you will be charged commissions or service charges for transactions executed prior to establishing your Accounts; you should discuss your options for funding your Accounts with your Financial Advisor. The Program Fee is based on the total assets under management of your Annuity and Brokerage Account, including any portion maintained in cash or in short‐term vehicles. As the aggregate market value of the Program Account and if applicable, other managed accounts in the billing household reaches a higher tier, as shown in the table below, the assets within that higher tier are charged a lower rate. Our standard Program Fee schedule is as follows: Assets Under Management Maximum Program Fee First $250,000 2.00% Next $250,000 1.75% Next $500,000 1.50% Next $1,000,000 1.25% Next $2,000,000 1.00% Over $4,000,000 Negotiable From time‐to‐time, we offer discounted pricing programs at our discretion. For example, current employees of PNCWM and their immediate family members are eligible for employee pricing. Your Financial Advisor has discretion to negotiate a Program Fee that varies from the standard schedule above. This can depend on certain factors, including the type and size of your Annuity, the range of services provided and the total amount you or other members of your household have invested with PNC Wealth Management. The Program Fee is referenced in the fee schedule included as part of the Proposal completed and accepted by you. The Program Fee you pay to PNC Wealth Management for the Capital Directions Annuities Program is charged quarterly in advance and will be based on the combined average daily balance held in your Annuity Page 10 of 23 Capital Directions Annuities Program October 17, 2025  Account with the Insurance Carrier and your PNCWM Brokerage Account over the prior calendar quarter or portion thereof (except in the case of a new Capital Directions Annuities Account). Calculation of Program Fees The Program Fee will be paid in advance following the end of each calendar quarter for the upcoming quarter and will be calculated on the last business day of the quarter as follows. The Program Fee is calculated based upon the average daily market value of the total assets in the Annuity and your Brokerage Account over the prior calendar quarter, including cash holdings. Cash holdings, within your Brokerage Account, in excess of 7.5% operational cash will be excluded from the average daily market value calculation when the Program Fee is calculated. Upon your request, we will provide you with a detailed explanation of the fee calculation which will allow you to recalculate the fees should you so desire. With your initial contribution (after the date the Insurance Carrier receives the initial assets of your Annuity) and for any additional contribution or distribution adjustments, your fee will be calculated for that portion of the ongoing quarterly Program Fee that relates to the number of days remaining in the calendar quarter as of the date your Annuity Account becomes subject to the Investment Management Agreement or that you make the additional contribution or distribution, as applicable. An adjustment to the next quarterly fee will be made for any significant contributions or distributions that occur during the inception quarter of your Brokerage Account and/or Annuity Account. This Program Fee will be based on the total market value of assets in your Annuity Account and Brokerage Account on that date. If your Annuity is terminated by you or PNC Wealth Management during a calendar quarter, the fee for that quarter will be prorated over the number of days that the Annuity was held during the quarter. Any overpayment will be refunded to you after the Annuity is closed. Fees are not prorated for contributions or withdrawals made during a calendar quarter, except in the case of a new or terminated Annuity, as outlined above. If you terminate your Annuity within 90 calendar days of initial investment, your Insurance Carrier reserves the right to charge you commissions and fees according to its policies. For more information regarding these commissions and fees please consult your Annuity’s prospectus or your Annuity Contract. Additional Fees for Annuity/Insurance Carrier If an annuity is purchased, additional fees may be charged by the Insurance Carrier, including trading and operational service fees. Certain annuity contract charges, including a Mortality, Expense & Administration (sometimes referred to as M&E or M&E&A) fees and other fees assessed by the Insurance Carrier. Any additional riders to an annuity contract are subject to additional fees. These charges are assessed against the Annuity Contract’s account value. M&E fees and other fees related to an annuity contract are explicitly outlined in each product’s prospectus. Investment Options are also subject to additional fund expense fees by the Insurance Carrier. The annuity’s prospectus should be thoroughly reviewed for a full explanation of the assessment of all fees and expenses. All fees assessed by the Insurance Carrier for your Annuity are in addition to any Program Fees charged by PNC Wealth Management and subject to the Insurance Carrier’s policies. Additional fees assessed by the Insurance Carrier for your Annuity will reduce your investment returns. Deduction of PNCWM Fees PNCWM fees such as Program Fees or Brokerage Account fees, are unable to be paid directly from your Annuity. Through the PNCWM Advisory Annuity Billing Agreement, you will authorize the payment of the Program Fee Capital Directions Annuities Program October 17, 2025 Page 11 of 23  directly from a Brokerage Account listed on the Billing Agreement. Cash held in this Brokerage Account will be categorized as unallocated cash described in Cash Balances section below. You should be aware that this unallocated cash will be included in calculating the Program Fee. If the Brokerage Account does not have a sufficient cash balance or enough money market mutual fund shares to cover the fees, we will liquidate other securities as necessary to pay them. Selling securities to pay fees is subject to the securities’ short‐term trading policies and, if your Brokerage Account is taxable, will create tax consequences for you. Additionally, if you are unable to pay the Program Fee, PNCWM has the right to terminate your Investment Management Agreement within 30 days of when that fee was to be paid. You may contact your Financial Advisor if you have any questions regarding the fees charged to your Brokerage Account. Other Expenses Within the Capital Directions Annuities Program, PNC Wealth Management will only offer “I‐Shares” or “ADV Shares” of variable annuities. This share class features annuity products that do not have a contingent deferred sales charge and a lowered mortality and expense fee schedule. Each Investment Option in which your Annuity Account is invested charges its own separate fund‐level fees and operating expenses, including, for example, administrative, custody, transfer agent, legal and audit fees and expenses, investment advisory or management fees, shareholder servicing fees, omnibus accounting fees, fees for sub‐administration, recordkeeping, print mail services and other expenses. These fees and operating expenses are ultimately borne by the shareholders invested in the Investment Options, including you, and will reduce your investment returns. Other share classes offered by mutual fund Investment Options have lower fund‐level fees and expenses than those used in this Program. Please review the relevant fund prospectuses for a full explanation of fund expenses and charges. PNC Wealth Management receives additional compensation, referred to as revenue sharing, from the advisors or distributors of the mutual funds and annuity carriers offered in the Program, which compensates us for administrative services we provide to them and is based on the amounts our customers invest in those mutual funds and/or annuities in our Programs. Our independent due diligence process for selecting mutual funds and annuities for the Program is designed so that mutual funds and annuities are selected based on objective, investment related criteria and does not take into account compensation to PNC Wealth Management. However, only funds or annuities for which we receive revenue sharing are considered for inclusion in this due diligence process. This is a conflict of interest for us because mutual funds and annuities that may otherwise meet our investment criteria are not included in the Program because their advisors or distributors do not offer revenue sharing to PNC Wealth Management. We will not credit your Accounts for any revenue sharing payments we receive. Although we include only mutual funds and annuities whose sponsors pay PNCWM revenue sharing, we believe this conflict is mitigated by the large and diverse universe of mutual funds and annuities we make available in our programs which meet our clients’ needs. However, you should be aware that we will not liquidate your annuity contract if an insurance carrier’s participation in our Program is discontinued, PNCWM has the option to instead resign as broker‐dealer and terminate the Investment Management Agreement. If this occurs, PNCWM will notify you and direct you to contact the Insurance Carrier for on‐going services related to your Annuity. For details on revenue sharing received by PNC Wealth Management from mutual fund advisors or distributors, please see the following link: https://www.pnc.com/content/dam/pnc‐com/pdf/personal/wealth‐ Capital Directions Annuities Program October 17, 2025 Page 12 of 23  management/Additional‐Compensation‐Disclosure.PDF For more information on the compensation a particular mutual fund provider may pay, please refer to the mutual fund’s or annuity’s prospectus and/or Statement of Additional Information. Purchasing your Annuity in the Program may cost you more or less than purchasing an annuity directly through an agent of the Insurance Carrier without enrolling in the Program, including through a brokerage account at PNC Wealth Management. If you purchase an annuity directly, you may not receive the asset allocation and account monitoring services available via the Program and may not qualify to invest in share classes available to investors through the Program. In addition, annuities purchased outside the Program may charge commissions and back‐ end sales charges depending on the share class. PNC Wealth Management receives an annual credit from National Financial (the “Business Development Credit”). PNCWM is incentivized to select and continue its relationship with National Financial to receive the Business Development Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. The Business Development Credit is not related to the sale or offer of any specific products or services, nor is it dependent upon assets under management. If received, we will retain the Business Development Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the Business Development Credit. Additionally, if under certain circumstances our clearing arrangement with National Financial is terminated prior to the expiration of our agreement, PNCWM is subject to certain contractual fees and penalties (collectively, the “Termination Fee”). The Termination Fee creates a strong disincentive for PNCWM to consider clearing relationships other than National Financial. This creates a conflict of interest for us as we expect to benefit from the continued recommendation of National Financial as our clearing firm. Additionally, PNCWM is further incentivized to continue the relationship with National Financial as we may not receive the same incentives from other clearing firm arrangements, such as receiving particular credits from National Financial or having the ability to mark‐up certain fees to clients. Cash Balances You will only be able to hold cash in your Brokerage Account, this cash will be considered unallocated cash. Unallocated cash will be automatically swept through the Bank Deposit Sweep Program (“BDSP”) into an interest‐bearing deposit account (“Deposit Account”) at our affiliate, PNC Bank (and, as noted above, are included in the assets on which Management Fees are charged). The interest rate (“BDSP interest rate”) for BDSP assets held in the Deposit Account is determined by PNC Bank with the input of PNC Wealth Management such as objective competitive market data. BDSP is the only cash sweep option available to your Brokerage Account. The only exception is in very limited situations where your account type is not eligible for BDSP (such as participant accounts of employer sponsored qualified plans) and your funds will be invested in a money market mutual fund selected by us. You should be aware that although assets held in the Deposit Account are protected by FDIC insurance neither PNC Wealth Management nor PNC Bank will monitor whether BDSP deposits, individually or in combination with other deposits you hold at PNC Bank, exceed FDIC insurance limitations. You should review your cash balance held in the Deposit Account and other PNC Bank accounts to ensure that cash balances do not exceed FDIC insurance Page 13 of 23 Capital Directions Annuities Program October 17, 2025  coverage levels, or alternatively, in the event your cash balance exceeds FDIC insurance limitations, that you are comfortable with the risks associated with having uninsured cash. The rate of return you receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to such cash balances. PNC Bank uses the BDSP program assets to fund its lending activities, allowing PNC Bank to earn revenue based on the difference between the rate paid to you and the higher rate of interest earned by lending the assets to its customers. Moreover, PNC Wealth Management receives revenue from PNC Bank based on the assets in the BDSP, this revenue amount varies depending on market conditions, but will not exceed the current Federal Funds Target Rate Range – Upper Limit rate (available online at https://fred.stlouisfed.org/series/DFEDTARU) plus 0.50%. This means PNC Wealth Management benefits in two ways from placing assets in the BDSP (i.e., the Management Fee and the revenue share from our affiliate). We will not credit any portion of this revenue to your Brokerage or Annuity Account. Note that the revenue earned by PNC Wealth Management and our affiliate PNC Bank will significantly exceed the interest credited to your Brokerage Account from the allocation to BDSP. The revenue we receive is a conflict of interest for us, because we, and our affiliate, PNC Bank, obtain a financial benefit when your unallocated cash is held through the BDSP in a Deposit Account. This financial benefit is greater than the financial benefit we would receive if your unallocated cash was invested through a different cash sweep vehicle such as a money market fund, which could pay you a higher rate of interest. For information pertaining to the interest rate spread earned by PNC on all loans, including those generated from BDSP assets, please see the Net Interest Margin discussion in the most recent Annual Report on Form 10‐K and subsequent Quarterly Reports on Form 10‐Q for The PNC Financial Services Group, Inc., available at, https://investor.pnc.com/financial‐information/financial‐results. Brokerage Account assets invested through the BDSP typically will pay you less interest – and in some market conditions, much less interest – than they would if invested in alternative cash sweep vehicles that are available to PNC Wealth Management such as a money market fund. Accordingly, you should not participate in the Program if you wish to hold your unallocated cash in another sweep vehicle. (Please note that while BDSP is used as the sweep option to hold unallocated cash, if your Brokerage Account has an investment allocation to cash, that allocation will typically be held in money market mutual funds or other short duration securities.) In certain circumstances, it may not be possible or practical to sweep uninvested cash in your account to the Bank Deposit Sweep Program (described above). For example, cash deposited to fund an annuity or insurance contract may not be swept to BDSP prior to contract issuance and instead will be held by the clearing firm, which will pay interest according to the terms in your Brokerage Account Customer Agreement. If interest from uninvested cash is credited to your account, it will appear on your account statement as credit interest. For more information regarding BDSP, including information about FDIC insurance limitations, please see the PNCWM BDSP Disclosure Document, you may also review the current BDSP interest rate at the following link: https://www.pnc.com/en/personal‐banking/investments‐and‐retirement/sweep‐program‐rates.html. Additionally, information about FDIC insurance can be found online at: https://www.fdic.gov/resources/deposit‐insurance/. Capital Directions Annuities Program October 17, 2025 Page 14 of 23  Account Termination Either party may terminate the Investment Management Agreement on 30 days’ written notice to the other party. You are also entitled to terminate such agreement within five (5) business days of your execution of it without incurring a Program Fee; you may, however, be subject to certain other fees incurred with respect to the Annuity for the relevant period. Upon the termination of the Investment Management Agreement, PNCWM will be under no obligation to provide advice on any holdings in your Annuity. If this occurs, you will need to contact the Insurance Carrier directly for on‐going services related to your Annuity. Any transactions executed by you after the termination of the Investment Management Agreement will be subject to fees and commissions described by Insurance Carrier’s Annuity Contract and/or prospectus and PNC Investment’s Overview of Products and Services (the “Overview of Products and Services”). You will want to refer to your Annuity Contract or the Insurance Carrier’s prospectus for information about fees and commissions. You may obtain a copy of our current Overview of Products and Services, at any time, by contacting your Financial Advisor, by contacting us at (800) 622‐7086 or online at www.pnc.com/investments‐relationship‐summary. In addition, upon learning of the death of any account owner, PNCWM will immediately terminate the Investment Management Agreement. You should be aware that any transactions executed by your heirs or beneficiaries after your death will be subject to fees and commissions described by the Insurance Carrier and in the Overview of Products and Services, unless waived by us in our sole discretion. Please see the Investment Management Agreement governing your Capital Directions Annuities Program for more information. Financial Advisor Compensation A portion of the fees charged for Program services will be paid to your Financial Advisor in connection with purchasing and providing on‐going investment advice to your Annuity, as well as for providing client‐related services within the Program. This compensation may be more or less than a Financial Advisor would receive if you invested in a brokerage annuity, rather than a managed annuity in the Capital Directions Annuities Program, and paid separately for investment advice, brokerage and other services covered by the Program Fee. In circumstances where the managed annuity would generate higher fees for the Financial Advisor than a brokerage annuity, your Financial Advisor will have greater financial incentive to offer a managed product over a brokerage product. As disclosed above, certain of our Programs charge a negotiable Program Fee and others charge a negotiable Program Fee plus a Model Provider Fee, which in certain circumstances may be waived but is not negotiable. Differences in fees for Model Providers in Programs with a third‐party manager, or the absence of such fees in any Program, create a conflict of interest as such differences provide an opportunity for Financial Advisors to negotiate a higher Fee for a strategy with lower or no separate Model Provider Fees than they would for strategies that charge a higher Model Provider Fee. The opportunity to negotiate a higher fee also creates a financial incentive for Financial Advisors to recommend such Programs and/or Model Providers. The ability of the Financial Advisor to negotiate a higher Program Fee in these circumstances also provides a financial benefit to PNC Wealth Management, which retains a portion of the Program Fee. Occasionally, Accounts may be reassigned from the originating Financial Advisor to a new Financial Advisor because the originating Financial Advisor leaves our firm, takes a new position, or for other reasons. Financial Advisors receive less compensation for accounts reassigned to them (“Reassigned Accounts”) than accounts they originated and therefore have a conflict of interest because they have a financial incentive to provide better service to accounts that they have originated versus Reassigned Accounts. Financial Advisors receive additional compensation when clients add funds to Reassigned Accounts and have incentive to encourage additional deposits to Reassigned Accounts. PNC Wealth Management has established policies and procedures reasonably designed to ensure that any recommendation made is suitable for your unique circumstances. PNC Wealth Capital Directions Annuities Program October 17, 2025 Page 15 of 23  Management typically will advance to Financial Advisors a portion of the first year’s estimated fees for clients who invest in the Program. In addition, certain Financial Advisors who typically work with higher net worth clients can earn enhanced upfront compensation when customers establish a new advisory account or add new assets into an existing advisory account with us. This compensation creates a conflict of interest because these Financial Advisors have an additional incentive to encourage clients to place their funds in investment advisory accounts. From time‐to‐time, PNC Wealth Management initiates incentive programs for its employees including Financial Advisors. These programs include, but are not limited to, programs that compensate them for attracting new assets and clients, or for referring business to our affiliates (such as referrals for mortgages, trusts, or insurance services); programs that reward them for promoting investment advisory services, in some circumstances by enhancing revenue credits paid to them in connection with new advisory accounts or additions to existing advisory accounts, for participating in advanced training, and for improving client service; and programs that reward Financial Advisors who meet total production criteria. Annuity and insurance products are restricted from incentive programs. Financial Advisors who participate in these incentive programs are rewarded with cash and/or non‐cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. These programs may be partly subsidized by external vendors or our affiliates, such as mutual fund companies, insurance carriers or money managers. Therefore, our Financial Advisors have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services that we offer. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients The minimum account size for the Capital Directions Annuities Program is $50,000. We may terminate the advisory services on any Annuity Account that falls below minimum account value guidelines established by the Firm on 30 days’ written notice to the Account holder. To avoid termination, you may be required to deposit additional assets in your Annuity Account to remain in the Capital Directions Annuities Program, as allowable under your Annuity Contract. Please review your Annuity Contract and/or prospectus for specific requirements for subsequent contributions. Under certain limited circumstances, we may waive the minimum account size requirement. PNC Wealth Management principally provides investment advice to US based individuals and high‐net worth individuals. PORTFOLIO MANAGER SELECTION AND EVALUATION The Program does not engage Portfolio Managers. PNC Wealth Management and Other Service Providers to the Program PNC Wealth Management was formed in 2003, and is a direct, wholly owned subsidiary of PNC Bank. PNC Bank is a wholly owned subsidiary of The PNC Financial Services Group, Inc., a financial holding company. Capital Directions Annuities Program October 17, 2025 Page 16 of 23  PNC Wealth Management is registered with the SEC as an investment adviser and a broker‐dealer. PNC Wealth Management is a member of FINRA and SIPC and serves as the sponsor of the Program. PNC Wealth Management does not receive performance‐based fees calculated as a share of capital gains on, or capital appreciation of, the funds or any portion of the funds or other investments in a client’s Account. National Financial provides trading, custody and operational services for the Brokerage Account. National Financial carries client Brokerage Accounts, is the custodian for the investments in your Brokerage Account, reports all the trades in your Brokerage Account and affects many such trades. National Financial will provide you with trade confirmations, monthly statements, and income tax reporting.  For annuities purchased in the Capital Directions Annuities Program, the Insurance Carrier is the custodian for the assets in the annuity contract and will report and affect all trades in your Annuity Account. Your Insurance Carrier will provide all transaction confirmations, periodic statements as noted in the product’s prospectus and income tax reporting. Risks of Investing in the Capital Directions Annuities Program Investing in annuities, including the Investment Options offered through the Program, involves risk of loss that you should be prepared to bear. There is no guarantee that the elements of the Program, including the asset allocation models, selection of annuity subaccounts and/or index segments will protect against such loss. Other risks include:  Annuity Risk. Annuity investment returns are based on performance of the Investment Options. Annuities are not FDIC insured and are subject to federal income tax penalties for withdrawals prior to age 59 ½. Future income from the annuity depends on the Insurance Carrier remaining financially sound. Review the Annuity Contract’s prospectus for features, risks, costs and benefits.   Market Risk. Market risk is the risk that the price of your subaccount and/or index segment will fall over short or extended periods of time. Historically, the prices of equity securities have moved in cycles, and the value of an annuity’s investments will fluctuate from day to day. When individual companies are negatively impacted by industry or economic trends or report poor operating results, the price of securities issued by those companies will typically decline in response. These factors contribute to price volatility.   Allocation Risk. An Annuity is subject to the risk that Investment Option decisions will not anticipate market trends correctly. For example, weighting an annuity subaccount and/or index segment too heavily in equities during a stock market decline may cause a loss of value. Conversely, investing too heavily in fixed income Investment Options during a period of stock market appreciation may result in lower total returns.   Credit Risk. The value of your Investment Options within your Annuity is affected by the ability of issuers to make principal and interest payments. If an Insurance Carrier cannot meet its payment obligations or if its credit rating is lowered, the value of its debt securities will typically fall.   Interest Rate Risk. The value of your Investment Options within your Annuity will typically decline because of an increase in market interest rates. In addition, in certain low‐yield interest rate Capital Directions Annuities Program October 17, 2025 Page 17 of 23  environments, some short‐term investments may produce negative yield, after accounting for fees, inflation and other expenses.  Unsystematic Risk. Unsystematic risk is unique to a specific company or industry. Also known as “nonsystematic risk,” “specific risk,” “diversifiable risk” or “residual risk,” in the context of an investment portfolio, unsystematic risk can be reduced through diversification.   Mortality Risk. With the risk of if you die too soon after buying an annuity, your beneficiaries may not receive the benefit of the future payments you had expected, depending on the death benefits chosen on the contract.  Inflation Risk. Consider how rising inflation can reduce the spending power of those payments. You may want to look at options with your Financial Advisor to adjust your annuity benefit for inflation.   The Program is intended to be a long‐term investment program and does not support market‐timing. You will be limited to one change in risk allocation per calendar quarter, except as warranted by changes to your financial situation as agreed by you and your Financial Advisor. Frequent or excessive changes in Capital Directions Annuities Accounts is grounds for account termination, with 30 days’ written notice, by PNC Wealth Management, even if the rules above are not violated. The determination of frequent and/or excessive changes is solely at the discretion of PNC Wealth Management. Proxy Voting PNCWM will not vote or instruct the Insurance Carrier on proxies (or give clients advice on how to vote proxies) relating to the Annuity. PNCWM will not be responsible or liable for failing to notify a client of proxies or failing to send to a client, as applicable, proxy materials or annual reports where PNCWM have not received proxies or related client communications on a timely basis or at all. For more information regarding proxy voting, please see your Annuity Contract and/or prospectus. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Not applicable as this Program does not involve engagement of Portfolio Managers. CLIENT CONTACT WITH PORTFOLIO MANAGERS The Program does not engage Portfolio Managers. Your Financial Advisor will communicate any changes about you to PNC Wealth Management. You should direct any inquiries regarding your Annuity to your Financial Advisor. ADDITIONAL INFORMATION Disciplinary Information  On April 11, 2016, PNC Wealth Management entered into a settlement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of Capital Directions Annuities Program October 17, 2025 Page 18 of 23  findings that it failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales and failed to apply such waivers to mutual fund purchases by certain retirement plan customers that were eligible to purchase Class A shares in certain mutual funds without a front‐end sales charge. The findings also stated that PNC Wealth Management failed to maintain adequate written policies and procedures or to provide adequate training to assist financial advisors in determining when sales charge waivers were available for retirement plan customers. PNC Wealth Management was not required to pay a fine, but consented to be censured and to pay restitution to eligible customers who did not receive sales charge waivers for fund purchases since July 1, 2009.  On April 6, 2018, PNC Wealth Management entered into a settlement (“Order”) with the SEC. Without admitting or denying the findings, PNC Wealth Management consented to the findings that, as a result of the conduct described below, PNCWM willfully violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)‐7 thereunder. The Order finds that the violations resulted from the following conduct of PNCWM: (1) PNCWM, without adequate disclosure of the associated conflicts of interest, invested advisory clients in mutual fund share classes with 12b‐1 fees instead of available lower‐cost share classes of the same funds without 12b‐1 fees; (2) PNCWM did not disclose a conflict of interest regarding marketing support payments paid on such mutual fund share classes that charged 12b1 fees; (3) PNCWM improperly charged advisory fees to client accounts where the investment adviser representative departed the firm (“Orphaned Accounts”) and where PNCWM failed to assign a new investment adviser representative within thirty days; and (4) PNCWM failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices and treatment of Orphaned Accounts. The Order requires PNCWM to cease and desist from committing or causing any violations and any future violations of Advisers Act Sections 206(2), 206(4), and 207 and Rule 206(4)‐7; censures PNCWM; and requires PNCWM to pay disgorgement of $5,234,856, and prejudgment interest of $612,344, to compensate advisory clients who were affected by certain conduct detailed in the Order. PNCWM will pay, in addition to the disgorgement and prejudgment interest described above, disgorgement of $497,144 in marketing support fees and prejudgment interest thereon of $63,426 to the SEC for the transfer to the general fund of the United States Treasury. Lastly, PNCWM will pay a civil monetary penalty of $900,000.  On April 22, 2024, PNC Wealth Management signed a Final Order with the State of North Carolina Department of the Secretary of State Securities Division. Without admitting or denying the findings, PNCWM was ordered to pay civil penalties in the amount of $7,500 and costs of investigation in the amount of $1,000 resulting from the following conduct: (1) PNCWM and one investment adviser representative (“IAR”) failed to comply with North Carolina’s IAR registration requirements in violation of N.C.G.S. §78C‐16(a1) in which the IAR transacted advisory business in North Carolina from on or about December 2021 through on or about October 2023 without being IAR registered; (2) PNCWM was in violation of N.C.G.S. §78C‐18(b) and 18 NCAC 06A .1801(a)(18) by employing the IAR in North Carolina without the appropriate registration and by not furnishing this information to the IAR’s PNCWM advisory clients; and (3) PNCWM failed to supervise the IAR’s acts, practices and conduct to ensure adherence with North Carolina’s IAR registration provisions in violation of N.C.G.S. §78C‐19(a)(2)(j) and 18 NCAC 06A .1808. Page 19 of 23 Capital Directions Annuities Program October 17, 2025   On April 24, 2024, PNC Wealth Management signed a Consent Agreement and Order with the Pennsylvania Department of Banking and Securities. The Department alleged that from on or about December 2018 until December 2023, PNCWM failed to register at least one employee as an investment adviser representative in Pennsylvania in violation of Section 301(c.1)(1)(ii) of the Pennsylvania Securities Act of 1972 (“the 1972 Act”), 70 P.S. § 1‐301(c.1)(1)(ii). Without admitting or denying the findings in the Order, PNCWM agreed to pay a monetary fine of $100,000 and to comply with the relevant provision of the 1972 Act.  On September 3, 2024, PNC Wealth Management signed a Settlement Order with the Commonwealth of Virginia Division of Securities and Retail Franchising. The Division alleged that from on or about February 2019 to June 2024, PNCWM failed to register an investment advisor representative in Virginia in violation of § 13.1‐504 C (ii) of the Virginia Securities Act. Without admitting or denying the findings in the Order, PNCWM paid $10,000 in monetary penalties and $1,000 in investigation costs.  On September 18, 2024 PNC Wealth Management entered into an Administrative Consent Agreement and Order with the District of Columbia’s Department of Insurance, Securities and Banking alleging that from on or about August 2012 through February 2024, PNCWM failed to register three investment advisor representatives in D.C. in violation of D.C. Official Code §§ 31‐5602(b)(2) and 31‐5605.01(4). PNCWM paid $162,500 as a civil penalty and $1,080 in unpaid registration fees.  On June 16, 2025, PNC Wealth Management entered into an agreement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that from at least June 2021, it violated FINRA rules by failing to establish and maintain a reasonably designed supervisory system, including written supervisory procedures, for the surveillance and supervision of rates of deferred variable annuity exchanges. PNC Wealth Management was required to pay a $200,000 fine and to implement a supervisory system and written supervisory procedures reasonably designed to achieve compliance in surveilling registered representatives’ rates of deferred variable annuity exchanges consistent with applicable securities laws and regulations, and with applicable FINRA rules. Other Financial Industry Activities and Affiliations PNC Wealth Management’ principal business is that of a full‐service, general securities broker‐dealer and investment adviser, registered with the SEC and as a member of FINRA. Our primary retail brokerage activities include the sale of corporate equities, corporate debt, municipal securities and funds, mutual funds, ETFs and annuities. PNC Wealth Management is part of a broad financial services organization and is therefore affiliated with other entities engaged in a variety of financial services businesses. In some cases, the firm has business arrangements with its affiliates that are material to its advisory business or to its clients. These are described in more detail below and, in some cases, cause PNC Wealth Management’ or a related person’s interests to diverge from the best interests of our clients. PNC Wealth Management is affiliated with the following financial services entities through its parent, The PNC Financial Services Group, Inc.:  PNC Bank, National Association is a wholly owned subsidiary of The PNC Financial Services Group, Capital Directions Annuities Program October 17, 2025 Page 20 of 23  Inc., and is a full‐service bank engaged in traditional lending, cash and/or treasury management and other services.  PNC Capital Advisors, LLC is a wholly owned subsidiary of PNC Bank and provides discretionary fixed income investment advisory services to institutional accounts.   PNC Capital Markets LLC is an indirect, wholly owned subsidiary of The PNC Financial Services Group, Inc. and offers loan syndication, public finance underwriting and advisory services, securities underwriting and trading, private placements, asset securitizations and merger and acquisition advisory services.   PNC Insurance Services, LLC is a wholly owned subsidiary of PNC Wealth Management and a licensed insurance agency. It provides a variety of insurance products and advice.   Selected conflicts of interest that exist between PNC Wealth Management and its affiliates are discussed below. Although PNC Wealth Management is committed to acting in the best interests of our clients, in some situations there are conflicts of interest between the firm’s interests and a client’s interests, or there are conflicts in the interests of multiple clients. Many of these conflicts of interest are inherent in operating an investment advisory business. For example, PNC Wealth Management may have an incentive to resolve a matter in favor of clients that are affiliates of the firm over clients that are not affiliates of the firm. PNC Wealth Management has adopted policies and procedures that it believes are reasonably designed to help mitigate these conflicts of interest. Affiliates of PNC Wealth Management provide advice to their clients with respect to Investment Strategies that are similar to or the same as strategies offered by PNC Wealth Management. Those advisory affiliates may purchase on behalf of their clients the same securities that PNC Wealth Management may purchase for our clients. As a result, the interests of PNC Wealth Management’ clients may conflict with the interests of the clients of these affiliated advisors. For example, if an investment advisor affiliate implements a portfolio management decision for its client ahead of, or contemporaneously with, a decision PNC Wealth Management makes for its client(s), the market impact of the decision made by the firm’s advisory affiliate could result in one or more of PNC Wealth Management’ clients receiving less favorable trading results than they otherwise would. PNC Wealth Management’ trade allocation and trade aggregation procedures do not typically apply to portfolio management decisions and trading executed by investment advisory affiliates for their clients that are not clients of PNC Wealth Management. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PNC Wealth Management has adopted a Code of Ethics, which consists of certain general principles, including the following:  Advisory personnel must place client interests before their own   The personal securities transactions of our personnel must avoid even the appearance of a conflict with client interests   Our personnel must avoid actions or activities that allow, or appear to allow, them to profit or benefit from their position with respect to clients, or that would otherwise bring into question their Capital Directions Annuities Program October 17, 2025 Page 21 of 23  independence or judgment   From time‐to‐time, PNC Wealth Management personnel may accept training, business entertainment or gifts of de minimis value from product vendors. PNC Wealth Management has adopted policies and  procedures reasonably designed to ensure any such activity does not impact our personnel’s ability to act in the best interests of our clients In addition, the Code of Ethics requires our employees to report their personal securities transactions and holdings. A copy of our Code of Ethics will be provided to any client or prospective  client upon request. Our employees are also subject to the PNC Employee Conduct Policies, which cover matters including compliance with law, conflicts of interest, insider trading, outside activities and safeguarding confidential information. Review of Accounts When you open a Capital Directions Annuities Program Account, we review and must approve your investment objectives and strategy for consistency with Capital Directions Annuities Program guidelines. Thereafter, we will monitor the Annuity on an ongoing basis, including its performance, the appropriateness of the individual subaccounts and/or indexed segments in it, and any investment restrictions that might apply. We will attempt to contact you at least annually, including by mail or email (if you have authorized us to send you electronic communications), to request that you review your Annuity and inform us of any changes to your financial profile or investment objectives. You should inform your Financial Advisor of any changes to your financial profile or investment objectives as they occur. Your Financial Advisor will communicate any changes about you to PNC Wealth Management. Therefore, it is very important that you maintain contact and communication with your Financial Advisor. You should direct any inquiries about your Annuity, the Allocation Model, and/or Investment Options to your Financial Advisor. Your Financial Advisor will be reasonably available to you for consultation about the Annuity. We encourage you to contact your Financial Advisor with questions. You will receive a monthly statement following any month in which there is activity in your Annuity or Brokerage Account, reflecting the value of your Annuity and advisory fees paid to PNC Wealth Management. For periods in which there is no investment activity, statements will be provided quarterly. You will also receive a quarterly performance report that tracks the performance of your Annuity against relevant benchmarks. You will be reminded quarterly to contact your Financial Advisor if you should have any questions, or if there have been material changes in your financial goals or needs that would affect your Investment Strategy. In regard to your Annuity, your Insurance Carrier will provide transaction confirmations for any financial transactions that occur in the Annuity Account (re‐balancing, subaccount transfers, withdrawals, contributions, etc.). The Insurance Carrier will provide you with annual or quarterly statements of the Annuity Contract values, along with change confirmations and tax notifications, depending on the frequency required for the annuity type purchased. Capital Directions Annuities Program October 17, 2025 Page 22 of 23  Client Referrals and Other Compensation Your Financial Advisor may refer you to PNC Bank or other PNC Wealth Management affiliates for additional products or services and will generally receive compensation for such referrals. A portion of the fees charged for the Capital Directions Annuities Program services described in this Brochure are paid to your Financial Advisor in connection with the introduction of Accounts as well as for providing client‐ related services within the Programs. This compensation may be more or less than a Financial Advisor would receive if you paid separately for investment advice, brokerage and/or other services. Certain employees of PNC Bank’s Wealth Management and or Private Client Group receive compensation in connection with referrals to PNC Wealth Management. PNC Wealth Management has related persons who are investment advisors who act as general partners in partnerships in which our clients may be solicited. PNC Wealth Management would not have knowledge of such solicitations should they occur, and consequently, would not be a participant in them, nor would we receive any compensation for them. Financial Information In certain circumstances, PNC Wealth Management would be required to provide you with financial information or disclosures about our financial condition. Currently, no such circumstances exist for PNC Wealth Management. PNC Wealth Management has no financial commitments that impair our ability to meet our contractual and fiduciary commitments to our clients and has never been the subject of a bankruptcy proceeding. Capital Directions Annuities Program October 17, 2025 Page 23 of 23 

Form ADV Part 2A Appendix 1 801‐66195 Disclosure Document for the PNC Guided Solutions Program An Investment Advisory Service of PNC Wealth Management LLC 300 Fifth Avenue Pittsburgh, Pennsylvania 15222 (800) 622‐7086 www.pnc.com October 17, 2025 This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of PNC Wealth Management LLC with respect to the PNC Guided Solutions Program (the “Program”). If you have any questions about the contents of this Brochure, please contact us at (800) 622‐7086. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. PNC Wealth Management LLC, a registered investment adviser and broker‐dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), is a wholly owned subsidiary of The PNC Financial Services Group, Inc. Registration does not imply a certain level of skill or training. Additional information about PNC Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. • NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, PNC BANK, N.A. OR ANY OF ITS AFFILIATES • SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED  Material Changes ADV Part 2A dated October 17, 2025 The following change(s) have been made to the PNC Wealth Management Guided Solutions Program Brochure since the last Brochure dated July 16, 2025: On or about October 17, 2025, our firm’s legal and business name will change from PNC Investments LLC to PNC Wealth Management LLC. This change is administrative in nature and does not affect the ownership, management, operation, services, or fees of the firm. All references to PNC Investments LLC within the Brochure will be updated to PNC Wealth Management LLC. No other material changes have been made since our last Form ADV 2A Brochure was filed on July 16, 2025. PNC Guided Solutions Program October 17, 2025 Page 2 of 34  Table of Contents About PNC Wealth Management LLC 4 .......................................................................................................... SERVICES, FEES AND COMPENSATION The PNC Guided Solutions Program Allocation Models Automatic Rebalancing Account Statements Account Termination Review of Accounts Securities Transferred into an Account Withdrawals from an Account Taxes Fees and Expenses Calculation of Account Fees Additional Fees for Brokerage Services Deduction of Account Fees Other Expenses Cash Balances Financial Advisor Compensation 4 4 5 10 10 10 11 11 12 12 12 17 18 18 18 21 22 ............................................................................................................. ............................................................................................................ ........................................................................................................................................ .............................................................................................................................. .................................................................................................................................. ................................................................................................................................. ................................................................................................................................... ..................................................................................................... .................................................................................................................. .......................................................................................................................................................... ..................................................................................................................................... ...................................................................................................................... ..................................................................................................... ....................................................................................................................... .......................................................................................................................................... ............................................................................................................................................ ............................................................................................................... ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients Collateral Accounts 23 23 24 ...................................................................................... .................................................................................................. .................................................................................................................................... PORTFOLIO MANAGER SELECTION AND EVALUATION Financial Advisor Selection and Evaluation Fund and Model Provider Selection and Evaluation PNC Wealth Management and Other Service Providers to the Program Risks of Investing in the PNC Guided Solutions Program Trading Practices Proxy Voting 25 25 26 26 26 28 29 .................................................................................. ............................................................................................... ................................................................................. ................................................. .......................................................................... ....................................................................................................................................... .............................................................................................................................................. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS 29 .................................................................... CLIENT CONTACT WITH PORTFOLIO MANAGERS 29 .......................................................................................... ADDITIONAL INFORMATION Disciplinary Information Other Financial Industry Activities and Affiliations Affiliate Transactions Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Client Reports Client Referrals and Other Compensation Financial Information 30 30 31 32 33 33 33 34 .......................................................................................................................... ............................................................................................................................ ................................................................................... ................................................................................................................................. ............................. ............................................................................................................................................ ................................................................................................ ................................................................................................................................ Page 3 of 34 PNC Guided Solutions Program October 17, 2025  About PNC Wealth Management LLC PNC Wealth Management LLC (“PNC Wealth Management,” “PNCWM” or the “Firm”) is an investment adviser and also a registered broker‐dealer and member of FINRA and SIPC. The Firm offers retail brokerage and investment advisory services. PNC Wealth Management serves as the sponsor of, and in some cases as a portfolio manager for, wrap fee investment programs. PNC Wealth Management is a wholly owned subsidiary of PNC Bank, National Association (“PNC Bank”) and is a part of The PNC Financial Services Group, Inc. (“PNC”) which is a diversified financial services institution with roots in commercial banking and investment management dating back to the early 1800s. Throughout this document, the terms “client,” “you,” and “yours” are used to refer to the individual(s), institution(s) or organization(s) who contract with us for the services described here. “PNC Wealth Management,” “we,” “our,” “us” and “the firm” refer to PNC Wealth Management LLC, together (as applicable) with our affiliates, including but not limited to, PNC and its agents with respect to any services provided by those agents. Our affiliates include any entity that is controlled by, controls or is under common control with PNC Wealth Management, including but not limited to our parent company, The PNC Financial Services Group, Inc. Each affiliate is a separate legal entity and not responsible for the obligations of any other affiliate. “Account” means each brokerage and/or advisory account you open with us that is subject to the PNC Guided Solutions Program investment management agreement (the “Investment Management Agreement”), including any and all mutual funds, exchange traded funds, money, securities, financial instruments and/or other property you have funded in such accounts. “Business Day” means Monday through Friday, excluding New York Stock Exchange holidays. “Wrap” refers to an Account that charges a quarterly or annual fee based on the average assets under management, where such fee covers administrative, commission, execution and management expenses. SERVICES, FEES AND COMPENSATION . Other This Brochure describes our PNC Guided Solutions Program (“Program”). In addition to the Program, PNC Wealth Management offers a variety of other investment advisory services. These include the Capital Directions Program, the Portfolio Solutions Program, the PNC Directions Program, the Portfolio Solutions Strategist Program, and the Capital Directions Annuities Program. More information about these programs and services is contained in the applicable PNC Wealth Management brochure and is available upon request from PNC Wealth Management or through the SEC’s website at https://adviserinfo.sec.gov/. For more information about these or other services that are available from PNC Wealth Management, please contact your Financial Advisor1 advisory services are offered by our affiliates. The PNC Guided Solutions Program The Program is a discretionary, unified investment advisory program that provides clients an integrated set of diversified portfolios through a single brokerage account. Within the Program, PNC Wealth Management has 1 We use the term “Financial Advisor” to refer to PNC Wealth Management’ branch‐based and wealth Financial Advisors, as well as Advisor Direct Financial Advisors and Investment Services Consultants. PNC Guided Solutions Program October 17, 2025 Page 4 of 34  discretionary authority and your Financial Advisor will exercise such authority to purchase or sell securities in your account without seeking your prior approval for each trade. The PNC Guided Solutions Program is designed for investors who wish to give PNC Wealth Management discretion to invest the assets in their Accounts according to the asset allocation model selected. Once you are in the Program, you will not have the ability to directly buy or sell individual securities in your Account, or to direct your Financial Advisor or any Model Provider to buy or sell securities in your PNC Guided Solutions Account. Your Financial Advisor will be reasonably available to consult with you regarding your Account, however, your Financial Advisor will not be required to discuss transactions with you prior to execution. Through your Financial Advisor, we will work with you to formulate an investment strategy based on your needs, circumstances, and investment goals; your Financial Advisor will help you complete an investor questionnaire to help us understand your unique situation. Your investment strategy will be implemented through the use of flexible asset allocation or income models (“Allocation Models”) investment manager models, mutual funds and/or exchange traded funds (collectively “Funds”) that are a part of the Program. PNC Wealth Management, through our Financial Advisor, will exercise discretion to invest your Account in all or a combination of equities, fixed‐income securities, Funds, and other securities and investment products made available through the Program now or in the future. The investor questionnaire provides us with an understanding of your financial situation, investment objectives, risk tolerance and investment time horizon. Based on the information collected in the investor questionnaire and other information you share with your Financial Advisor; your Financial Advisor will recommend an Allocation Model appropriate to your situation. Your Financial Advisor will help you understand the risk and return characteristics of the selected Allocation Model and help you evaluate the Allocation Model’s return potential in relation to your investment goals and objectives. After selecting your Allocation Model, PNC Wealth Management, through your Financial Advisor, will select for your portfolio a variety of approved Funds, investment models (“Investment Models”) offered by professional third‐party asset managers (“Model Providers”) as further described below, and individual equity or fixed income securities (collectively, “Investment Options”), available through the Program. We will present our investment strategy recommendation to you in the form of a proposal (the “Proposal”), which will include the actual initial investment portfolio recommended to you, for your acceptance and approval. It is very important that you understand the risks associated with the Allocation Model you select and should discuss this with your Financial Advisor if you have any questions. Allocation Models PNC Wealth Management uses five core asset allocation models, each associated with a distinct risk profile and comprised of a unique mix of investment assets that have been developed by PNC Bank’s Private Bank (the “Private Bank”) and approved by PNCWM’s Investment Due Diligence Committee. Furthermore, PNC Wealth Management may also conduct its own research, including gaining insights from non‐affiliated third parties, to be used in making asset allocation decisions for the Allocation Models, which from time‐to‐time may diverge from models developed by the Private Bank. Additional model investment strategies provided by professional third‐party investment managers are also available in a variety of investment types and styles. In all cases, PNC Wealth Management has sole discretion in approving and modifying the Allocation Models for the Program. These models are summarized below: PNC Guided Solutions Program October 17, 2025 Page 5 of 34   Conservative. The primary objective of the Conservative model is to generate a modest amount of current income, and secondarily to provide a modest amount of long‐term capital growth, which should help offset some of the effects of inflation. Long‐term growth of principal will be aided by income reinvestment. While the goal is to maintain a low‐risk posture, investors should be willing to accept periodic declines in portfolio value. Although past performance is no guarantee of future results, generally any such decline should be less severe than declines in the broader equity markets. The portfolio’s allocation between equity and fixed income securities, with an allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Moderate. The objective of the Moderate model is to generate a moderate amount of current income with the potential for longer‐term capital growth. The portfolio is evenly allocated between equity and fixed income securities, with a small allocation to cash, and is constructed to provide both long‐term capital appreciation in excess of inflation and a moderate amount of current income. While the current income generated could be available to meet your day‐to‐day expenses, reinvestment of income will increase the portfolio’s ability to exceed inflation over the long‐term. The portfolio’s allocation between equity and fixed income securities, with an allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Balanced. The primary objective of the Balanced model is to provide long‐term capital growth in excess of inflation, with a modest amount of current income as a secondary objective. The portfolio is allocated between equities and fixed income securities, with a higher allocation to a variety of equity securities. The portfolio also contains a small allocation to cash. While the current income generated could be available to meet your day‐to‐day expenses, income reinvestment will increase the portfolio’s ability to exceed inflation over the long‐term. This portfolio maintains a somewhat aggressive risk posture, and you should be willing to accept periodic declines in portfolio value. Because the portfolio is largely invested in equities, it can experience fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Growth. The primary objective of the Growth model is long‐term capital growth. It may secondarily generate a minimal amount of current income by including some fixed income securities. The portfolio is concentrated in equity investments in order to earn returns exceeding the rate of inflation over the long‐term. A small allocation to fixed income securities, as well as cash, is included primarily to help dampen volatility over the long‐ term. This portfolio maintains an aggressive risk posture, and you should be willing to accept potentially significant declines in portfolio value that may be similar to or exceed declines in the broader equity Page 6 of 34 PNC Guided Solutions Program October 17, 2025  markets. Because the portfolio is predominantly invested in equities, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Aggressive. The primary objective of the Aggressive model is long‐term capital growth. An Aggressive portfolio is concentrated in equity investments for long‐term growth. Returns in excess of the underlying rate of inflation are necessary to increase both principal and purchasing power. This portfolio maintains a highly aggressive risk posture, and you should be willing to accept potentially significant declines in portfolio value, similar to or greater than declines in the broader equity markets. The portfolio may contain a small allocation to fixed income securities as well as cash. Because the portfolio is predominantly invested in equity securities, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective. In addition to the asset allocation models, the Program offers two income models that have been developed by PNC Wealth Management based on input from PNC’s Investment Policy Committee. Each income model is associated with a distinct risk profile and comprised of a unique mix of investment assets. These income models are summarized below:  Core Fixed Income. The primary objective of this portfolio is total return comparable to a portfolio of investment grade domestic bonds. Capital preservation is a secondary objective. The minimum recommended time horizon for this portfolio is three to five years. This portfolio has a strategic allocation to U.S. investment grade bonds and tactical allocations to other non‐investment grade securities. The portfolio’s allocation to 100% fixed income securities exposes it to the risk of rising interest rates. Any decline experienced in this portfolio should be significantly less severe than declines in a portfolio that has significant equity exposure.  Core-Plus Fixed Income. The primary objective of this portfolio is total return incrementally higher than a portfolio of investment grade domestic bonds achieved through slightly more aggressive tactical decision making. A secondary objective is capital preservation. The suggested time horizon for this portfolio is at least three to five years. This portfolio invests in fixed income securities with an emphasis on total return and portfolio yield. This portfolio uses a broader range of credit quality securities which emphasizes slightly more tactical decision making. The portfolio’s allocation to 100% fixed income exposes it to the risk of rising interest rates and its allocations to high yield fixed income exposes it to credit risk. An alternative version of select asset allocation models is also available. The alternative models include an allocation to alternative strategy Funds (“Alternative Funds”) that are registered with the SEC under the Investment Company Act of 1940 (the “Investment Company Act”). Alternative Funds can use one of many different strategies including, but not limited to, long/short, managed futures, or market neutral. PNC Wealth Management will select the Funds and allocation in the alternative models, but you will have the ability to Page 7 of 34 PNC Guided Solutions Program October 17, 2025  modify the Funds or allocation selected. When alternative models are selected, the traditional asset classes in each model will be reduced on a pro rata basis. Alternative Funds seek to provide additional diversification benefits beyond those of a traditional portfolio of stocks and bonds. However, Alternative Funds are accompanied by risks that might be different from those associated with traditional investments. When used as part of an overall solution, alternatives may help to meet a client’s investment needs. Because Alternative Funds are regulated under the Investment Company Act, there are several ways in which they are structured to mitigate some liquidity risk, which may occur during severe market conditions, and differ from unregistered hedge funds and other alternative investments. You should carefully review the prospectus for any Alternative Fund you are considering for details on liquidity and other risks associated with them and review the manager’s ability to place limitations on liquidity. Alternative Funds are subject to: Limits on illiquid investments including a maximum of 15% of assets in illiquid investments; Limits on leveraging of no more than 33% of assets;    Diversification requirements including a maximum of 25% of assets invested in one issuer; and  Daily pricing and redeemability of fund shares. Alternative Funds are also prohibited from charging the types of management and performance based fees (e.g., a “2/20” fee) charged by some hedge funds. Before you open an Account in the PNC Guided Solutions Program, you should carefully review our Client Relationship Summary (“Form CRS”) and consider whether an advisory relationship is right for your situation and circumstances. You may discuss any questions you have regarding our Form CRS or whether an advisory account is right for you with your Financial Advisor. Some things you may wish to consider are: your preference for a fee‐based versus a commission based relationship; your desire for on‐going support and advice from your Financial Advisor; how much trading activity you expect to take place in your account; and the anticipated total costs. You should know that your Financial Advisor benefits when you open a PNC Guided Solutions account, as described in more detail in the Financial Advisor Compensation section of this Brochure, and has a conflict of interest when recommending an advisory account to you. PNC Wealth Management has delegated certain portfolio management services to Envestnet Asset Management, Inc., an unaffiliated investment adviser (the “Investment Delegate”) for Program Accounts. The Investment Delegate will implement Model Providers’ Investment Models (excluding Manager Traded Models as described below) and will facilitate the execution of trades in your Account as instructed by PNC Wealth Management. Manager Traded Models are fixed income Models, and trades for those Models are implemented by the Model Provider rather than by PNC Wealth Management or the Investment Delegate. Finally, PNC Wealth Management or your Financial Advisor will periodically exercise its discretion to adjust Allocation Models or remove Funds or Investment Models from our approved list. In all of these circumstances, PNC Wealth Management will update your Allocation Model and/or the Funds or Investment Models you have selected accordingly and, if necessary to align your account to the new investment model, will execute transactions in your account. Note that you will not be sent a new Proposal in these circumstances, unless requested through your Financial Advisor. Furthermore, PNC Wealth Management may, at its discretion, remove an asset allocation model from the schedule of available models and replace it with another model, without any prior notice to you. PNC Wealth Management retains the authority to limit the availability of any investment model offered by a Model Provider, or Fund, and/or to terminate or change investment models or Funds when circumstances are such that PNC Wealth Management believes a change is in your best interest. If an investment model or Fund is terminated, PNC Wealth Management will select a replacement investment without any prior notice to you. PNC Guided Solutions Program October 17, 2025 Page 8 of 34  Your Financial Advisor will periodically modify Investment Options selected for your Account or may adjust allocations among the Investment Options utilized in your Account. Your Financial Advisor will make such adjustments without first discussing or authorizing them with you. If your Financial Advisor makes such adjustments, he or she will sell your holdings in the terminated Investment Option and purchase shares in the substituted Investment Option. Certain of these changes will result in an increase/decrease to the fees discussed further herein (see Services, Fees and Compensation – Fees and Expenses). Although you will not be sent an updated Proposal in some circumstances described above, any changes to the Account’s fees will be reflected on future Account statements summarizing the activity in your Account. Before you may establish a PNC Guided Solutions Account, you must establish a brokerage account with PNC Wealth Management and agree to the terms and conditions of the PNC Wealth Management Brokerage Account Customer Agreement. By accepting and signing the Investment Management Agreement, you grant discretion over your Account to PNC Wealth Management and you authorize us, through your Financial Advisor, to invest and reinvest the assets in your Account in a combination of equity securities, fixed income securities, Funds, and other financial instruments in accordance with the Allocation Model that you have selected. The scope of any investment advisory relationship we have with you is defined in the Investment Management Agreement. When you are enrolled in the Program, we will act as your introducing broker and we will also act as your investment adviser, but only for your Program Account and not for any other assets or accounts, unless otherwise separately agreed to by us in writing. As discussed in more detail below, we earn certain fees and other revenue in connection to our capacity as introducing broker to your account. This is a conflict of interest because we would not earn such fees or revenue if we did not serve as your introducing broker. Our PNC Guided Solutions Program advisory relationship with you begins when we enter into an Investment Management Agreement with you, which occurs at the later of the date of acceptance of the signed Investment Management Agreement by PNC Wealth Management or the date on which you have contributed the required minimum level of assets to your Account. Preliminary discussions or recommendations before we enter into an Investment Management Agreement with you are not intended as investment advice under the Investment Advisers Act and should not be relied on as such. While your Financial Advisor will have discretion, you will retain, however, the ability to place reasonable restrictions on the securities that may be purchased for or held in your Account, subject to the review and approval of PNC Wealth Management as the manager of the Account and based on the investment model selected. In general, you may impose individual security restrictions, including Funds, and specific equity securities or industry restrictions. You may also have the ability to restrict certain bond characteristics, such as years to maturity, credit quality or duration. PNC Wealth Management will determine which specific securities fall within an industry restriction and will implement any industry restrictions in a manner it determines in its sole discretion from time‐to‐time. If an individual security restriction is reasonable, PNC Wealth Management will generally allocate assets that would have been invested in a restricted security to cash or one or more substitute securities, which may include ETFs, on a pro rata basis. Any restrictions you impose on individual securities will not apply to the underlying holdings of Funds. PNCWM offers values‐based investments, with categories such as gender, minority, religion, sustainability or environment, which seek to reflect a customer’s values by avoiding or increasing exposure to specific companies, sectors or practices. Certain religious values‐based investment managers invest in companies that generate income and returns inconsistent with a particular religion’s philosophies. In cases where this occurs, it PNC Guided Solutions Program October 17, 2025 Page 9 of 34  is the customer’s responsibility to determine the amount, if any, of non‐compliant generated income and/or gains. For more information about how to address these types of non‐compliant income or returns, please refer to the religious values‐based investment’s prospectus or disclosure agreement. Automatic Rebalancing The PNC Guided Solutions Program provides automatic rebalancing to ensure that the investments in your Account continue to conform to the selected allocation model. Asset allocations are monitored on a quarterly basis, and generally, we will rebalance an Account if any asset class varies by more than 3% from its target allocation within the model. In lieu of the Program’s default practice of rebalancing on a quarterly basis, you may request that periodic rebalancing for your Account occur on a less frequent basis of either semi‐annually or annually. You should consider, however, that less frequent periodic rebalancing, could cause your Account to diverge from the selected allocation percentages and such divergence could potentially negatively or positively impact performance. In addition to periodic automatic rebalancing, we will also rebalance your Account if you change your investment model, or when contributions to or withdrawals from your Account cause the cash balance to exceed 5% or be less than 0.5%, respectively, of the portfolio value. Occasionally, the total cash balance of your Account can exceed 5% when Model Providers utilized in your Account hold significant cash in their Investment Model or a Dollar Cost Averaging (“DCA”) method of funding has been selected (as further explained below). Further, you may also request, subject to approval by PNC Wealth Management, that an ad hoc rebalance be executed. In order to avoid the expense of inefficient rebalancing, we reserve the right, in our sole discretion, to from time‐to‐time change timeframes for effecting rebalances to your Account as well as the thresholds that must be exceeded before any rebalancing will occur. To rebalance an Account, we buy or sell, as relevant, shares of the individual Funds in an Account until its holdings match the Fund weight percentage specified for the applicable model. Rebalancing transactions are subject to short‐term trading policies, described more fully below, of Funds held in your Account, and, if your account is taxable, will create tax consequences for your Account. Please note that cash held outside of an Investment Model is not subject to rebalancing. Account Statements You will receive a monthly statement following any month in which there is investment activity in your Account, confirming all transactions in your Account, including additions, disbursements, purchases, sales, and advisory fees paid to PNC Wealth Management combined, if applicable with fees paid to Model Providers. For periods in which there is no investment activity in your Account, statements will be provided quarterly. You will also receive a quarterly performance report that tracks the performance of your portfolios against relevant benchmarks. You will be reminded quarterly to contact your Financial Advisor if you should have any questions, or if there have been material changes in your financial goals or needs that would affect your investment strategy. Account Termination Either party may terminate the Investment Management Agreement on 30 days’ written notice to the other party. You are also entitled to terminate such agreement within five (5) business days of your execution of it without incurring a Program Fee, defined below; you may, however, be subject to certain other fees incurred with respect to the Account for the relevant period. Upon the termination of the Investment Management Agreement, PNCWM will be under no obligation to provide advice on any holdings in your Account. Any transactions executed by you after the termination of the Investment Management Agreement will be subject to PNC Guided Solutions Program October 17, 2025 Page 10 of 34  fees and commissions described in the PNC Wealth Management Overview of Products and Services (the “Overview of Products and Services”). You may obtain a copy of our current Overview of Products and Services, at any time, by contacting your Financial Advisor, by contacting us at (800) 622‐7086 or online at www.pnc.com/investments‐relationship‐summary. In addition, upon learning of the death of any account owner, PNCWM will immediately terminate the Investment Management Agreement. You should be aware that any transactions executed by your heirs or beneficiaries after your death will be subject to fees and commissions described in the Overview of Products and Services, unless waived by us in our sole discretion. Please see the agreement governing your PNC Guided Solutions Program Account for more information. The Investment Management Agreement will continue in effect until terminated by you or PNC Wealth Management upon 30 days’ written notice to the other party. Review of Accounts When you open a PNC Guided Solutions Program Account, we review and must approve your investment objectives and strategy for consistency with PNC Guided Solutions Program guidelines. Thereafter, we will monitor the Account on an ongoing basis, including its performance, the appropriateness of the individual securities in it, and any investment restrictions that might apply. We will attempt to contact you at least semi‐annually, including by mail or email (if you have authorized us to send you electronic communications), to request that you review your Account and inform us of any changes to your financial profile or investment objectives. You should inform your Financial Advisor of any changes to your financial profile or investment objectives as they occur. If you elect to utilize an investment model offered by a Model Provider, you will have very limited, if any, direct contact with the Model Provider selected for your Account. Therefore, it is very important that you maintain contact and communication with your Financial Advisor. You should direct any inquiries about your Account, the allocation model or any Model Providers to your Financial Advisor. Finally, your Financial Advisor will be reasonably available to you for consultation about the Account. We encourage you to please contact your Financial Advisor if you have any questions. Securities Transferred into an Account You should be aware that if you transfer securities into a PNC Guided Solutions Account, any transferred securities that are not part of the recommended investments for your Account will be liquidated upon or shortly after transfer. Typically, this means that we will liquidate all of the securities you transfer into your account prior to investing your Account in the recommended investments. Your advisor may utilize a parking sleeve which will allow your Financial Advisor to set a plan to divest securities held inside your account but outside of your account’s model allocation. These funds may have embedded tax consequences and may benefit from transitioning those assets over time to match the makeup of your model. You should consult with your tax adviser to review these consequences. Your Financial Advisor may not use the parking sleeve feature for cash or high‐risk securities (e.g., low‐priced securities, thinly traded securities). Your Financial Advisor will be able to assist you in determining if a security is deemed high‐risk. Parking Sleeve securities are included in the account’s billable balance for two years from the transition date to your Account. If your account is not tax‐exempt, you will incur tax consequences as a result of these transactions. You should consult with your tax adviser to review these consequences. Additionally, if you liquidate securities prior to transferring your account to PNC Wealth Management or liquidate your securities prior to establishing your PNC Page 11 of 34 PNC Guided Solutions Program October 17, 2025  Guided Solutions account, you will likely incur transaction costs for those transactions. PNC Wealth Management will not reimburse you for transactions executed at another firm. Please note that if you transfer illiquid securities into a PNC Guided Solutions Account, it will delay management of that Account until such securities are transferred out or otherwise removed. You may, at your election, chose an optional Dollar Cost Averaging (“DCA”) feature when adding funds to your Program Account. With the DCA feature, you have the ability to deploy free cash to your Allocation Model over a defined period and in pre‐determined amounts. The DCA feature can enable clients to slowly invest excess cash over time, rather than make one lump‐sum investment. You have no obligation to complete scheduled DCA transactions and may terminate the DCA feature at any time, by providing notice to us, at least 5 business days prior to the next scheduled DCA transaction. You should know that if sufficient cash is not available in your Account at the time of a scheduled DCA transaction, that transaction, and all future scheduled DCA transactions will be canceled. You should also be aware that cash pending investment under an optional DCA plan will be treated as unallocated cash and swept to a deposit account at our affiliate bank, as described below. The parameters of DCA requests are subject to our approval. Withdrawals from an Account You should also be aware that if you request a withdrawal from a PNC Guided Solutions Account, your Financial Advisor may need to liquidate a portion of the Account to cover the requested withdrawal amount. If your account is taxable, you will incur tax consequences as a result. These transactions are subject to short‐term trading policies of Funds held in your account. Liquidation requests are processed according to our standard procedures and your liquidation request may not be completed on the day it was submitted. This is more likely if your request is submitted late in the day or during periods of severe market volatility. Cash is available for distribution three to five business days after the initial request is made, however, you should also be aware that liquidation transactions are at the discretion of the investment manager and could exceed this timeframe. Taxes You need to be aware that the Program operates in a manner that is not a tax efficient investment strategy, especially in taxable accounts, and will likely cause non‐retirement PNC Guided Solutions accounts to more frequently experience taxable gains and losses than a brokerage account holding individual securities for the same amount of time. When your Financial Advisor, at their discretion, sells securities to rebalance your asset allocation or to adjust your program model, the transaction will likely create a capital gain or loss for you. Additionally, any securities that you sell in order to raise cash to open and or be deposited into your account will likely create a capital gain or loss. These capital gains and losses are in addition to dividends and capital gains paid by the securities in the account. You should consider and discuss the potential tax implications of opening and maintaining a PNC Guided Solutions account with your tax adviser. Fees and Expenses You will pay both a program fee (the “Program Fee”) and, if your Financial Advisor elects to utilize an investment model offered by a Model Provider, a separate model provider fee (the “Model Provider Fee”) for the services provided under the PNC Guided Solutions Program. The Program Fee, and Model Provider fee, if applicable, will be combined and reflected on your account statement as the management fee (the “Management Fee”). You should be aware that your account is subject to the Management Fee whether you make or lose money on the investments. Each fee is calculated as a percentage of assets under management and will vary depending on the services provided to you. Generally, you will be charged commissions or service charges for transactions executed prior to establishing your PNC Guided Solutions account; you should discuss your options for funding Page 12 of 34 PNC Guided Solutions Program October 17, 2025  your account with your Financial Advisor. The Program Fee is based on the total assets under management, including any portion of the Account maintained in cash or in short‐term vehicles including, but not limited to, unallocated cash swept to a deposit account at our affiliate, PNC Bank, or money market funds. As the aggregate market value of the Program Account and if applicable, other managed accounts in the billing household reach a higher tier, as shown in the table below, the assets within that higher tier are charged a lower rate. Our standard Program Fee schedule is as follows: Assets Under Management Maximum Program Fee First $250,000 2.00% Next $250,000 1.75% Next $500,000 1.50% Next $1,000,000 1.25% Next $2,000,000 1.00% Over $4,000,000 Negotiable From time‐to‐time, we offer discounted pricing programs at our discretion. For example, current employees of PNCWM and their immediate family members are eligible for employee pricing. Your Financial Advisor has discretion to negotiate a Program Fee that varies from the standard schedule above. This can depend on certain factors, including the type and size of your Account, the range of services provided and the total amount you or other members of your household have invested with PNC Wealth Management. The Program Fee for your Account is referenced in the fee schedule included as part of the Proposal completed and accepted by you. The Program Fee you pay to PNC Wealth Management for the PNC Guided Solutions Program is charged quarterly in advance and will be based on the average daily balance in your PNC Guided Solutions Account over the prior calendar quarter or portion thereof (except in the case of a new PNC Guided Solutions Account). The Program Fee covers the cost of brokerage commissions and other transaction fees only for transactions executed through National Financial Services LLC (“National Financial”) on an agency basis. With respect to Investment Models, the Investment Delegate will typically route trades to National Financial for execution. From time‐to‐time, the Investment Delegate will trade through broker dealers other than National Financial when the Investment Delegate determines, in its sole discretion that this is in your best interest. Trades executed away from National Financial are described as “trading away” or “step‐out trades.” Model Providers will typically trade away for all trades when implementing trades in a Manager Traded Model. You will bear the cost of any brokerage commissions incurred on transactions executed through other brokers, dealer markups, markdowns and spreads when the Investment Delegate or a Model Provider trades away from National Financial. See the Additional Fees for Brokerage Services and Trading Practices sections below for further details. In addition to the Program Fee, if you elect to utilize an investment model offered by a Model Provider, you will PNC Guided Solutions Program October 17, 2025 Page 13 of 34  pay a separate Model Provider Fee for the services provided by the investment manager(s) that provide the investment model(s) you and your Financial Advisor has selected. The Model Provider Fee is based on the average daily balance of assets under advisement invested pursuant to the applicable investment model(s), including any portion of the Account maintained in cash, or in short‐term vehicles in excess of operational cash purposes including, but not limited to, unallocated cash swept to a deposit account at our affiliate, PNC Bank, or money market funds, over the prior calendar quarter, or portion thereof. PNCWM will bill Program Accounts on behalf of Model Providers and will remit payment to the appropriate Model Providers on behalf of Program Accounts. PNCWM does not anticipate retaining any portion of the Model Provider Fee. Current Model Provider Fees are set forth in the table below and are subject to change, without notice: Annual Fee 0.4 Model Provider Morningstar Dividend Non‐MLP Annual Fee 0.5 Model Provider AB Concentrated International Growth Equity AB Concentrated US Growth Alger Capital Appreciation Alger Mid Cap Growth 0.4 0.4 0.4 0.5 0.5 0.55 0.45 0.45 Morningstar Hare Non‐MLP Morningstar Tortoise Non‐MLP Neuberger Small Cap Intrinsic Value (SCIV) Neuberger Berman International ADR Nuveen Dividend Growth 0.45 0.38 0.4 0.4 0.38 0.38 0.27 Nuveen Intermediate‐Term Municipal Nuveen Limited Maturity Municipal Nuveen Long Term Municipal Nuveen Municipal Ladder 10‐25 Years Nuveen Municipal Ladder 1‐10 Years 0.28 0.28 0.28 0.17 0.17 0.4 0.27 0.27 Nuveen Municipal Ladder 1‐15 Years Nuveen Municipal Ladder 1‐7 Years Nuveen Municipal Ladder 5‐15 Years 0.17 0.17 0.17 0.15 PIMCO 1‐5 yr Corporate Ladder 0.23 0.15 PIMCO Low Duration 0.4 0.15 PIMCO Municipal Bond 0.28 0.38 0.27 PIMCO Total Return Polen Global Growth ADR 0.4 0.5 0.27 Polen U.S. Small Company Growth 0.6 0.27 Poplar Forest Contrarian Value Partners 0.4 Aristotle Value Equity Baird Chautauqua International Growth Equity Baird Mid‐Cap Growth Equity Baird Small/Mid Cap Growth BlackRock Capital Appreciation BlackRock Equity Dividend BlackRock Fundamental Core Taxable Fixed Income BlackRock Global Dividend Income ADR BlackRock Intermediate Municipal Fixed BlackRock Intermediate Taxable Fixed Income BlackRock Laddered Municipal (10‐20 Year) Fixed Income BlackRock Laddered Municipal (1‐10 Year) Fixed Income BlackRock Laddered Municipal (1‐5 Year) Fixed Income BlackRock Large Cap Value BlackRock Long‐Term Municipal Fixed Income BlackRock Short‐Term Municipal Fixed Income BlackRock Short‐Term Taxable Fixed Income BNYM Walter Scott International Stock ADR 0.5 Principal Real Estate Securities 0.45 PNC Guided Solutions Program October 17, 2025 Page 14 of 34  Boston Partners All Cap 0.4 0.38 0.45 0.3 Principal Spectrum Tax Advantaged Preferred Securities Principal US Small Cap Equity Principal US Small Cap Value 0.45 0.45 0.3 QRG QP: Market Series All Cap Core** 0.2 0.2 Boston Partners International Equity ADR Boyd Watterson All ETF Ultra Enhanced Core Boyd Watterson Investment Grade Intermediate Boyd Watterson Limited Duration* 0.3 Boyd Watterson Ultra Enhanced Core* 0.3 0.4 0.38 0.4 Brown Advisory Large‐Cap Sustainable Growth Causeway Global Value ADR Causeway International Value ADR Cincinnati High Yield Fixed Corp Bond 0.45 0.45 0.4 0.2 0.25 0.25 ClearBridge Appreciation ESG 0.48 0.15 ClearBridge Dividend ESG Strategy 0.48 0.15 0.2 ClearBridge Dividend Strategy 0.43 0.2 ClearBridge International Value ADR 0.43 0.2 ClearBridge Large Cap Value 0.43 0.2 ClearBridge Small Cap Growth 0.48 0.2 Columbia Contrarian Core 0.4 0.2 Columbia Dividend Income 0.4 0.2 Dana Large Cap Equity 0.45 Dana Municipal Bond* Dana Small Cap Core Equity 0.3 0.45 0.2 Dean Capital Mid Cap Value 0.4 0.45 Diamond Hill Large Cap 0.4 0.3 EARNEST Partners Mid Cap Core 0.48 QRG QP: Market Series All Cap Core ‐ Low Minimum** QRG QP: Market Series Emerg Mrkts ADR** QRG QP: Market Series Emerg Mrkts ADR ‐ Low Minimum** QRG QP: Market Series Global** QRG QP: Market Series Intl ADR** QRG QP: Market Series Intl ADR ‐Low Minimum** QRG QP: Market Series Large Cap Core** QRG QP: Market Series Large Cap Core ‐ Low Minimum** QRG QP: Market Series Large Cap Dividend Income** QRG QP: Market Series Large Cap Dividend Income ‐ Low Minimum** QRG QP: Market Series Large Cap Growth** QRG QP: Market Series Large Cap Growth ‐ Low Minimum** QRG QP: Market Series Large Cap Value** QRG QP: Market Series Large Cap Value ‐ Low Minimum** QRG QP: Market Series Mid Cap Growth** QRG QP: Market Series Mid Cap Value** 0.2 0.2 QRG QP: Market Series Small Cap Core** QRG QP: Market Series Small Cap Core ‐ Low Minimum** QRG QP: Sustainable Emerging Markets ADR Portfolio** QRG QP: Sustainable International ADR** PNC Guided Solutions Program October 17, 2025 Page 15 of 34  EARNEST Partners Mid Cap Value 0.48 0.3 Earnest Partners Small Cap Core 0.5 0.25 EARNEST Partners Small Cap Value 0.5 0.25 Federated International Strategic Value 0.45 0.25 0.4 0.2 0.2 QRG QP: Sustainable Large Cap Core ‐ Catholic Values** QRG QP: Sustainable Large Cap Core‐ Gender and Diversity** QRG QP: Sustainable Large Cap Core Portfolio ‐ ESG** QRG QP: Sustainable Small Cap Core Portfolio ‐ ESG** QRG QP: SustainableGlobal Climate** QRG: 1‐10 Yr Corp Ladder QRG: 1‐10 Yr Muni Ladder 0.3 0.095 0.095 Federated Strategic Value Dividend Franklin Intermediate Muni* Franklin Portfolio Advisors Intermediate Fixed income GW&K Core Bond* Harding Loevner International Equity ADR 0.3 0.45 0.3 0.3 Invesco Tax Free Limited Term Ithaka Growth 0.23 0.4 0.5 0.45 Janus Henderson Mid Cap Growth 0.44 0.45 0.45 Jennison International Equity Opportunities 0.48 0.45 Jennison Large Cap Growth Equity 0.4 0.45 Jensen Quality Growth Discipline 0.45 RNC Genter Muni Quality Intermediate Sage Advisory Tactical ETF Core Plus Fixed Income Managed Account Salient MLP Managed Account Schafer Cullen Global High Dividend Value ADR Managed Account Schafer Cullen International High Dividend ADR Managed Account Schroders International Alpha ADR Managed Account Segall Bryant & Hamill Small Cap Growth Managed Account Stonebridge Tax‐Advantaged QDI Preferred Securities Managed Account 0.4 John Hancock US Small Cap Core 0.5 0.48 JP Morgan Equity Income 0.4 0.38 Kayne Anderson Rudnick Small Cap 0.5 0.38 Lazard Emerging Markets Equity Select ADR 0.5 0.5 Lazard US Equity Select Tax‐Aware 0.4 0.4 Leeward (LMCG) Mid Cap Value 0.4 0.4 Loomis Sayles Large Cap Growth 0.45 Suncoast Large Cap Growth Managed Account T. Rowe International Core Equity Managed Account T. Rowe Price US Growth Stock Managed Account T. Rowe Price US Value Equity Managed Account T. Rowe US Large‐Cap Core Equity Managed Account The London Company Income Equity Managed Account The London Company SMID Managed Account Tributary Small Cap Core 0.42 0.27 TS&W Mid Cap Value Managed Account 0.4 Lord Abbett Intermediate Tax‐Exempt Fixed Income Lord Abbett Long Municpal 0.27 Page 16 of 34 PNC Guided Solutions Program October 17, 2025  Madison Mid‐Cap Equity 0.45 0.4 Mar Vista Strategic 0.4 0.55 Martin Currie Emerging Markets 0.6 0.55 MFS Large Cap Growth 0.43 0.45 Miller/Howard MLP Strategy Morningstar Absolute Return Strategy‐BNY Morningstar All‐Cap Equity 0.55 0.02 0.5 0.45 0.45 0.42 Vaughan Nelson Select Managed Account WCM Focused Growth International Managed Account WCM Quality Global Growth Managed Account Westfield Mid Cap Growth Equity Managed Account Westwood Small Cap Managed Account Westwood SMidCap Managed Account WST Asset Manager Credit Select Risk Managed Account Morningstar Dividend Managed 0.5 *Strategist Traded Model **Tiered Fee Schedule ‐ Maximum Rate is Displayed Calculation of Account Fees The Program Fee and the Model Provider Fee will be paid in advance following the end of each calendar quarter for the upcoming quarter and will be calculated on the last business day of the quarter as follows. The Program Fee is calculated based upon the average daily market value of the total assets in the Account over the prior calendar quarter, including cash holdings. Cash holdings in excess of 7.5% (operational cash purposes i.e., trading and account maintenance needs) will be excluded from the average daily market value calculation when the Program Fee is calculated. The Model Provider Fee is calculated based on the average daily market value of assets in the Account invested pursuant to the applicable investment model(s), including any portion of such assets maintained in cash, money market funds or other short‐term vehicles pursuant to the applicable investment model(s), over the prior calendar quarter. Because the Model Provider Fee differs based upon the investment options selected for the Account, the actual aggregate fees charged to the Account will be based upon the fees attributable to the investment options included in the Account at the time of the fee calculation (i.e., the last business day of the calendar quarter). Accordingly, it is important to note that changes in the Account’s asset allocation caused by rebalancing, as well as changes among the types of investment options, during a particular calendar quarter will cause the aggregate of the Program Fee and the Model Provider Fee to be higher or lower than such aggregate amount would have been if calculated based on the composition of the investment options actually held in the Account during the relevant calendar quarter. Upon your request, we will provide you with a detailed explanation of the fee calculation which will allow you to recalculate the fees should you so desire. If your Account is new, you will pay an initial fee after the date that National Financial, the custodian, receives the initial assets of your Account. An adjustment to the next quarterly fee will be made for any significant contributions or distributions that occur during the inception quarter of your Account. With your initial contribution and for any additional contribution or distribution adjustments, your fee will be calculated for that portion of the ongoing quarterly Program Fee that relates to the number of days remaining in the calendar quarter as of the date your Account becomes subject to the Investment Management Agreement or that you make the additional contribution or distribution, as applicable. This Program Fee will be based on the total market value of assets in your Account on that date. Page 17 of 34 PNC Guided Solutions Program October 17, 2025  If your Account is terminated by you or PNC Wealth Management during a calendar quarter, the fee for that quarter will be prorated over the number of days that the Account was open during the quarter. Any overpayment will be refunded to you after the Account is closed. Fees are not prorated for contributions or withdrawals made during a calendar quarter, except in the case of a new or terminated Account, as outlined above. If you terminate your PNC Guided Solutions account within 90 calendar days of initial investment, PNC Wealth Management reserves the right to charge you commissions, according to the Overview of Products and Services, for transactions executed on your behalf during the time your account was managed, less any pro‐ rated advisory fee paid by you. Additional Fees for Brokerage Services PNC Wealth Management will charge its standard fees for additional brokerage account services that are not included in the Program. Such fees include, but are not limited to, account termination/transfer fees, wire transfer fees, IRA fees and stop payment fees. You should be aware that in some cases, PNCWM retains this entire fee or marks up the fee our clearing firm, National Financial, charges to PNCWM for these services. This is a conflict of interest for us because PNCWM has an incentive to utilize a clearing firm that allows us to mark‐up designated fees. PNCWM also has incentive to recommend to you services that have been marked‐up. Please refer to the Account Level Fees section of the Overview of Products and Services for details. Deduction of Account Fees All fees incurred by the Account will be paid from the cash balance or by selling shares of a money market mutual fund. If the Account does not have a sufficient cash balance or enough money market mutual fund shares to cover the fees, we will liquidate other securities as necessary to pay them. Selling securities to pay fees is subject to the short‐term trading policies of Funds and, if your account is taxable, will create tax consequences for you. You may contact your Financial Advisor if you have any questions regarding the fees charged to your Account. Other Expenses Each Fund in which your Account is invested charges its own separate fund‐level fees and operating expenses, including, for example, administrative, custody, transfer agent, legal and audit fees and expenses, investment advisory or management fees, shareholder servicing fees, omnibus accounting fees, fees for sub‐administration, recordkeeping, print mail services and other expenses. These fees and operating expenses are ultimately borne by the shareholders invested in the Fund, including you, and will reduce your investment returns. Other classes of mutual funds have lower fund‐level fees and expenses than those used in this Program. Please review the relevant Funds’ prospectuses for a full explanation of fund expenses and charges. PNC Wealth Management includes in the Program only “Approved Share Classes” of mutual funds, which are share classes that generate revenue sharing payments, as described below, to PNCWM. PNCWM will select Approved Share Classes that are either (i) share classes that trade on our custodian’s Institutional No‐ Transaction Fee platform (“INTF Eligible” share classes); or (ii) if no such INTF Eligible share class is available, the least expensive non‐INTF Eligible share class eligible for inclusion in the Program. PNC Wealth Management uses INTF Eligible share classes in order to reduce PNC Wealth Management’ overall program trading costs, which costs would otherwise be payable by PNC Wealth Management. These selection criteria represent a conflict of interest for us because they enable PNC Wealth Management to avoid costs, but also may result in you purchasing a share class that is more expensive than other share classes of the same fund for which you are eligible. You acknowledge that when you establish a Program Account, you authorize and direct PNC Wealth Page 18 of 34 PNC Guided Solutions Program October 17, 2025  Management to purchase for your Account only Approved Share Classes using the criteria described above and you waive any obligation of PNC Wealth Management, if applicable, to purchase any other share classes for your Account, even if less expensive share classes are available. A higher cost share class will adversely affect the investment performance of your account. INTF Eligible share classes do not typically charge shareholders 12b‐1 fees or pay those fees to us or our custodian, which reduces costs to you, as compared to share classes that do pay 12b‐1 fees. As described more fully below, money market funds held in your Account typically charge 12b‐1 fees, but we will rebate any such fees we receive. Please note that the mutual funds included in the Program may provide compensation such as fees for omnibus accounting, sub‐administration, shareholder services, recordkeeping, print mail services or other related fees (“Mutual Fund Compensation”). While we do not expect to receive such fees, PNC Wealth Management will credit to your Account any Mutual Fund Compensation or 12b‐1 fees paid to us in connection with the holdings in your Account. Our custodian or other entities not affiliated with PNC Wealth Management may receive Mutual Fund Compensation. PNC Wealth Management is not a party to such arrangements and we will not credit your Account for Mutual Fund Compensation received by such entities. You should be aware that any Mutual Fund Compensation paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. Exchange‐traded funds, or ETFs, are similar to mutual funds in that they invest in a basket of securities, such as stocks, bonds, or other asset classes. Unlike mutual funds, however, ETFs trade on an exchange and their price can change throughout the day and may vary from the value of the underlying assets in the investment portfolio. There are three different types of ETFs: Index based or Passive – which track a specified index such as the S&P 500 or NASDAQ Composite Index, Smart beta – which invest in factors through a rules‐based index (low‐ volatility, equal‐weight, etc.), and actively managed – which are not tied to an index and offer portfolio manager flexibility and security selection with the intent to outperform a benchmark. Most ETFs publish their holdings daily. ETFs have internal operating expenses that reduce investment returns. Active ETFs generally, have higher internal operating expenses than other ETF types. ETFs typically have lower expenses than mutual funds that are actively managed. However, even though a mutual fund in the same asset class as an ETF may be more expensive, other factors such as ETFs that trade less frequently could make a mutual fund more advantageous. PNC Wealth Management receives an annual credit from National Financial (the “ETF Revenue Share Credit”). The ETF Revenue Share Credit is projected based on future sales of actively managed ETFs through National Financial. PNCWM's receipt of the ETF Revenue Share Credit is dependent on National Financial sharing a portion of its actively managed ETF revenue. With the receipt of the ETF Revenue Share Credit, we are incentivized to recommend actively managed ETFs over other ETFs and products in which we either receive less or no revenue share as compared to the ETF Revenue Share Credit. We are also incentivized to select and continue our relationship with National Financial to receive the ETF Revenue Share Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. We will retain the ETF Revenue Share Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the ETF Revenue Share Credit. You should be aware that any ETF Revenue Share Credit paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. PNC Wealth Management receives an annual credit from National Financial (the “Business Development Credit”). The Business Development Credit is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. PNCWM is incentivized to select and continue its relationship with National Page 19 of 34 PNC Guided Solutions Program October 17, 2025  Financial to receive the Business Development Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. The Business Development Credit is not related to the sale or offer of any specific products or services, nor is it dependent upon assets under management. If received, we will retain the Business Development Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the Business Development Credit. Additionally, if under certain circumstances our clearing arrangement with National Financial is terminated prior to the expiration of our agreement, PNCWM is subject to certain contractual fees and penalties (collectively, the “Termination Fee”). The Termination Fee creates a strong disincentive for PNCWM to consider clearing relationships other than National Financial. This creates a conflict of interest for us as we expect to benefit from the continued recommendation of National Financial as our clearing firm. Additionally, PNCWM is further incentivized to continue the relationship with National Financial as we may not receive the same incentives from other clearing firm arrangements, such as receiving particular credits from National Financial or having the ability to mark‐up certain fees to clients. PNC Wealth Management receives additional compensation, referred to as revenue sharing, from the advisors or distributors of the mutual funds offered in the Program, which compensates us for administrative services we provide to them and is based on the amounts our customers invest in those mutual funds in the Program. Our independent due diligence process for selecting mutual funds and ETFs for the Program is designed so that these products are selected based on objective, investment related criteria and does not take into account compensation to PNC Wealth Management. However, only funds for which we receive revenue sharing are considered for inclusion in this due diligence process. This is a conflict of interest for us because mutual funds and or certain ETFs that may otherwise meet our investment criteria are not included in the Program because their advisors or distributors do not offer revenue sharing to PNC Wealth Management. In addition, we receive a higher revenue share amount on mutual funds than ETFs. This is a conflict of interest for us when there are similar products offered in both product categories as we will be paid more revenue share when recommending mutual funds than if an ETF is recommended. We will not credit your Accounts for any revenue sharing payments we receive. Although we include only mutual funds and certain ETFs whose sponsors pay PNCWM revenue sharing, we believe this conflict is mitigated by the large and diverse universe of Funds we make available in our programs which meet our clients’ needs. Your Financial Advisor is not paid any part of the revenue sharing arrangements. You should also be aware that we will liquidate mutual funds and or certain ETFs held in your Account if the advisors or distributors of those funds discontinue their participation in our revenue sharing program. If your Account is taxable, you will have tax consequences as a result of such liquidations. PNC Wealth Management offers other advisory programs that include Funds whose advisors and distributors do not participate in revenue sharing. You can discuss our other advisory program options with your Financial Advisor if you wish to invest in Funds outside our revenue sharing program. We will not credit your Account for any revenue sharing payments we receive. For details on revenue sharing received by PNC Wealth Management from mutual fund and certain ETF advisors or distributors, please see the following link: https://www.pnc.com/content/dam/pnc‐com/pdf/personal/wealth‐management/Additional‐Compensation‐ Disclosure.PDF For more information around the compensation a particular mutual fund or ETF provider may pay, please refer to the Fund’s prospectus and/or Statement of Additional Information. Page 20 of 34 Additionally, some Funds impose redemption fees depending on the share class, if they are redeemed within a specified time period, to discourage short‐term trading or for other reasons. The relevant Fund company retains these redemption charges from the proceeds of the redemption for the benefit of the remaining shareholders of PNC Guided Solutions Program October 17, 2025  the Fund. Refer to the prospectus or Statement of Additional Information of relevant Funds for details on each Funds’ short‐term trading policies. The amount of such fees and charges retained will be reflected on your account trade confirmations. Purchasing securities in the Program may cost you more or less than purchasing the securities directly from the funds or through agents of the funds without enrolling in the Program, including through a brokerage account at PNC Wealth Management. By purchasing mutual funds outside of the Program, you may invest in a single fund family and obtain “breakpoints” that could lower the cost of the Funds. However, if you purchase mutual fund shares directly, you may not receive the discretionary investment management, asset allocation and account monitoring services available via the Program and may not qualify to invest in share classes available to investors through the Program. In addition, mutual funds purchased outside the Program may charge commissions, front‐ end or back‐end sales charges, and redemption fees, depending on the share class. Finally, your Account may be invested in Funds for which PNC Wealth Management or one of our affiliates acts as an advisor, sub‐advisor, or administrator, and receives a fee for such services. Therefore, PNC Wealth Management or an affiliate receives fees for the services provided to the Funds. The level of advisory or sub‐ advisory fees paid to PNC Wealth Management or its affiliates by such Funds, is disclosed in the Prospectus and/or Statement of Additional Information of such Funds. The maximum amount of your Account assets that may be invested in Funds, which pay advisory or sub‐advisory fees to PNC Wealth Management or its affiliates will depend on many factors, but in certain circumstances may reach 100% of your Account assets. You should ask your Financial Advisor about these advisory or sub‐advisory fees, and you may terminate your Investment Management Agreement with PNC Wealth Management at any time if you have any concerns about the level of these fees or the incentives that they create. PNC Wealth Management has an obligation to invest your assets in a manner that considers your best interest. To that end, PNC Wealth Management will take steps to minimize potential conflicts of interest that arise from investing with Funds that pay PNC Wealth Management or its affiliates advisory or sub‐advisory fees, to the extent required by applicable federal or state laws. PNC Wealth Management evaluates the appropriateness of investing your assets in Funds managed by affiliates of PNC Wealth Management, in the same manner as it evaluates all other Funds available through the Program. Cash Balances Unallocated cash will be automatically swept through the Bank Deposit Sweep Program (“BDSP”) into an interest‐bearing deposit account (“Deposit Account”) at our affiliate, PNC Bank (and, as noted above, are included in the assets on which Management Fees are charged). The interest rate (“BDSP interest rate”) for BDSP assets held in the Deposit Account is determined by PNC Bank with input from PNC Wealth Management such as objective competitive market data. BDSP is the only cash sweep option available to your Program Account. The only exception is in very limited situations where your account type is not eligible for BDSP (such as participant accounts of employer sponsored qualified plans) and your funds will be invested in a money market mutual fund selected by us. You should be aware that although assets held in the Deposit Account are protected by FDIC insurance neither PNC Wealth Management nor PNC Bank will monitor whether BDSP deposits, individually or in combination with other deposits you hold at PNC Bank, exceed FDIC insurance limitations. You should review your cash balance held in the Deposit Account and other PNC Bank accounts to ensure that cash balances do not exceed FDIC insurance coverage levels, or alternatively, in the event your cash balance exceeds FDIC insurance limitations, that you are comfortable with the risks associated with having uninsured cash. The rate of return you receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to such cash Page 21 of 34 PNC Guided Solutions Program October 17, 2025  balances. PNC Bank uses the BDSP program assets to fund its lending activities, allowing PNC Bank to earn revenue based on the difference between the rate paid to you and the higher rate of interest earned by lending the assets to its customers. Moreover, PNC Wealth Management receives revenue from PNC Bank based on the assets in the BDSP, this revenue amount varies depending on market conditions, but will not exceed the current Federal Funds Target Rate Range – Upper Limit rate (available online at https://fred.stlouisfed.org/series/DFEDTARU) plus 0.50%. This means PNC Wealth Management benefits in two ways from placing assets in the BDSP (i.e., the Management Fee and the revenue share from our affiliate). We will not credit any portion of this revenue to your Program Account. Note that the revenue earned by PNC Wealth Management and our affiliate PNC Bank will significantly exceed the interest credited to your Program Account from the allocation to BDSP. The revenue we receive is a conflict of interest for us, because we, and our affiliate, PNC Bank, obtain a financial benefit when your unallocated cash is held through the BDSP in a Deposit Account. This financial benefit is greater than the financial benefit we would receive if your unallocated cash was invested through a different cash sweep vehicle such as a money market fund, which could pay you a higher rate of interest. For information pertaining to the interest rate spread earned by PNC on all loans, including those generated from BDSP assets, please see the Net Interest Margin discussion in the most recent Annual Report on Form 10‐K and subsequent Quarterly Reports on Form 10‐Q for The PNC Financial Services Group, Inc., available at, https://investor.pnc.com/financial‐information/financial‐results. Account assets invested through the BDSP typically will pay you less interest – and in some market conditions, much less interest – than they would if invested in alternative cash sweep vehicles that are available to PNC Wealth Management such as a money market fund. Accordingly, you should not participate in the Program if you wish to hold your unallocated cash in another sweep vehicle. (Please note that while BDSP is used as the sweep option to hold unallocated cash, if your account has an investment allocation to cash, that allocation will typically be held in money market mutual funds or other short duration securities.) The rate of return you receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to such cash balances. You should also know that Model Providers utilized in your Program Account will have discretion to select the vehicle (BDSP, money market mutual fund or other short duration security) for any cash in the Investment Model. For more information regarding BDSP, including information about FDIC insurance limitations, please see the PNCWM BDSP Disclosure Document, you may also review the current BDSP interest rate at the following link: https://www.pnc.com/en/personal‐banking/investments‐and‐retirement/sweep‐program‐ rates.html. Additionally, information about FDIC insurance can be found on https://www.fdic.gov/resources/deposit‐insurance/ Financial Advisor Compensation A portion of the fees charged for Program services will be paid to your Financial Advisor in connection with opening and managing your Account, as well as for providing client‐related services within the Program. PNC Wealth Management typically will advance to Financial Advisors a portion of the first year’s estimated fees for clients who invest in the Program. In addition, certain Financial Advisors who typically work with higher net worth clients can earn enhanced upfront compensation when customers establish a new advisory account or add new assets into an existing advisory account with us. This compensation creates a conflict of interest because these Financial Advisors have an additional incentive to encourage clients to place their funds in PNC Guided Solutions Program October 17, 2025 Page 22 of 34  investment advisory accounts. This compensation may be more or less than a Financial Advisor would receive if you transacted in a brokerage account, rather than a managed account in the PNC Guided Solutions Program, and paid separately for investment advice, brokerage and other services covered by the Program Fee. Therefore, your Financial Advisor may have greater financial incentive to offer a managed product over a brokerage product. We address this conflict through established policies and procedures reasonably designed to ensure that any recommendation made is suitable for your unique circumstances. As disclosed above, certain of our Programs charge a negotiable Program Fee and others charge a negotiable Program Fee plus a Model Provider Fee, which in certain circumstances may be waived but is not negotiable. Differences in fees for Model Providers in Programs with a third‐party manager, or the absence of such fees in any Program, create a conflict of interest as such differences provide an opportunity for Financial Advisors to negotiate a higher Fee for a strategy with lower or no separate Model Provider Fees than they would for strategies that charge a higher Model Provider Fee. The opportunity to negotiate a higher fee also creates a financial incentive for Financial Advisors to recommend such Programs and/or Model Providers. The ability of the Financial Advisor to negotiate a higher Program Fee in these circumstances also provides a financial benefit to PNC Wealth Management, which retains a portion of the Program Fee. Occasionally, Program Accounts may be reassigned from the originating Financial Advisor to a new Financial Advisor because the originating Financial Advisor leaves our firm, takes a new position, or for other reasons. Financial Advisors receive less compensation for accounts reassigned to them (“Reassigned Accounts”) than accounts they originated and therefore have a conflict of interest because they have a financial incentive to provide better service to accounts that they have originated versus Reassigned Accounts. Financial Advisors receive additional compensation when clients add funds to Reassigned Accounts and have incentive to encourage additional deposits to Reassigned Accounts. From time‐to‐time, PNC Wealth Management initiates incentive programs for its employees including Financial Advisors. These programs include, but are not limited to, programs that compensate them for attracting new assets and clients, or for referring business to our affiliates (such as referrals for mortgages, trusts, or insurance services); programs that reward them for promoting investment advisory services, in some circumstances by enhancing revenue credits paid to them in connection with new advisory accounts or additions to existing advisory accounts, for participating in advanced training, and for improving client service; and programs that reward Financial Advisors who meet total production criteria. Financial Advisors who participate in these incentive programs are rewarded with cash and/or non‐cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. These programs may be partly subsidized by external vendors or our affiliates, such as mutual fund companies, insurance carriers or money managers. Therefore, our Financial Advisors have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services that we offer. Additionally, please note our Financial Advisors are still subject to our reasonably designed policies and procedures to ensure that any recommendation made is suitable for your unique circumstances. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients The minimum account size for the PNC Guided Solutions Program is $500,000. We may terminate the advisory services on any Account that falls below minimum account value guidelines established by the firm on 30 days’ Page 23 of 34 PNC Guided Solutions Program October 17, 2025  written notice to the Account holder. To avoid termination, you may be required to deposit additional assets in your Account to remain in the PNC Guided Solutions Program. Under certain limited circumstances, we may waive the minimum account size requirement. In addition, Model Providers utilized for the Program typically impose their own investment minimums and may limit or terminate the availability of their model for Accounts that fall below this minimum with 30 days’ notice to PNC Wealth Management. Upon receipt of such account minimum notices from a Model Provider, PNC Wealth Management will use commercially reasonable efforts to identify another Model Provider that is consistent with or substantively similar to the model and/or Model Provider that has terminated the availability of their model and resume a continuous investment program for the Account. PNC Wealth Management will have limited or no ability to waive Model Provider minimums. Collateral Accounts You will not be able to obtain a margin loan using the securities in your Account as collateral. However, under certain circumstances you may elect to pledge the assets in your non‐IRA/ERISA Account as collateral for a general purpose loan with our affiliate, PNC Bank, or other financial institution (collectively the “Lending Arrangements”). When your Account assets are pledged or otherwise used as collateral in connection with Lending Arrangements, you give the lender certain rights and powers over the assets in the Account. Importantly, lenders have the right to direct PNC Wealth Management to sell or redeem any and all assets pledged as collateral for the loan. In the event of a collateral call on the Account, securities will be liquidated from the Account, which may be contrary to your interests and/or inconsistent with the investment strategy for the Account because positions may be redeemed or liquidated more rapidly (and/or at significantly lower prices) than might be desirable. You or your Financial Advisor may not be provided with prior notice of the liquidation of the securities in the Account. Furthermore, you and your Financial Advisor may not be entitled to choose the securities to be liquidated. After the execution of a collateral call, any remaining securities in the Account may be lower in value than the investment minimums required for the PNC Guided Solutions Program and the Account may be subject to termination as described above. You may wish to discuss with your Financial Advisor how a collateral call could impact you if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. Any action taken by us, or an affiliate, with respect to the assets held in your Account pursuant to the Lending Arrangements will not constitute a breach of our fiduciary duties as an investment adviser to you under the PNC Guided Solutions Program. The costs associated with the Lending Arrangements are not included in the Program Fee you pay under the Program. Your transaction costs may rise as a result of a collateral call, because securities may be liquidated under unfavorable market conditions. You should consult with your own independent tax adviser in order to fully understand the tax implications associated with the Lending Arrangements. The securities subject to the collateral call will not be liquidated in a manner that considers tax efficiency. PNC Wealth Management does not provide legal, tax or accounting advice. You are encouraged to speak with your Financial Advisor to the extent you have questions about the Program, the Lending Arrangements and how they may impact the management of your Account. You should be aware that PNC Wealth Management and your Financial Advisor have a conflict of interest because PNC Wealth Page 24 of 34 PNC Guided Solutions Program October 17, 2025  Management and your Financial Advisor’s compensation is based on the assets held in your account and benefits if you enter into a Lending Arrangement instead of withdrawing funds from your account. In addition, you should be aware that PNC Wealth Management and your Financial Advisor will be compensated based on the amounts you draw on the credit line. This is a conflict of interest for your Financial Advisor because he or she has an incentive to recommend Lending Arrangements as opposed to other potential funding sources, because your Financial Advisor is not compensated for other options. In addition, PNC Bank generates revenue by charging interest on any loan underwritten by PNC Bank, which represents a further conflict of interest for PNC Wealth Management. Qualification criteria and requirements, including but not limited to, approval criteria, underwriting standards, loan to value requirements, maintenance requirements and asset eligibility vary by program. You should refer back to the Lending Arrangements and associated documents for the specific terms governing the Lending Arrangements. PORTFOLIO MANAGER SELECTION AND EVALUATION The PNC Guided Solutions Account is managed to diversify your investments and may include investments in equity and fixed‐income securities, and Funds, including money market instruments. Accounts are managed on an individual basis, and our investment decisions are determined by and based on our understanding of your financial situation, investment objectives and risk tolerance. You will not have the ability to direct PNCWM or your Financial Advisor to execute specific transactions in your Program Account. You may, however, impose further reasonable restrictions and guidelines on your Account, but these will affect the composition and performance of your portfolio. Additionally, although your Financial Advisor will exercise discretion in your Account, the performance of your Account will not be monitored on a day‐to‐day basis. Financial Advisor Selection and Evaluation Financial Advisors must meet certain requirements that include additional certifications and training to offer the Program. These requirements include obtaining and maintaining at least one of the following designations: Chartered Financial Analyst (CFA), Certified Financial Planner (CFP), Certified Investment Management Analyst (CIMA) or Accredited Portfolio Management Advisor (APMA) as well having a reasonable amount of experience in the industry. Eligible PNC Investment Financial Advisors are recommended by their Regional Sales Manager to participate in the Program. After this recommendation is made, an internal home office group consisting of representatives from Compliance, Supervision and Product (“the Review Group”) review the Financial Advisor’s recommendation, performance, credentials and background. A Financial Advisor who is approved to offer the Program then may choose whether to participate in the Program. Accordingly, the Program is only available through certain Financial Advisors. PNC Wealth Management conducts ongoing reviews of your Financial Advisor’s use of discretionary trading in your Account as described in the Review of Accounts section above. In addition to the ongoing Account reviews, on at least an annual basis, the Review Group will complete an analysis of your Financial Advisor’s continued approval to participate in the Program. This analysis will consist of, but is not limited to, monitoring for evidence of the Financial Advisor’s adherence to the Firm’s and Program’s policies and procedures, documentation of client interactions, and a general comparison of the Financial Advisor’s overall portfolio performance of Program Accounts to certain benchmarks set for the Program. Please note, there is no assurance that the discretionary services under the PNC Guided Solutions Program will be provided by any particular Financial Advisor. In the event that your Financial Advisor becomes unavailable to provide the services under the Program, PNC Wealth Management will promptly name a designated back‐up Financial Advisor to manage your Account on a discretionary basis. See the Financial Advisor Compensation Page 25 of 34 PNC Guided Solutions Program October 17, 2025  section above for more details regarding Reassigned Accounts. Fund and Model Provider Selection and Evaluation We select the investments and Model Providers that are available in the program. The factors influencing the inclusion of any investment model or Fund on our list of recommended investments may include, among other things, past performance, management style, quality of the relevant Model Provider or Fund manager, its investment process, the number and continuity of investment professionals, and its client servicing capabilities. While PNC Wealth Management is the sole sponsor of the Program, we receive research and assistance in selecting and reviewing Model Providers, investment models, mutual funds and ETFs from the Private Bank of our affiliate PNC Bank and Morningstar, Inc. (collectively, “research partners”). Expenses for these services are paid by PNC Wealth Management. We also rely on the Private Bank for research and assistance in selecting and reviewing investment models and Funds for the Program. The initial and on‐going research and due diligence PNC Wealth Management and/or one of its research partners conduct typically includes, but is not limited to, reviewing completed questionnaires, interviews with members of the Model Provider’s or Fund manager’s management, quarterly performance reviews and if applicable, addressing significant events regarding a Model Provider or Fund Manager. This process is an ongoing one, and investment models and Funds are added or removed from the Program based on many factors, either internal or external to a Model Provider or Fund manager’s management. Returns reported by Model Providers are derived from sources believed to be reliable, but we make no representations or warranties as to the accuracy of such performance information. The Program includes products managed by investment management affiliates of PNC Wealth Management, which receive compensation for their investment advisory and other services. We will not treat those entities and Funds any differently from investment managers and Funds that are not affiliated with PNC Wealth Management, including performing research on the selection and reviews of those entities and Funds. The services provided by our affiliates and the fees they collect for these services vary and generally are disclosed in each Fund’s prospectus. These fees are paid directly by the Fund and affect the total return of a shareholder’s investment. PNC Wealth Management and Other Service Providers to the Program PNC Wealth Management does not receive performance‐based fees calculated as a share of capital gains on, or capital appreciation of, the funds or any portion of the funds or other investments in a client’s Account. National Financial provides trading, custody and operational services for the Program. National Financial carries client Accounts, is the custodian for the investments in your Account, reports all the trades in your Account and effects many such trades. National Financial will provide you with trade confirmations, monthly statements, and income tax reporting. PNC Wealth Management has also engaged a service provider to perform certain support services in connection with the Program, including account rebalancing for the asset allocation models. This service provider is also responsible for calculating and preparing quarterly performance reports for client accounts. Risks of Investing in the PNC Guided Solutions Program Investing in securities, including the investments offered through the Program, involves risk of loss that you should be prepared to bear. There is no guarantee that the elements of the Program, including the asset allocation models, selection of investment manager models and/or investment decisions made on your behalf by PNCWM or your Financial Advisor will protect against such loss. Other risks include: Page 26 of 34 PNC Guided Solutions Program October 17, 2025   Market Risk. Market risk is the risk that the price of securities will fall over short or extended periods of time. Historically, the prices of equity securities have moved in cycles, and the value of an Account’s investments will fluctuate from day to day. When individual companies are negatively impacted by industry or economic trends or report poor operating results, the price of securities issued by those companies will typically decline in response. These factors contribute to price volatility.  Allocation Risk. A client Account is subject to the risk that asset allocation decisions will not anticipate market trends correctly. For example, weighting an Account too heavily in equities during a stock market decline may cause a loss of value. Conversely, investing too heavily in fixed income securities during a period of stock market appreciation may result in lower total returns.  Concentration/Diversification Risk. Concentration risk occurs when a client Account holds significant positions in certain securities, sectors or geographic regions. Concentrated positions can be more volatile and present a greater risk of loss, especially over the short term.  Discretion Risk. Discretionary investment management is a form of investment management in which buy and sell decisions are made by an investment manager or a financial advisor for the client's account. Clients cede control over their investment decisions and will generally, not be permitted to direct investment decisions in this Program. The risk is that the investment decisions of the investment manager or financial advisor could underperform and result in loss to the account’s value.  Parking Sleeve Risk. As discussed in the Securities Transferred into an Account section above, assets placed in a parking sleeve may have embedded tax consequences. A risk of the parking sleeve is that it may not achieve and be able to deliver realized losses due to market conditions. Neither PNCWM nor its Financial Advisors render advice on tax and tax accounting matters to clients. Clients should consult their personal tax and/or legal advisor to learn about potential tax or other implications that may result from using the parking sleeve in this Program  Credit Risk. The value of debt securities is affected by the ability of issuers to make principal and interest payments. If an issuer cannot meet its payment obligations or if its credit rating is lowered, the value of its debt securities will typically fall.  Interest Rate Risk. The value of fixed‐income investments will typically decline because of an increase in market interest rates. In addition, in certain low‐yield interest rate environments, some short‐term investments may produce negative yield, after accounting for fees, inflation and other expenses.  Liquidity Risk. The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in unusually wide bid‐ask spreads or large price movements (especially to the downside).  Stock-Specific (Unsystematic) Risk. Unsystematic risk is unique to a specific company or industry. Also known as “nonsystematic risk,” “specific risk,” “diversifiable risk” or “residual risk,” in the context of an investment portfolio, unsystematic risk can be reduced through diversification. The Program is intended to be a long‐term investment program and does not support market‐timing or frequent trading. You will be limited to one model change per calendar quarter, except as warranted by changes to your Page 27 of 34 PNC Guided Solutions Program October 17, 2025  financial situation as agreed by you and your Financial Advisor. Trading Practices PNC Wealth Management is an introducing broker‐dealer, clearing transactions related to the Program Accounts through National Financial. PNC Wealth Management has a best execution committee (“BEC”) that meets regularly to rigorously review data for equity orders executed by National Financial including those orders that are sent by the Investment Delegate. Such data includes, among other things, speed of execution and price improvement provided by the execution venues selected by National Financial. PNC Wealth Management does not receive any payment for order flow from the execution venues. The BEC also reviews data for fixed income trades executed through trading systems used by PNC Wealth Management to ensure that the net prices obtained are reasonable under the circumstances. The Program Fee includes the costs of trades executed only for transactions executed through National Financial on an agency basis. The Program Fee does not include any additional trading expenses incurred when the Investment Delegate determines to trade away from National Financial, for trades executed in Manager Traded Models (as decided by the Model Providers) or for transactions where National Financial acts as principal. The Investment Delegate will trade away from National Financial when the Investment Delegate determines it is in your best interest to do so. This can occur when the Investment Delegate is implementing a model change simultaneously across accounts with many different introducing firms, such as PNC Wealth Management. In these instances, the Investment Delegate may group together trades from several different introducing firms and execute those trades through a single broker‐dealer. This process is known as Block Trading (“Block Trading”). Block Trading is intended to reduce the market impact of executing large transactions in a particular security and can allow clients to get better overall execution prices than if the trades were placed individually. The Investment Delegate may also trade away from National Financial when it determines that a broker‐dealer other than National Financial is capable of obtaining a better execution price for the trade. This can typically occur in thinly traded securities or in fixed‐income securities. Additionally, Manager Traded Models are implemented directly by the Model Provider rather than by PNC Wealth Management or the Investment Delegate. A Model Provider of a Manager Traded Model may trade away from National Financial for the same reasons as described above. Model Providers historically implement substantially all trades in Manager Traded Models away from National Financial. Model Providers for Manager Traded Models typically trade fixed income securities away from National Financial. These trades will incur additional costs per bond or on a per transaction basis. These costs are embedded in the net price you receive and are not separately disclosed by the executing broker in your confirmation or statement. PNCWM does not receive any benefit when the Investment Delegate or Model Providers elect to trade away. Model Providers and Investment Delegate are responsible for fixed income securities’ best execution. Program Accounts utilizing Manager Traded Models should closely examine each Model Provider’s Form ADV Part 2A brochure for information relating to each Model Provider’s best execution and brokerage policies, including information to the Model Provider’s receipt of soft dollars in connection with its trading activities. In either case, it is important that you understand that you will pay any commissions, mark‐ups or mark‐downs incurred, in addition to the Program Fee when the Investment Delegate or a Model Provider elects to trade away from National Financial or for transactions where National Financial acts as principal. For additional information on the trading practices of the Investment Delegate and the Model Providers, please see the following link: https://www.pnc.com/content/dam/pnc-com/pdf/personal/wealth-investments/PNCWM/Trade- Practice-Disclosure.pdf. Information regarding Investment Delegate and Model Provider trading practices is based upon data provided to us by both the Investment Delegate and the Model Providers. We make no Page 28 of 34 PNC Guided Solutions Program October 17, 2025  representations regarding the accuracy of the information presented and cannot guarantee that the trading practices reflected in the information presented will be followed by the Investment Delegate or Model Providers in the future. You should be aware that certain Model Providers provide their model portfolio updates to the Investment Delegate after they make changes to accounts that they manage directly. In these instances, this will impact execution prices for your Account relative to other accounts in the same investment strategy that are managed directly by the Model Provider. Depending on various factors, including price movements and variations in trade execution, the performance of your Account will differ from, and be better or worse than, the performance of such other accounts managed directly by the Model Provider. You should also review the Form ADV Part 2 for the Investment Delegate and, if applicable, the Model Provider you have selected, for additional information regarding that firm’s execution practices. Proxy Voting PNC Wealth Management will vote all proxies for securities held in the Program Account on your behalf, unless you direct otherwise. PNC Wealth Management has retained and delegated our proxy voting power to Envestnet, a third‐party service provider, to receive proxy statements and to vote shares. the Investment Delegate to receive proxy statements and to vote shares according to our instructions. Envestnet votes proxies based on the recommendations of Glass‐Lewis & Co. (“Glass‐Lewis”), an independent third‐party research provider. Glass‐Lewis issues voting recommendations based on its own internal guidelines, which assist in limiting possible conflicts of interest in voting your proxies. We will not vote proxies in accordance with voting instructions received from you. PNC Wealth Management has adopted policies and procedures to address any conflicts that arise in connection with voting proxies. PNC Wealth Management may depart from its stated guidelines in order to avoid voting decisions believed to be contrary to the best interests of its clients. More information regarding our policies and procedures regarding proxies can be obtained by contacting your Financial Advisor or by calling PNC Wealth Management at (800) 622‐7086. If you choose, you may request to vote your own proxies by providing us with written instructions to deliver all proxy related materials directly to you for consideration and execution. If you choose this option, proxy materials typically will be forwarded to you by the custodian for your Account. If this option is selected, PNC Wealth Management, or the Investment Delegate, will no longer be in a position to vote proxies for any securities for your Account, including securities over which PNC Wealth Management has investment discretion. PNC Wealth Management will not advise or act for you with respect to any legal matters for securities held in your Account, including class actions or bankruptcies. Documents received with respect to such matters will be forwarded directly to you for your consideration. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS As part of the acceptance and approval process, and by signing the Investment Management Agreement, you grant us discretionary trading authority over your Account. PNC Wealth Management utilizes information regarding your financial circumstances, investment goals and objectives and any special written instructions you may wish to give regarding your Account. CLIENT CONTACT WITH PORTFOLIO MANAGERS Your Financial Advisor will serve as the portfolio manager for your Account. Your Financial Advisor will attempt to contact you at least semi‐annually, which may be by mail or e‐mail, as noted earlier, to review your Account PNC Guided Solutions Program October 17, 2025 Page 29 of 34  and evaluate if there are any changes to your financial situation. Your Financial Advisor will also be reasonably available to discuss or review your Account at other times. If any Funds or Model Providers are held in your Account, you will not have direct contact with the individuals responsible for the management of the Funds or Model Providers. You should direct any inquiries regarding the Funds or Manager Models in your Account to your Financial Advisor. ADDITIONAL INFORMATION Disciplinary Information  On April 11, 2016, PNC Wealth Management entered into a settlement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that it failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales and failed to apply such waivers to mutual fund purchases by certain retirement plan customers that were eligible to purchase Class A shares in certain mutual funds without a front‐end sales charge. The findings also stated that PNC Wealth Management failed to maintain adequate written policies and procedures or to provide adequate training to assist financial advisors in determining when sales charge waivers were available for retirement plan customers. PNC Wealth Management was not required to pay a fine, but consented to be censured and to pay restitution to eligible customers who did not receive sales charge waivers for fund purchases since July 1, 2009.  On April 6, 2018, PNC Wealth Management entered into a settlement (“Order”) with the Securities and Exchange Commission (“SEC”). Without admitting or denying the findings, PNC Wealth Management consented to the findings that, as a result of the conduct described below, PNCWM willfully violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)‐ 7 thereunder. The Order finds that the violations resulted from the following conduct of PNCWM: (1) PNCWM, without adequate disclosure of the associated conflicts of interest, invested advisory clients in mutual fund share classes with 12b‐1 fees instead of available lower‐cost share classes of the same funds without 12b‐1 fees; (2) PNCWM did not disclose a conflict of interest regarding marketing support payments paid on such mutual fund share classes that charged 12b1 fees; (3) PNCWM improperly charged advisory fees to client accounts where the investment adviser representative departed the firm (“Orphaned Accounts”) and where PNCWM failed to assign a new investment adviser representative within thirty days; and (4) PNCWM failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices and treatment of Orphaned Accounts. The Order requires PNCWM to cease and desist from committing or causing any violations and any future violations of Advisers Act Sections 206(2), 206(4), and 207 and Rule 206(4)‐7; censures PNCWM; and requires PNCWM to pay disgorgement of $5,234,856, and prejudgment interest of $612,344, to compensate advisory clients who were affected by certain conduct detailed in the Order. PNCWM will pay, in addition to the disgorgement and prejudgment interest described above, disgorgement of $497,144 in marketing support fees and prejudgment interest thereon of $63,426 to the SEC for the transfer to the general fund of the United States Treasury. Lastly, PNCWM will pay a civil monetary penalty of $900,000.  On April 22, 2024, PNC Wealth Management signed a Final Order with the State of North Carolina Department of the Secretary of State Securities Division. Without admitting or denying the findings, PNCWM was ordered to pay civil penalties in the amount of $7,500 and costs of investigation in the Page 30 of 34 PNC Guided Solutions Program October 17, 2025  amount of $1,000 resulting from the following conduct: (1) PNCWM and one investment adviser representative (“IAR”) failed to comply with North Carolina’s IAR registration requirements in violation of N.C.G.S. §78C‐16(a1) in which the IAR transacted advisory business in North Carolina from on or about December 2021 through on or about October 2023 without being IAR registered; (2) PNCWM was in violation of N.C.G.S. §78C‐18(b) and 18 NCAC 06A .1801(a)(18) by employing the IAR in North Carolina without the appropriate registration and by not furnishing this information to the IAR’s PNCWM advisory clients; and (3) PNCWM failed to supervise the IAR’s acts, practices and conduct to ensure adherence with North Carolina’s IAR registration provisions in violation of N.C.G.S. §78C‐19(a)(2)(j) and 18 NCAC 06A .1808.  On April 24, 2024, PNC Wealth Management signed a Consent Agreement and Order with the Pennsylvania Department of Banking and Securities. The Department alleged that from on or about December 2018 until December 2023, PNCWM failed to register at least one employee as an investment adviser representative in Pennsylvania in violation of Section 301(c.1)(1)(ii) of the Pennsylvania Securities Act of 1972 (“the 1972 Act”), 70 P.S. § 1‐301(c.1)(1)(ii). Without admitting or denying the findings in the Order, PNCWM agreed to pay a monetary fine of $100,000 and to comply with the relevant provision of the 1972 Act.  On September 3, 2024, PNC Wealth Management signed a Settlement Order with the Commonwealth of Virginia Division of Securities and Retail Franchising. The Division alleged that from on or about February 2019 to June 2024, PNCWM failed to register an investment advisor representative in Virginia in violation of § 13.1‐504 C (ii) of the Virginia Securities Act. Without admitting or denying the findings in the Order, PNCWM paid $10,000 in monetary penalties and $1,000 in investigation costs.  On September 18, 2024 PNC Wealth Management entered into an Administrative Consent Agreement and Order with the District of Columbia’s Department of Insurance, Securities and Banking alleging that from on or about August 2012 through February 2024, PNCWM failed to register three investment advisor representatives in D.C. in violation of D.C. Official Code §§ 31‐5602(b)(2) and 31‐5605.01(4). PNCWM paid $162,500 as a civil penalty and $1,080 in unpaid registration fees.  On June 16, 2025, PNC Wealth Management entered into an agreement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that from at least June 2021, it violated FINRA rules by failing to establish and maintain a reasonably designed supervisory system, including written supervisory procedures, for the surveillance and supervision of rates of deferred variable annuity exchanges. PNC Wealth Management was required to pay a $200,000 fine and to implement a supervisory system and written supervisory procedures reasonably designed to achieve compliance in surveilling registered representatives’ rates of deferred variable annuity exchanges consistent with applicable securities laws and regulations, and with applicable FINRA rules. Other Financial Industry Activities and Affiliations PNC Wealth Management’ principal business is that of a full‐service, general securities broker‐dealer and investment adviser, registered with the SEC and as a member of FINRA. Our primary retail brokerage activities include the sale of corporate equities, corporate debt, municipal securities and funds, mutual funds, ETFs and annuities. Page 31 of 34 PNC Guided Solutions Program October 17, 2025  PNC Wealth Management is part of a broad financial services organization and is therefore affiliated with other entities engaged in a variety of financial services businesses. In some cases, the firm has business arrangements with its affiliates that are material to its advisory business or to its clients. These are described in more detail below and, in some cases, cause PNC Wealth Management’ or a related person’s interests to diverge from the best interests of our clients. PNC Wealth Management is affiliated with the following financial services entities through its parent, The PNC Financial Services Group, Inc.:  PNC Bank, National Association is a wholly owned subsidiary of The PNC Financial Services Group, Inc., and is a full‐service bank engaged in traditional lending, cash and/or treasury management and other services.  PNC Capital Advisors, LLC is a wholly owned subsidiary of PNC Bank and provides discretionary fixed income investment advisory services to institutional accounts.  PNC Capital Markets LLC is an indirect, wholly owned subsidiary of The PNC Financial Services Group, Inc. and offers loan syndication, public finance underwriting and advisory services, securities underwriting and trading, private placements, asset securitizations and merger and acquisition advisory services.  PNC Insurance Services, LLC is a wholly owned subsidiary of PNC Wealth Management and a licensed insurance agency. It provides a variety of insurance products and advice. Selected conflicts of interest that exist between PNC Wealth Management and its affiliates are discussed below. Although PNC Wealth Management is committed to acting in the best interests of our clients, in some situations there are conflicts of interest between the firm’s interests and a client’s interests, or there are conflicts in the interests of multiple clients. Many of these conflicts of interest are inherent in operating an investment advisory business. For example, PNC Wealth Management may have an incentive to resolve a matter in favor of clients that are affiliates of the firm over clients that are not affiliates of the firm. PNC Wealth Management has adopted policies and procedures that it believes are reasonably designed to help mitigate these conflicts of interest. Affiliates of PNC Wealth Management provide advice to their clients with respect to investment strategies that are similar to or the same as strategies offered by PNC Wealth Management. Those advisory affiliates may purchase on behalf of their clients the same securities that PNC Wealth Management may purchase for our clients. As a result, the interests of PNC Wealth Management’ clients may conflict with the interests of the clients of these affiliated advisors. For example, if an investment advisor affiliate implements a portfolio management decision for its client ahead of, or contemporaneously with, a decision PNC Wealth Management makes for its client(s), the market impact of the decision made by the firm’s advisory affiliate could result in one or more of PNC Wealth Management’ clients receiving less favorable trading results than they otherwise would. PNC Wealth Management’ trade allocation and trade aggregation procedures do not typically apply to portfolio management decisions and trading executed by investment advisory affiliates for their clients that are not clients of PNC Wealth Management. Affiliate Transactions Page 32 of 34 PNC Guided Solutions Program October 17, 2025  PNC Wealth Management or its affiliates may from time‐to‐time recommend investments in transactions in which PNC Wealth Management or its affiliates act as financial advisor or a broker‐dealer, or in securities which are underwritten, issued, packaged or serviced by an affiliate. Moreover, PNC Wealth Management may act as a broker in executing your purchase or sale for your account of a debt security from or to PNC Capital Markets, a brokerage affiliate. Additionally, your Financial Advisor may recommend you purchase a mutual fund advised by PNC Capital Advisors, an affiliated registered investment adviser. These affiliates receive compensation as a result of these transactions, if these transactions were to occur. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PNC Wealth Management has adopted a Code of Ethics, which consists of certain general principles, including the following:  Advisory personnel must place client interests before their own  The personal securities transactions of our personnel must avoid even the appearance of a conflict with client interests  Our personnel must avoid actions or activities that allow, or appear to allow, them to profit or benefit from their position with respect to clients, or that would otherwise bring into question their independence or judgment  From time‐to‐time, PNC Wealth Management personnel may accept training, business entertainment or gifts of de minimis value from product vendors. PNC Wealth Management has adopted policies and procedures reasonably designed to ensure any such activity does not impact our personnel’s ability to act in the best interests of our clients  In addition, the Code of Ethics requires our employees to report their personal securities transactions and holdings. A copy of our Code of Ethics will be provided to any client or prospective client upon request. Our employees are also subject to the PNC Employee Conduct Policies, which cover matters including compliance with law, conflicts of interest, insider trading, outside activities and safeguarding confidential information. Client Reports As part of the PNC Guided Solutions Program, we will provide periodic reports to assist you in monitoring and assessing the performance of your Account. These reports will contain information regarding trades, investment return, and selected benchmark comparisons. These reports may also contain letters, notices and other important information regarding the Model Managers and any changes to the Account during the period. Client Referrals and Other Compensation Your Financial Advisor may refer you to PNC Bank or other PNC Wealth Management’ affiliates for additional products or services and will generally receive compensation for such referrals. A portion of the fees charged for the PNC Guided Solutions Program services described in this Brochure are paid Page 33 of 34 PNC Guided Solutions Program October 17, 2025  to your Financial Advisor in connection with the introduction of Accounts as well as for providing client‐related services within the Programs. This compensation may be more or less than a Financial Advisor would receive if you paid separately for investment advice, brokerage and/or other services. Certain employees of PNC Bank’s Wealth Management and or Private Client Group receive compensation in connection with referrals to PNC Wealth Management. PNC Wealth Management has related persons who are investment advisors who act as general partners in partnerships in which our clients may be solicited. PNC Wealth Management would not have knowledge of such solicitations should they occur, and consequently, would not be a participant in them, nor would we receive any compensation for them. Financial Information In certain circumstances, PNC Wealth Management would be required to provide you with financial information or disclosures about our financial condition. Currently, no such circumstances exist for PNC Wealth Management. PNC Wealth Management has no financial commitments that impair our ability to meet our contractual and fiduciary commitments to our clients and has never been the subject of a bankruptcy proceeding. Page 34 of 34 PNC Guided Solutions Program October 17, 2025 

Form ADV Part 2A Appendix 1 801‐66195 Disclosure Document for the PNC Directions Program An Investment Advisory Service of PNC Wealth Management LLC 300 Fifth Avenue Pittsburgh, Pennsylvania 15222 (800) 622‐7086 www.pnc.com October 17, 2025 This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of PNC Wealth Management, LLC with respect to the PNC Directions Wrap‐Fee Advisory Program (“PNC Directions Program,” “PNC Directions” or “Program”). If you have any questions about the contents of this Brochure, please contact us at (800) 622‐7086. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. PNC Wealth Management LLC, a registered investment adviser and broker‐dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), is a wholly owned subsidiary of The PNC Financial Services Group, Inc. Registration does not imply a certain level of skill or training. Additional information about PNC Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. • NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, PNC BANK, N.A. OR ANY OF ITS AFFILIATES • SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED  MATERIAL CHANGES ADV Part 2A dated October 17, 2025 The following change(s) have been made to the PNC Wealth Management PNC Directions Wrap Fee Program Brochure since the last Brochure dated July 16, 2025: On or about October 17, 2025, our firm’s legal and business name will change from PNC Investments LLC to PNC Wealth Management LLC. This change is administrative in nature and does not affect the ownership, management, operation, services, or fees of the firm. All references to PNC Investments LLC within the Brochure will be updated to PNC Wealth Management LLC. No other material changes have been made since our last Form ADV 2A Brochure was filed on July 16, 2025.  Table of Contents ............................................................................................ .................................................................................................................. ...................................................................................................................... ..................................................................................................................... ........................................................................................................................ ......................................................................................... ....................................................................................................... .............................................................................................................................................. About PNC Wealth Management LLC Automatic Rebalancing Account Statements Account Termination Review of Accounts Securities Transferred into an Account Withdrawals from an Account Taxes Fees and Expenses Additional Fees for Brokerage Services Deduction of Account Fees Fund‐Level Fees and Expenses Received by Us Other Expenses and Costs Cash Balances Financial Advisor Compensation 4 7 8 8 8 9 9 9 10 11 11 11 13 14 15 ....................................................................................................................... ....................................................................................... .......................................................................................................... ........................................................................... ........................................................................................................... .............................................................................................................................. ................................................................................................. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients Collateral Accounts 16 16 16 ....................................................................... .................................................................................... ...................................................................................................................... PORTFOLIO MANAGER SELECTION AND EVALUATION Selection of Funds PNC Wealth Management and Other Service Providers to the Program Risks of Investing in the PNC Directions Program Trading Practices Proxy Voting 17 17 18 18 19 20 ................................................................... ........................................................................................................................ ................................... ....................................................................... .......................................................................................................................... ................................................................................................................................. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS 20 ...................................................... CLIENT CONTACT WITH PORTFOLIO MANAGERS 20 ............................................................................ ADDITIONAL INFORMATION Disciplinary Information Other Financial Industry Activities and Affiliations Funds Advised by Affiliates Affiliate Transactions Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Client Reports Client Referrals and Other Compensation Financial Information 21 21 22 23 24 24 24 24 25 ............................................................................................................ .............................................................................................................. ..................................................................... .......................................................................................................... ................................................................................................................... ............... .............................................................................................................................. ................................................................................... ................................................................................................................... Page 3 of 25 PNC Directions Program October 17, 2025  About PNC Wealth Management LLC PNC Wealth Management LLC (“PNC Wealth Management” or the “Firm”) is an investment adviser and also a registered broker‐dealer and member of FINRA and SIPC. The Firm offers retail brokerage and investment advisory services. PNC Wealth Management serves as the sponsor of, and in some cases as a portfolio manager for, wrap fee investment programs. PNC Wealth Management is a wholly owned subsidiary of PNC Bank, National Association (“PNC Bank”) and is a part of The PNC Financial Services Group, Inc. (“PNC”) which is a diversified financial services institution with roots in commercial banking and investment management dating back to the early 1800s. Throughout this document, the terms “client,” “you,” and “yours” are used to refer to the individual(s), institution(s) or organization(s) who contract with us for the services described here. “PNC Wealth Management,” “we,” “our,” “us” and “the firm” refer to PNC Wealth Management LLC, together (as applicable) with our affiliates, including but not limited to, PNC and its agents with respect to any services provided by those agents. Our affiliates include any entity that is controlled by, controls or is under common control with PNC Wealth Management, including but not limited to our parent company, The PNC Financial Services Group, Inc. Each affiliate is a separate legal entity and not responsible for the obligations of any other affiliate. “Account” means each brokerage and/or advisory account you open with us that is subject to the PNC Directions Program investment management agreement (the “Investment Management Agreement”), including any and all mutual funds, exchange traded funds, money, securities, financial instruments and/or other property you have funded in such accounts. “Business Day” means Monday through Friday, excluding New York Stock Exchange holidays. “Wrap” refers to an Account that charges a quarterly or annual fee based on the average assets under management, where such fee covers administrative, commission, execution and management expenses. SERVICES, FEES AND COMPENSATION This Brochure is being provided pursuant to Section 204 of the Investment Advisers Act of 1940, as amended, and deals solely with our PNC Directions Program. In addition to the Program, PNC Wealth Management offers a variety of investment advisory services. These include, but are not limited to, the Capital Directions Program, the Portfolio Solutions Program, the Portfolio Solutions Strategist Program, the Capital Directions Annuities Program, and the Guided Solutions Program. More information about these programs and services is contained in the applicable PNC Wealth Management brochure and is available upon request from PNC Wealth Management or through the SEC’s website at https://adviserinfo.sec.gov/. For more information about these or other services that are available from PNC Wealth Management, please contact your Financial Advisor. Other advisory services are offered by our affiliates. The PNC Directions Program PNC Directions is a discretionary mutual fund and exchange traded fund (“ETF”) advisory program that provides an asset allocation strategy for investing in a portfolio of mutual funds and ETFs (together, “Funds”) based on your declared risk tolerance, asset levels, time horizons, and financial goals. Before you open an Account in the PNC Directions Program, you should carefully review our Client Relationship Summary (“Form CRS”) and consider whether an advisory relationship is right for your situation and circumstances. You may discuss any questions you have regarding our Form CRS or whether an advisory account is right for you with your Financial Advisor. Some things you may wish to consider are your preference for a fee‐based versus a commission based Page 4 of 25 PNC Directions Program October 17, 2025  relationship, your preference for on‐going support and advice from your Financial Advisor, how much trading activity you expect to take place in your account, and the anticipated total costs. You should know that your Financial Advisor benefits when you open a PNC Directions account, as described in more detail in the Financial Advisor Compensation section of this Brochure, and has a conflict of interest when recommending an advisory account to you. will help you complete an investor When you open a PNC Directions account, your Financial Advisor1 questionnaire that provides an understanding of your financial situation, investment objectives, investment time horizon and risk tolerance. Based on the information collected in the investor questionnaire, we will recommend an asset allocation strategy (“Allocation Model”) appropriate to your situation. Your Financial Advisor will help you understand the risk and return characteristics of the selected Allocation Model and help you evaluate the Allocation Model’s return potential in relation to your investment goals and objectives. We will present our recommendation to you in the form of a proposal (the “Proposal”), which will include the actual initial investment portfolio recommended to you, for your acceptance and approval. It is very important that you understand the risks associated with the Allocation Model you select and should discuss this with your Financial Advisor if you have any questions. Five Allocation Models, each associated with a distinctive risk profile and comprised of a different mix of asset classes, have been developed by PNC Bank’s Private Bank (the “Private Bank”) and approved by PNCWM’s Investment Due Diligence Committee (IDD). Furthermore, PNC Wealth Management may also conduct its own research, including gaining insights from non‐affiliated third parties, to be used in making asset allocation decisions for the Allocation Models, which from time‐to‐time may diverge from models developed by the Private Bank. In all cases, PNCWM has sole discretion in approving Allocation Models for the program. As described above, working with your Financial Advisor, you can select a strategy based on your investment goals and financial circumstances. The five strategies are summarized below.  Conservative. The primary objective of the Conservative model is to generate a modest amount of current income, and secondarily to provide a modest amount of long‐term capital growth, which should help offset some of the effects of inflation. Long‐term growth of principal will be aided by income reinvestment. While the goal is to maintain a low‐risk posture, investors should be willing to accept periodic declines in portfolio value. Although past performance is no guarantee of future results, generally any such decline should be less severe than declines in the broader equity markets. The portfolio’s split allocation between equity and fixed income securities, with an allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Moderate. The objective of the Moderate model is to generate a moderate amount of current income with the potential for longer‐term capital growth. The portfolio is split between equity and fixed income securities, with a small allocation to cash, and is constructed to provide both long‐term capital appreciation in excess of inflation and a moderate amount of current income. While the current income generated could be available to meet your day‐to‐day expenses, reinvestment of income will increase the portfolio’s ability to exceed inflation over the long‐term. 1 We use the term “Financial Advisor” to refer to PNC Wealth Management’ branch‐based and wealth Financial Advisors, as well as Advisor Direct Financial Advisors and Investment Services Consultants. Page 5 of 25 PNC Directions Program October 17, 2025  The portfolio’s allocation between equity and fixed income securities, with an allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Balanced. The primary objective of the Balanced model is to provide long‐term capital growth in excess of inflation, with a modest amount of current income as a secondary objective. The portfolio is split between equities and fixed income securities, with a higher allocation to a variety of equity securities. The portfolio also contains a small allocation to cash. While the current income generated could be available to meet your day‐to‐day expenses, income reinvestment will increase the portfolio’s ability to exceed inflation over the long‐term. This portfolio maintains a somewhat aggressive risk posture, and you should be willing to accept periodic declines in portfolio value. Because the portfolio is largely invested in equities, it can experience fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Growth. The primary objective of the Growth model is long‐term capital growth. It may secondarily generate a minimal amount of current income by including some fixed income securities. The portfolio is concentrated in equity investments in order to earn returns exceeding the rate of inflation over the long‐term. A small allocation to fixed income securities, as well as cash, is included primarily to help dampen volatility over the long‐ term. This portfolio maintains an aggressive risk posture, and you should be willing to accept potentially significant declines in portfolio value that may be similar to or exceed declines in the broader equity markets. Because the portfolio is predominantly invested in equities, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective.  Aggressive. The primary objective of the Aggressive model is long‐term capital growth. An Aggressive portfolio is concentrated in equity investments for long‐term growth. Returns in excess of the underlying rate of inflation are necessary to increase both principal and purchasing power. This portfolio maintains a highly aggressive risk posture, and you should be willing to accept potentially significant declines in portfolio value, similar to or greater than declines in the broader equity markets. The portfolio may contain a small allocation to fixed income securities as well as cash. Because the portfolio is predominantly invested in equity securities, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long‐term investment objective. PNC Wealth Management will periodically adjust Allocation Models or remove Funds from our approved list. In all of these circumstances, PNC Wealth Management will update your Allocation Model and/or the Funds accordingly and, if necessary to align your Account to the new Allocation Model, will execute transactions in your Account. Note that you will not be sent a new Proposal in these circumstances, unless requested through your Financial Advisor. Your Financial Advisor may recommend you change your Allocation Model if they Page 6 of 25 PNC Directions Program October 17, 2025  determine your financial circumstances have changed. Additionally, you may direct us to change the Allocation Model for your Account once every 90 days, or more frequently as PNC Wealth Management may agree in its sole discretion. Before you may establish a PNC Directions Account, you must establish a brokerage account with PNC Wealth Management and agree to the terms and conditions of the PNC Wealth Management Brokerage Account Customer Agreement. By accepting and signing the Investment Management Agreement, you grant discretion over your Account to PNC Wealth Management and you authorize us to invest and reinvest the assets in your Account in a combination of Funds, and other financial instruments in accordance with the Allocation Model that you have selected. PNC Wealth Management has delegated certain portfolio management services to Envestnet Asset Management, Inc., an unaffiliated investment adviser (the “Investment Delegate”) for Program Accounts. The Investment Delegate will facilitate the execution of trades in your Account as instructed by PNC Wealth Management. The scope of any investment advisory relationship we have with you is defined in the Investment Management Agreement. When you are enrolled in the Program, we will act as your introducing broker and we will also act as your investment advisor, but only for your Program Account and not for any other assets or accounts, unless otherwise separately agreed to by us in writing. As discussed in more detail below, we earn certain fees and other revenue in connection to our capacity as introducing broker to your account. This is a conflict of interest because we would not earn such fees or revenue if we did not serve as your introducing broker. Our PNC Directions Program advisory relationship with you begins when we enter into an Investment Management Agreement with you, which occurs at the later of the date of acceptance of the signed Investment Management Agreement by PNC Wealth Management or the date on which you have contributed the required minimum level of assets to your Account. Preliminary discussions or recommendations before we enter into an Investment Management Agreement with you are not intended as investment advice under the Investment Advisers Act and should not be relied on as such. The PNC Directions Program is designed for investors who wish to give PNC Wealth Management full discretion to invest the assets in their Accounts according to the asset allocation model selected. Once you are approved for the Program, you will not have the ability to directly buy or sell individual securities in your Account, or to direct your Financial Advisor to buy or sell securities in your PNC Directions Account. You will not be able to obtain a margin loan using the securities in your Account as collateral. You will have, subject to our approval, the ability to place certain reasonable investment restrictions on the types of Funds that may be purchased for your Account. For example, you may request that your Account not be invested in Funds with a primary focus on international securities. You should note, however, that Funds utilized in a domestic‐only strategy may potentially maintain some exposure to international markets. Automatic Rebalancing The PNC Directions Program provides automatic rebalancing to ensure that the investments in your Account continue to conform to the selected allocation model. Asset allocations are monitored on a quarterly basis, and generally, we will rebalance an Account if any asset class varies by more than 3% from its target allocation within the model. In lieu of the Program’s default practice of rebalancing on a quarterly basis, you may request that periodic rebalancing for your Account occur on a less frequent basis of either semi‐annually or annually. You should consider, however, that less frequent periodic rebalancing, could cause your Account to diverge from the selected allocation percentages and such divergence could potentially negatively or positively impact performance. In addition to periodic automatic rebalancing, we will also rebalance your Account if you change your investment model, or when additional contributions to or withdrawals from your Account cause the cash Page 7 of 25 PNC Directions Program October 17, 2025  balance to exceed 5%, or be less than 0.5%, respectively, of the portfolio value. Further, you may also request, subject to approval by PNC Wealth Management, that an ad hoc rebalance be executed. In order to avoid the expense of inefficient rebalancing, we reserve the right, in our sole discretion, to from time to time change timeframes for effecting rebalances to your Account as well as the thresholds that must be exceeded before any rebalancing will occur. To rebalance an Account, we buy or sell, as relevant, shares of the individual Funds in an Account until its holdings match the Fund weight percentage specified for the applicable model. Rebalancing transactions are subject to short‐term trading policies, described more fully below, of Funds held in your Account, and, if your account is taxable, will create tax consequences for your Account. Account Statements You will receive a monthly statement following any month in which there is investment activity in your Account, confirming all transactions in your Account, including additions, disbursements, purchases, sales, and advisory fees paid to PNC Wealth Management or fees paid to Model Providers. For periods in which there is no investment activity in your Account, statements will be provided quarterly. You will also receive a quarterly performance report that tracks the performance of your portfolios against relevant benchmarks. You will be reminded quarterly to contact your Financial Advisor if you should have any questions, or if there have been material changes in your financial goals or needs that would affect your investment strategy. Account Termination Either party may terminate the Investment Management Agreement on 30 days’ written notice to the other party. You are also entitled to terminate such agreement within five (5) business days of your execution of it without incurring a Program Fee, defined below; you may, however, be subject to certain other fees incurred with respect to the Account for the relevant period. Upon the termination of the Investment Management Agreement, PNCWM will be under no obligation to provide advice on any holdings in your Account. Any transactions executed by you after the termination of the Investment Management Agreement will be subject to fees and commissions described in the PNC Wealth Management Overview of Products and Services (the “Overview of Products and Services”). You may obtain a copy of our current Overview of Products and Services, at any time, by contacting your Financial Advisor, by contacting us at (800) 622‐7086 or online at www.pnc.com/investments‐relationship‐summary. In addition, upon learning of the death of any account owner, PNCWM will immediately terminate the Investment Management Agreement. You should be aware that any transactions executed by your heirs or beneficiaries after your death will be subject to fees and commissions described in the Overview of Products and Services, unless waived by us in our sole discretion. Please see the agreement governing your PNC Directions Program Account for more information. The Investment Management Agreement will continue in effect until terminated by you or PNC Wealth Management upon 30 days’ written notice to the other party. Review of Accounts When you open a PNC Directions Program Account, we review and must approve your investment objectives and strategy for consistency with Program guidelines. Thereafter, we will continuously monitor the Account including its performance, the appropriateness of the individual funds in it, and any restrictions that might apply. We will attempt to contact you at least annually, including by mail or email (if you have authorized us to send you electronic communications), to request that you review your Account and inform us of any changes to your financial profile or investment objectives. You should inform your Financial Advisor of any changes to your financial profile or investment objectives as they occur. Your Financial Advisor will communicate any changes about you to PNC Wealth Management. Finally, your Financial Advisor will be reasonably available to you for Page 8 of 25 PNC Directions Program October 17, 2025  consultation about the Account. We encourage you to please contact your Financial Advisor if you have any questions. Securities Transferred into an Account You should be aware that if you transfer securities into a PNC Directions Account, any transferred securities that are not part of the recommended investments for your Account will be liquidated upon or shortly after transfer. Typically, this means that we will liquidate all of the securities you transfer to your Account prior to investing to your Account in the recommended investments. If your Account is not tax‐exempt, you will incur tax consequences as a result of these transactions. You should consult with your tax adviser to review these consequences. Additionally, if you liquidate securities prior to transferring your account to PNC Wealth Management, or liquidate your securities prior to establishing your PNC Directions account, you will likely incur transaction costs for those transactions. PNC Wealth Management will not reimburse you for transactions executed at another firm. Please note that if you transfer illiquid securities into a PNC Directions Account, it will delay management of that Account until such securities are transferred out or otherwise removed. You may, at your election, chose an optional Dollar Cost Averaging (“DCA”) feature when adding funds to your Program Account. With the DCA feature, you have the ability to deploy free cash to your Allocation Model over a defined period and in pre‐determined amounts. The DCA feature can enable clients to slowly invest excess cash over time, rather than make one lump‐sum investment. You have no obligation to complete scheduled DCA transactions and may terminate the DCA feature at any time, by providing notice to us, at least 5 business days prior to the next scheduled DCA transaction. You should know that if sufficient cash is not available in your Account at the time of a scheduled DCA transaction, that transaction, and all future scheduled DCA transactions will be canceled. You should also be aware that cash pending investment under an optional DCA plan will be treated as unallocated cash, and swept to a deposit account at our affiliate bank, as described below. The parameters of DCA requests are subject to our approval. Withdrawals from an Account You should also be aware that if you request a withdrawal from a PNC Directions Account, PNC Wealth Management as investment manager, may need to liquidate a portion of the Account to cover the requested withdrawal amount. This will happen, for example, when the cash in your Account is insufficient to accommodate the requested withdrawal. If your Account is taxable, you will incur tax consequences as a result. These transactions are subject to short‐term trading policies of Funds held in your Account. Liquidation requests are processed according to our standard procedures and your liquidation request may not be completed on the day it was submitted. This is more likely if your request is submitted late in the day or during periods of severe market volatility. Cash is available for distribution three to five business days after the initial request is made, however, you should also be aware that liquidation transactions are at the discretion of the investment manager and could exceed this timeframe. Taxes You need to be aware that the Program operates in a manner that will likely cause non‐retirement Program Accounts to more frequently experience taxable gains and losses than a brokerage account holding individual securities for the same amount of time. When we, at our discretion, sell securities to rebalance your asset allocation or to adjust your program model, the transaction will likely create a capital gain or loss for you. Additionally, any securities that you sell in order to raise cash to open and or be deposited into your account will likely create a capital gain or loss. These capital gains and losses are in addition to dividends and capital gains paid by the securities in the account. You should consider and discuss the potential tax implications of opening Page 9 of 25 PNC Directions Program October 17, 2025  and maintaining a PNC Directions account with your tax adviser. Fees and Expenses The program fee you pay to PNC Wealth Management for the PNC Directions Program is charged quarterly in advance and is based on the average daily market value in your Account over the prior calendar quarter, including cash holdings, or portion thereof (“Program Fee”). However, cash holdings in excess of 7.5% (operational cash purposes i.e., trading and account maintenance needs) will be excluded from the average daily market value calculation when the Program Fee is calculated. You should be aware that your account is subject to the Program Fee whether you make or lose money on the investments. The Program Fee covers the cost of brokerage commissions and other transaction fees only for transactions executed through National Financial Services LLC (“National Financial”) on an agency basis. The Investment Delegate will typically route trades to National Financial for execution. From time to time, the Investment Delegate will trade through broker dealers other than National Financial when the Investment Delegate determines, in its sole discretion, that this is in your best interest. Trades executed away from National Financial are described as “trading away” or “step‐out trades.” You will bear the cost of any brokerage commissions incurred on transactions executed through other brokers, dealer markups, markdowns and spreads when the Investment Delegate trades away from National Financial. See the Trading Practices section below for details. Generally, the Program Fee is non‐negotiable. The Program fee for PNC Directions is in addition to any of the specific fund fees and expenses that are discussed in more detail below. Generally, you will be charged commissions or service charges for transactions executed prior to establishing your PNC Directions account; you should discuss your options for funding your account with your Financial Advisor. You may contact your Financial Advisor if you have any questions regarding the fees charged to your Account. Upon your request we will provide you with a detailed explanation of the fee calculation which will allow you to recalculate the fee should you so desire. Generally, fees incurred by your Account will be paid from the cash balance in the Account. If your Account does not have a sufficient cash or money market mutual fund balance to pay the fees, we may sell Fund shares as necessary to pay the fees. As described previously, you may incur transaction costs and could create tax consequences by selling securities to pay fees and expenses. The annual Program Fee for the PNC Directions Program is 1.00%. There is an annual minimum fee for the program of $80.00. From time to time, we offer discounted pricing programs in our discretion. For smaller accounts, a minimum account fee may apply to the Program Fee or fees charged by the Advisor or custodian. Minimum accounts fees are expressed in annual amounts, but are determined and assessed based on the account asset value each quarter. For example, if an account has a $80 minimum annual account Program Fee, it will be assessed a minimum of $20 every quarter. Therefore, if a Client has large asset inflows or outflows during the year that cross the minimum asset value threshold, it is possible for an account to be assessed a minimum fee for a particular quarter even if at the end of the year a look back over the account’s average balance for the entire year would have placed it above the minimum asset value threshold. If your Account is new, you will pay an initial fee after the date that National Financial, the custodian, receives the initial assets of your Account. An adjustment to the next quarterly fee will be made for any significant contributions or distributions that occur during the inception quarter of your Account. With your initial contribution and for any additional contribution or distribution adjustments, your fee will be calculated for that portion of the ongoing quarterly Program Fee that relates to the number of days remaining in the calendar quarter as of the date your Account becomes subject to the Investment Management Agreement or that you Page 10 of 25 PNC Directions Program October 17, 2025  make the additional contribution or distribution, as applicable. This Program Fee will be based on the total market value of assets in your Account on that date. If your Account is terminated by you or PNC Wealth Management during a calendar quarter, the fee for that quarter will be prorated over the number of days that the Account was open during the quarter. Any overpayment will be refunded to you after the Account is closed. Fees are not prorated for contributions or withdrawals made during a calendar quarter, except in the case of a new or terminated Account, as outlined above. If you terminate your PNC Directions account within 90 calendar days of initial investment, PNC Wealth Management reserves the right to charge you commissions, according to the Overview of Products and Services, for transactions executed on your behalf during the time your account was managed, less any pro‐rated advisory fee paid by you. Additional Fees for Brokerage Services PNC Wealth Management will charge its standard fees for additional brokerage account services that are not included in the Program. Such fees include, but are not limited to, ACAT (i.e., account transfer) fees, wire transfer fees, IRA fees and stop payment fees. You should be aware that in some cases, PNCWM retains this entire fee or marks up the fee National Financial, our clearing firm, charges to PNCWM for these services. This is a conflict of interest for us because PNCWM has an incentive to utilize a clearing firm that allows us to mark up designated fees. PNCWM also has incentive to recommend to you services that have been marked‐up. Please refer to the Account Level Fees section of the Overview of Products and Services for details. Deduction of Account Fees All fees incurred by the Account will be paid from the cash balance or by selling shares of a money market mutual fund. If the Account does not have a sufficient cash balance or enough money market mutual fund shares to cover the fees, we will liquidate other securities as necessary to pay them. Selling securities to pay fees is subject to the short‐term trading policies of Funds and, if your account is taxable, will create tax consequences for you. You may contact your Financial Advisor if you have any questions regarding the fees charged to your Account. Fund-Level Fees and Expenses Received by Us Mutual Fund Models. Each mutual fund in which your Account is invested charges its own separate fund‐level fees and operating expenses, including, for example, administrative, custody, transfer agent, legal and audit fees and expenses, investment advisory or management fees, shareholder servicing fees, omnibus accounting fees, fees for sub‐administration, recordkeeping, print mail services and other expenses. These fees and operating expenses are ultimately borne by the shareholders invested in the Fund, including you, and will reduce your investment returns. Other classes of mutual funds have lower fund‐level fees and expenses than those used in this Program. Please review the relevant mutual funds’ prospectuses for a full explanation of fund expenses and charges. PNC Wealth Management includes in the Program only “Approved Share Classes” of mutual funds, which are share classes that generate revenue sharing payments, as described below, to PNCWM. PNCWM will select Approved Share Classes that are either (i) share classes that trade on our custodian’s Institutional No‐ Transaction Fee platform (“INTF Eligible” share classes); or (ii) if no such INTF Eligible share class is available, the least expensive non‐INTF Eligible share class eligible for inclusion in the Program. PNC Wealth Management uses INTF Eligible share classes in order to reduce PNC Wealth Management’ overall program trading costs, which costs would otherwise be payable by PNC Wealth Management. These selection criteria represent a conflict of interest for us because they enable PNC Wealth Management to avoid costs, but also may result in you Page 11 of 25 PNC Directions Program October 17, 2025  purchasing a share class that is more expensive than other share classes of the same fund for which you are eligible. You acknowledge that when you establish a Program Account, you authorize and direct PNC Wealth Management to purchase for your Account only Approved Share Classes using the criteria described above and you waive any obligation of PNC Wealth Management, if applicable, to purchase any other share classes for your Account, even if less expensive share classes are available. A higher cost share class will adversely affect the investment performance of your account. INTF Eligible share classes do not typically charge shareholders 12b‐1 fees or pay those fees to us or our custodian, which reduces costs to you, as compared to share classes that do pay 12b‐1 fees. As described more fully below, money market funds held in your Account typically charge 12b‐1 fees, but we will rebate any such fees we receive. Please note that the mutual funds included in the Program may provide compensation such as fees for omnibus accounting, sub‐administration, shareholder services, recordkeeping, print mail services or other related fees (“Mutual Fund Compensation”). While we do not expect to receive such fees, PNC Wealth Management will credit to your Account any Mutual Fund Compensation or 12b‐1 fees paid to us in connection with the holdings in your Account. Our custodian or other entities not affiliated with PNC Wealth Management may receive Mutual Fund Compensation. PNC Wealth Management is not a party to such arrangements and we will not credit your Account for Mutual Fund Compensation received by such entities. You should be aware that any Mutual Fund Compensation paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. ETF Models. Exchange‐traded funds, or ETFs, are similar to mutual funds in that they invest in a basket of securities, such as stocks, bonds, or other asset classes. Unlike mutual funds, however, ETFs trade on an exchange and their price can change throughout the day and may vary from the value of the underlying assets in the investment portfolio. There are three different types of ETFs: Index based or Passive – which track a specified index such as the S&P 500 or NASDAQ Composite Index, Smart beta – which invest in factors through a rules‐based index (low‐volatility, equal‐weight, etc.), and actively managed – which are not tied to an index and offer portfolio manager flexibility and security selection with the intent to outperform a benchmark. Most ETFs publish their holdings daily. ETFs have internal operating expenses that reduce investment returns. Active ETFs generally, have higher internal operating expenses than other ETF types. ETFs typically have lower expenses than mutual funds that are actively managed. However, even though a mutual fund in the same asset class as an ETF may be more expensive, other factors such as ETFs that trade less frequently could make a mutual fund more advantageous. Each ETF charges its own separate fund‐level fees and operating expenses. These fees and operating expenses are ultimately borne by the shareholders invested in the ETF, including you. PNC Wealth Management receives an annual credit from National Financial (the “ETF Revenue Share Credit”). The ETF Revenue Share Credit is projected based on future sales of actively managed ETFs through National Financial. PNCWM's receipt of the ETF Revenue Share Credit is dependent on National Financial sharing a portion of its actively managed ETF revenue. With the receipt of the ETF Revenue Share Credit, we are incentivized to recommend actively managed ETFs over other ETFs and products in which we either receive less or no revenue share as compared to the ETF Revenue Share Credit. We are also incentivized to select and continue our relationship with National Financial to receive the ETF Revenue Share Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. We will retain the ETF Revenue Share Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the ETF Revenue Share Credit. You should be aware that any ETF Revenue Share Credit paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. Page 12 of 25 PNC Directions Program October 17, 2025  PNC Wealth Management receives an annual credit from National Financial (the “Business Development Credit”). PNCWM is incentivized to select and continue its relationship with National Financial to receive the Business Development Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. The Business Development Credit is not related to the sale or offer of any specific products or services, nor is it dependent upon assets under management. If received, we will retain the Business Development Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the Business Development Credit. Additionally, if under certain circumstances our clearing arrangement with National Financial is terminated prior to the expiration of our agreement, PNCWM is subject to certain contractual fees and penalties (collectively, the “Termination Fee”). The Termination Fee creates a strong disincentive for PNCWM to consider clearing relationships other than National Financial. This creates a conflict of interest for us as we expect to benefit from the continued recommendation of National Financial as our clearing firm. Additionally, PNCWM is further incentivized to continue the relationship with National Financial as we may not receive the same incentives from other clearing firm arrangements, such as receiving particular credits from National Financial or having the ability to mark‐up certain fees to clients. PNC Wealth Management receives additional compensation, referred to as revenue sharing, from the advisors or distributors of the mutual funds offered in the Program, which compensates us for administrative services we provide to them and is based on the level of assets invested in the mutual funds they advise or distribute. Our independent due diligence process for selecting mutual funds and ETFs for our investment advisory programs is designed so that products are selected based on objective, investment related criteria and does not take into account compensation to PNC Wealth Management. However, only funds for which we receive revenue sharing are considered for inclusion in this due diligence process. This is a conflict of interest for us because mutual funds and or certain ETFs that may otherwise meet our investment criteria are not included in the Program because their advisors or distributors do not offer revenue sharing to PNC Wealth Management. In addition, we receive a higher revenue share amount on mutual funds than ETFs. This is a conflict of interest for us when there are similar products offered in both product categories as we will be paid more revenue share when recommending mutual funds than if an ETF is recommended. We will not credit your Accounts for any revenue sharing payments we receive. Although we include only mutual funds and certain ETFs whose sponsors pay PNCWM revenue sharing, we believe this conflict is mitigated by the large and diverse universe of Funds we make available in our programs which meet our clients’ needs. Your Financial Advisor is not paid any part of the revenue sharing arrangements. You should also be aware that we will liquidate mutual funds and or certain ETFs held in your Account if the advisors or distributors of those funds discontinue their participation in our revenue sharing program. If your Account is taxable, you will have tax consequences as a result of such liquidations. PNC Wealth Management offers other advisory programs that include Funds whose advisors and distributors do not participate in revenue sharing. You can discuss our other advisory program options with your Financial Advisor if you wish to invest in Funds outside our revenue sharing program. We will not credit your Account for any revenue sharing payments we receive. For details on revenue sharing received by PNC Wealth Management from mutual fund and certain ETF advisors or distributors, please see the following link: https://www.pnc.com/content/dam/pnc‐com/pdf/personal/wealth‐management/Additional‐Compensation‐ Disclosure.PDF For more information around the compensation a particular mutual fund or ETF provider may pay, please refer to the Fund’s prospectus and/or Statement of Additional Information. Other Expenses and Costs Additionally, some Funds impose redemption fees depending on the share class, if they are redeemed within a Page 13 of 25 PNC Directions Program October 17, 2025  specified time period, to discourage short‐term trading or for other reasons. The relevant Fund company retains these redemption charges from the proceeds of the redemption for the benefit of the remaining shareholders of the Fund. Refer to the prospectus or Statement of Additional Information of relevant Funds for details on each Funds’ short‐term trading policies. The amount of such fees and charges retained will be reflected on your account trade confirmations. Purchasing securities in the Program may cost you more or less than purchasing the securities directly from the funds or through agents of the funds without enrolling in the Program, including through a brokerage account at PNC Wealth Management. By purchasing mutual funds outside of the Program, you may invest in a single fund family and obtain “breakpoints” that could lower the cost of the Funds. However, if you purchase mutual fund shares directly, you may not receive the asset allocation and account monitoring services available via the Program and may not qualify to invest in share classes available to investors through the Program. In addition, mutual funds purchased outside the Program may charge commissions, front‐end or back‐end sales charges, and redemption fees, depending on the share class. Cash Balances Unallocated cash will be automatically swept through the Bank Deposit Sweep Program (“BDSP”) into an interest‐bearing deposit account (“Deposit Account”) at our affiliate, PNC Bank (and, as noted above, are included in the assets on which Program Fees are charged). The interest rate (“BDSP interest rate”) for BDSP assets held in the Deposit Account is determined by PNC Bank with input from PNC Wealth Management such as objective competitive market data. BDSP is the only cash sweep option available to your Program Account. The only exception is in very limited situations where your account type is not eligible for BDSP (such as participant accounts of employer sponsored qualified plans) and your funds will be invested in a money market mutual fund selected by us. You should be aware that although assets held in the Deposit Account are protected by FDIC insurance neither PNC Wealth Management nor PNC Bank will monitor whether BDSP deposits, individually or in combination with other deposits you hold at PNC Bank, exceed FDIC insurance limitations. You should review your cash balance held in the Deposit Account and other PNC Bank accounts to ensure that cash balances do not exceed FDIC insurance coverage levels, or alternatively, in the event your cash balance exceeds FDIC insurance limitations, that you are comfortable with the risks associated with having uninsured cash. The rate of return you receive on cash balances will, in certain market conditions, be less than the Program Fees attributable to such cash balances. PNC Bank uses the BDSP program assets to fund its lending activities, allowing PNC Bank to earn revenue based on the difference between the rate paid to you and the higher rate of interest earned by lending the assets to its customers. Moreover, PNC Wealth Management receives revenue from PNC Bank based on the assets in the BDSP, this revenue amount varies depending on market conditions, but will not exceed the current Federal Funds Target Rate Range – Upper Limit rate (available online at https://fred.stlouisfed.org/series/DFEDTARU) plus 0.50%.. This means PNC Wealth Management benefits in two ways from placing assets in the BDSP (i.e., the Program Fee and the revenue share from our affiliate). We will not credit any portion of this revenue to your Program Account. Note that the revenue earned by PNC Wealth Management and our affiliate PNC Bank will significantly exceed the interest credited to your Program Account from the allocation to BDSP. The revenue we receive is a conflict of interest for us, because we, and our affiliate, PNC Bank, obtain a financial benefit when your unallocated cash is held through the BDSP in a Deposit Account. This financial benefit is greater than the financial benefit we would receive if your unallocated cash was invested through a different cash sweep vehicle such as a money market fund. For information pertaining to the interest rate spread earned by PNC on all loans, including those generated Page 14 of 25 PNC Directions Program October 17, 2025  from BDSP assets, please see the Net Interest Margin discussion in the most recent Annual Report on Form 10‐K and subsequent Quarterly Reports on Form 10‐Q for The PNC Financial Services Group, Inc., available at, https://investor.pnc.com/financial‐information/financial‐results. Account assets invested through the BDSP typically will pay you less interest – and in some market conditions, much less interest – than they would if invested in alternative cash sweep vehicles that are available to PNC Wealth Management such as a money market fund. Accordingly, you should not participate in the Program if you wish to hold your unallocated cash in another sweep vehicle. (Please note that while BDSP is used as the sweep option to hold unallocated cash, if your account has an investment allocation to cash, that allocation will typically be held in money market mutual funds or other short duration securities.) For more information regarding BDSP, including information about FDIC insurance limitations, please see the PNCWM BDSP Disclosure Document, you may also review the current BDSP interest rate at the following link: https://www.pnc.com/en/personal‐banking/investments‐and‐retirement/sweep‐program‐rates.html. Additionally, information about FDIC insurance can be found on https://www.fdic.gov/resources/deposit‐ insurance/ Financial Advisor Compensation A portion of the fees charged for Program services generally will be paid to your Financial Advisor in connection with opening your Account, as well as for providing client‐related services within the Program. This compensation may be more or less than a Financial Advisor would receive if you transacted in a brokerage account, rather than a managed account in the PNC Directions Program, and paid separately for investment advice, brokerage and other services covered by the Program Fee. Therefore, your Financial Advisor may have greater financial incentive to offer a managed product over a brokerage product. As disclosed above, certain of our Programs charge a negotiable Program Fee and others charge a negotiable Program Fee plus a Model Provider Fee, which in certain circumstances may be waived but is not negotiable. Differences in fees for Model Providers in Programs with a third‐party manager, or the absence of such fees in any Program, create a conflict of interest as such differences provide an opportunity for Financial Advisors to negotiate a higher Fee for a strategy with lower or no separate Model Provider Fees than they would for strategies that charge a higher Model Provider Fee. The opportunity to negotiate a higher fee also creates a financial incentive for Financial Advisors to recommend such Programs and/or Model Providers. The ability of the Financial Advisor to negotiate a higher Program Fee in these circumstances also provides a financial benefit to PNC Wealth Management, which retains a portion of the Program Fee. Occasionally, Program Accounts may be reassigned from the originating Financial Advisor to a new Financial Advisor because the originating Financial Advisor leaves our firm, takes a new position, or for other reasons. Financial Advisors receive less compensation for accounts reassigned to them (“Reassigned Accounts”) than accounts they originated and therefore have a conflict of interest because they have a financial incentive to provide better service to accounts that they have originated versus Reassigned Accounts. Financial Advisors receive additional compensation when clients add funds to Reassigned Accounts and have incentive to encourage additional deposits to Reassigned Accounts. PNC Wealth Management has established policies and procedures reasonably designed to ensure that any recommendation made is suitable for your unique circumstances. PNC Wealth Management may advance to Financial Advisors a portion of the first year’s estimated fees for clients who invest in the Program. In addition, certain Financial Advisors who typically work with higher net worth clients can earn enhanced upfront compensation when customers establish a new advisory account or add new assets into an existing advisory account with us. This compensation creates a conflict of interest because these Financial Advisors have an additional incentive to encourage clients to place their funds in investment advisory accounts. From time to time, PNC Wealth Management initiates incentive programs for its employees including Financial Advisors. These programs include, but are not limited to, programs that compensate them for attracting new Page 15 of 25 PNC Directions Program October 17, 2025  assets and clients, or for referring business to our affiliates (such as referrals for mortgages, trusts, or insurance services); programs that reward them for promoting investment advisory services, in some circumstances by enhancing revenue credits paid to them in connection with new advisory accounts or additions to existing advisory accounts, for participating in advanced training, and for improving client service; and programs that reward Financial Advisors who meet total production criteria. Financial Advisors who participate in these incentive programs are rewarded with cash and/or non‐cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. These programs may be partly subsidized by external vendors or our affiliates, such as mutual fund companies, insurance carriers or money managers. Therefore, our Financial Advisors have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services that we offer. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients The minimum investment required for the PNC Directions Program is $5,000. We may terminate, on thirty days’ written notice to the Account holder, the advisory services on any Account that falls below minimum account value guidelines established by us. To avoid account termination, you may be required to deposit additional assets in your Account to remain in the Program. Under certain limited circumstances, we may waive the minimum account size requirement. We may also limit the maximum new account size allowable for the Program. We reserve the right to reject contributions to the Account that may result in Account balances greater than $100,000. Collateral Accounts Under certain circumstances you may elect to pledge the assets in your non‐IRA/ERISA Account as collateral for a general purpose loan with our affiliate, PNC Bank or other financial institution (collectively the “Lending Arrangements”). When your Account assets are pledged or otherwise used as collateral in connection with Lending Arrangements, you give the lender certain rights and powers over the assets in the Account. Importantly, lenders have the right to direct PNC Wealth Management to sell or redeem any and all assets pledged as collateral for the loan. In the event of a collateral call on the Account, securities will be liquidated from the Account, which may be contrary to your interests and/or inconsistent with the investment strategy for the Account because positions may be redeemed or liquidated more rapidly (and/or at significantly lower prices) than might be desirable. You or your Financial Advisor may not be provided with prior notice of the liquidation of the securities in the Account. Furthermore, you and your Financial Advisor may not be entitled to choose the securities to be liquidated. After the execution of a collateral call, any remaining securities in the Account may be lower in value than the investment minimums required for the PNC Directions Program and the Account may be subject to termination as described above. You may wish to discuss with your Financial Advisor how a collateral call could impact you if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. Any action taken by us, or an affiliate, with respect to the assets held in your Account pursuant to the Lending Arrangements will not constitute a breach of our fiduciary duties as an investment adviser to you under the PNC Directions Program. The costs associated with the Lending Arrangements are not included in the Program Fee you pay under the Program. Your transaction costs may rise as a result of a collateral call, because securities may be liquidated Page 16 of 25 PNC Directions Program October 17, 2025  under unfavorable market conditions. You should consult with your own independent tax adviser in order to fully understand the tax implications associated with the Lending Arrangements. The securities subject to the collateral call will not be liquidated in a manner that considers tax efficiency. PNC Wealth Management does not provide legal, tax or accounting advice. You are encouraged to speak with your Financial Advisor to the extent you have questions about the Program, the Lending Arrangements and how they may impact the management of your Account. You should be aware that PNC Wealth Management and your Financial Advisor have a conflict of interest because PNC Wealth Management and your Financial Advisor’s compensation is based on the assets held in your account and benefits if you enter into a Lending Arrangement instead of withdrawing funds from your account. In addition, you should be aware that PNC Wealth Management and your Financial Advisor will be compensated based on the amounts you draw on the credit line. This is a conflict of interest for your Financial Advisor because he or she has an incentive to recommend Lending Arrangements as opposed to other potential funding sources, because your Financial Advisor is not compensated for other options. In addition, PNC Bank generates revenue by charging interest on any loan underwritten by PNC Bank, which represents a further conflict of interest for PNC Wealth Management. Qualification criteria and requirements, including but not limited to, approval criteria, underwriting standards, loan to value requirements, maintenance requirements and asset eligibility vary by program. You should refer back to the Lending Arrangements and associated documents for the specific terms governing the Lending Arrangements. PORTFOLIO MANAGER SELECTION AND EVALUATION Selection of Funds PNC Directions was previously an affiliated mutual fund and ETF wrap program, utilizing mutual funds and ETFs advised by investment managers affiliated with PNCWM. In November 2019, PNC Capital Advisors sold components of its business, including the PNC Funds, to Federated Investors, Inc. (“Federated”). Subsequently, on May 18, 2020, PNC divested its entire holding of BlackRock, Inc. (“BlackRock”) and accordingly, Blackrock is no longer an affiliate of PNC Wealth Management. As a result of these transactions, the mutual fund and ETF selection criteria for PNC Directions no longer focuses on any specific investment manager, including BlackRock mutual funds, iShares or Federated mutual funds, and any eligible fund approved by PNC Wealth Management may be included in the Program. Going forward, we will evaluate BlackRock and Federated mutual funds and iShares for continued and future use in Program accounts in the same manner as we evaluate all investment managers. It is anticipated that BlackRock and Federated funds will continue to represent a significant portion of PNC Directions mutual fund accounts and that iShares will comprise all or nearly all of PNC Direction ETF accounts since we will typically not remove approved funds from the program until our research process indicates there is a reason to do so. The factors influencing the inclusion of a Fund on our list of recommended Funds include, among other things, the Fund’s past performance, management style, quality of its investment process, the number and continuity of investment professionals, and its client servicing capabilities. We receive research and assistance in selecting and reviewing mutual funds and ETFs from the Private Bank division (the “Private Bank”) of our affiliate PNC Bank and Morningstar, Inc. Expenses for these services are paid by PNC Wealth Management. We or our research partners may ask a relevant investment manager to provide a completed questionnaire, database information on the firm and statistical analysis of the mutual fund/ETF manager’s track record. We or our research providers may also conduct interviews with members of the Fund’s management. This process is an Page 17 of 25 PNC Directions Program October 17, 2025  ongoing one, and Funds are added or removed from the PNC Directions Program based on many factors, either internal or external to the Fund’s management. Returns reported are derived from sources believed to be reliable; however, we make no representations or warranties as to the accuracy of performance information. The PNC Directions Program includes investments in Funds advised or serviced by affiliates of PNC Wealth Management, who receive compensation for their investment advisory and other services to such Funds. As described above, PNC Wealth Management and our Affiliates also receive additional compensation in the form of revenue sharing payments from mutual fund and certain ETF providers or their affiliates who compensate us for assets invested in their Funds. These payments create incentives to select those mutual funds and or certain ETFs for which we receive revenue sharing and other compensation over Funds from providers that do not compensate us through revenue sharing. We also seek to mitigate conflicts of interest with respect to mutual funds and ETFs by utilizing a robust due diligence process for selecting mutual funds and ETFs for the Program. This process is designed with the intent that Funds be selected on criteria other than the compensation that may be derived by PNC Wealth Management, and our Affiliates. Each of the Funds considered for use in the Program is subject to the same review and selection process. PNC Wealth Management offers a variety of investment advisory services. Advice provided to clients of the PNC Directions Program, or action taken in PNC Directions Program accounts may be the same as or different from advice provided to or actions taken in the accounts of clients in other advisory programs. It is expected that funds recommended for this Program may or may not be recommended for our other advisory programs and vice versa. PNC Wealth Management and Other Service Providers to the Program PNC Wealth Management was formed in 2003, and is a direct, wholly owned subsidiary of PNC Bank. PNC Bank is a wholly owned subsidiary of The PNC Financial Services Group, Inc., a financial holding company. PNC Wealth Management is registered with the SEC as an investment advisor and a broker‐dealer. PNC Wealth Management is a member of FINRA and SIPC and serves as the sponsor of the Program. PNC Wealth Management does not receive performance‐based fees calculated as a share of capital gains on, or capital appreciation of, the funds or any portion of the funds or other investments in a client’s Account. National Financial provides trading, custody and operational services for the Program. National Financial carries client Accounts, is the custodian for the investments in your Account, reports all the trades in your Account and effects many such trades. National Financial will provide you with trade confirmations, monthly statements, and income tax reporting. PNC Wealth Management has also engaged a service provider to perform certain support services in connection with the Program, including account rebalancing for the asset allocation models. This service provider is also responsible for calculating and preparing quarterly performance reports for client accounts. Risks of Investing in the PNC Directions Program Investing in securities, including the investments offered through the Program, involves risk of loss that you should be prepared to bear. There is no guarantee that the elements of the Program, including the asset allocation models, selection of investment manager models and/or research recommendations will protect against such loss. Other risks include: Page 18 of 25 PNC Directions Program October 17, 2025   Market Risk. Market risk is the risk that the price of securities will fall over short or extended periods of time. Historically, the prices of equity securities have moved in cycles, and the value of an Account’s investments will fluctuate from day to day. When individual companies are negatively impacted by industry or economic trends or report poor operating results, the price of securities issued by those companies will typically decline in response. These factors contribute to price volatility.  Allocation Risk. A client Account is subject to the risk that asset allocation decisions will not anticipate market trends correctly. For example, weighting an Account too heavily in equities during a stock market decline may cause a loss of value. Conversely, investing too heavily in fixed income securities during a period of stock market appreciation may result in lower total returns.  Concentration/Diversification Risk. Concentration risk occurs when a client Account holds significant positions in certain securities, sectors or geographic regions. Concentrated positions can be more volatile and present a greater risk of loss, especially over the short term.  Credit Risk. The value of debt securities is affected by the ability of issuers to make principal and interest payments. If an issuer cannot meet its payment obligations or if its credit rating is lowered, the value of its debt securities will typically fall.  Interest Rate Risk. The value of fixed‐income investments will typically decline because of an increase in market interest rates. In addition, in certain low‐yield interest rate environments, some short‐term investments may produce negative yield, after accounting for fees, inflation and other expenses.  Liquidity Risk. The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in unusually wide bid‐ask spreads or large price movements (especially to the downside)  Stock-Specific (Unsystematic) Risk. Unsystematic risk is unique to a specific company or industry. Also known as “nonsystematic risk,” “specific risk,” “diversifiable risk” or “residual risk,” in the context of an investment portfolio, unsystematic risk can be reduced through diversification. The Program is intended to be a long‐term investment program and does not support market‐timing or frequent trading. You will be limited to one model change per calendar quarter, except as warranted by changes to your financial situation as agreed by you and PNC Wealth Management. In addition, you will be limited to one investment manager model change per asset class per quarter, except as may be agreed by you and PNC Wealth Management. Frequent or excessive trading in PNC Directions accounts are grounds for account termination, with 30 days’ written notice, by PNC Wealth Management, even if the rules above are not violated. The determination of frequent and/or excessive trading is solely at the discretion of PNC Wealth Management. Trading Practices PNC Wealth Management is an introducing broker‐dealer, clearing transactions related to the Program Accounts through National Financial. PNC Wealth Management has a best execution committee (“BEC”) that meets regularly to rigorously review data for equity orders executed by National Financial including those orders that are sent by the Investment Delegate. Such data includes, among other things, speed of execution and price improvement provided by the execution venues selected by National Financial. PNC Wealth Management does not receive any payment for order flow from the execution venues. The BEC also reviews data for fixed income trades executed through trading systems used by PNC Wealth Management to ensure that the net prices obtained are reasonable under the circumstances. Page 19 of 25 PNC Directions Program October 17, 2025  The Program Fee includes the costs of trades executed only for transactions executed through National Financial on an agency basis. The Program Fee does not include any additional trading expenses incurred when the Investment Delegate determines to trade away from National Financial or for transactions where National Financial acts as principal. The Investment Delegate will trade away from National Financial when the Investment Delegate determines it is in your best interest to do so. This can occur when the Investment Delegate is implementing a model change simultaneously across accounts with many different introducing firms, such as PNC Wealth Management. In these instances, the Investment Delegate may group together trades from several different introducing firms and execute those trades through a single broker‐dealer. This process is known as Block Trading (“Block Trading”). Block Trading is intended to reduce the market impact of executing large transactions in a particular security and can allow clients to get better overall execution prices than if the trades were placed individually. The Investment Delegate may also trade away from National Financial when it determines that a broker‐dealer other than National Financial is capable of obtaining a better execution price for the trade. This can typically occur in thinly traded securities or in fixed‐income securities. These trades will incur additional costs per bond or on a per transaction basis. These costs are embedded in the net price you receive and are not separately disclosed by the executing broker in your confirmation or statement. PNCWM does not receive any benefit when the Investment Delegate elects to trade away. It is important that you understand that you will pay any commissions, mark‐ups or mark‐downs incurred, in addition to the Program Fee when the Investment Delegate elects to trade away from National Financial or for transactions where National Financial acts as principal. For additional information on the trading practices of the Investment Delegate, please see the following link: https://www.pnc.com/content/dam/pnc‐ com/pdf/personal/wealth‐investments/PNCWM/Trade‐Practice‐Disclosure.pdf. Information regarding Investment Delegate is based upon data provided to us by the Investment Delegate. We make no representations regarding the accuracy of the information presented and cannot guarantee that the trading practices reflected in the information presented will be followed by the Investment Delegate in the future. You should also review the Form ADV Part 2 for the Investment Delegate for additional information regarding that firm’s execution practices. Proxy Voting You will retain the right to vote any and all proxies associated with securities held in the PNC Directions program. Neither PNC Wealth Management nor your Financial Advisor take any action or give advice regarding the voting of proxies to the issuers of securities on the assets in your Program Account. You will retain proxy‐ voting authority and are responsible for voting proxies over securities held in your Accounts. Our custodian, National Financial, will forward annual reports, shareholder and proxy information to you received by National Financial on the applicable assets in your Program Account. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS The PNC Directions Program involves the allocation of client assets among mutual fund or ETF portfolios, rather than among particular third‐party investment advisers or portfolio managers. Thus, PNC Wealth Management acts as the portfolio manager for the Program and obtains client information directly from you. We do not provide information about clients participating in the PNC Directions Program to the Funds or Fund companies, except to the extent such information may be required to maintain or service an Account with the Funds. CLIENT CONTACT WITH PORTFOLIO MANAGERS Page 20 of 25 PNC Directions Program October 17, 2025  The PNC Directions Program does not involve the allocation of client assets among third‐party investment advisers or portfolio managers. Instead the Program involves investment in Funds. As such, we do not expect clients to contact the Funds or Fund companies directly. PNC Wealth Management acts as the portfolio manager for the Program and clients may contact the Firm, including via their financial Advisor or other PNC Wealth Management representative. ADDITIONAL INFORMATION Disciplinary Information  On April 11, 2016, PNC Wealth Management entered into a settlement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that it failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales and failed to apply such waivers to mutual fund purchases by certain retirement plan customers that were eligible to purchase Class A shares in certain mutual funds without a front‐end sales charge. The findings also stated that PNC Wealth Management failed to maintain adequate written policies and procedures or to provide adequate training to assist financial advisors in determining when sales charge waivers were available for retirement plan customers. PNC Wealth Management was not required to pay a fine, but consented to be censured and to pay restitution to eligible customers who did not receive sales charge waivers for fund purchases since July 1, 2009.  On April 6, 2018, PNC Wealth Management entered into a settlement (“Order”) with the Securities and Exchange Commission (“SEC”). Without admitting or denying the findings, PNC Wealth Management consented to the findings that, as a result of the conduct described below, PNCWM willfully violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)‐ 7 thereunder. The Order finds that the violations resulted from the following conduct of PNCWM: (1) PNCWM, without adequate disclosure of the associated conflicts of interest, invested advisory clients in mutual fund share classes with 12b‐1 fees instead of available lower‐cost share classes of the same funds without 12b‐1 fees; (2) PNCWM did not disclose a conflict of interest regarding marketing support payments paid on such mutual fund share classes that charged 12b1 fees; (3) PNCWM improperly charged advisory fees to client accounts where the investment adviser representative departed the firm (“Orphaned Accounts”) and where PNCWM failed to assign a new investment adviser representative within thirty days; and (4) PNCWM failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices and treatment of Orphaned Accounts. The Order requires PNCWM to cease and desist from committing or causing any violations and any future violations of Advisers Act Sections 206(2), 206(4), and 207 and Rule 206(4)‐7; censures PNCWM; and requires PNCWM to pay disgorgement of $5,234,856, and prejudgment interest of $612,344, to compensate advisory clients who were affected by certain conduct detailed in the Order. PNCWM will pay, in addition to the disgorgement and prejudgment interest described above, disgorgement of $497,144 in marketing support fees and prejudgment interest thereon of $63,426 to the SEC for the transfer to the general fund of the United States Treasury. Lastly, PNCWM will pay a civil monetary penalty of $900,000.  On April 22, 2024, PNC Wealth Management signed a Final Order with the State of North Carolina Department of the Secretary of State Securities Division. Without admitting or denying the findings, Page 21 of 25 PNC Directions Program October 17, 2025  PNCWM was ordered to pay civil penalties in the amount of $7,500 and costs of investigation in the amount of $1,000 resulting from the following conduct: (1) PNCWM and one investment adviser representative (“IAR”) failed to comply with North Carolina’s IAR registration requirements in violation of N.C.G.S. §78C‐16(a1) in which the IAR transacted advisory business in North Carolina from on or about December 2021 through on or about October 2023 without being IAR registered; (2) PNCWM was in violation of N.C.G.S. §78C‐18(b) and 18 NCAC 06A .1801(a)(18) by employing the IAR in North Carolina without the appropriate registration and by not furnishing this information to the IAR’s PNCWM advisory clients; and (3) PNCWM failed to supervise the IAR’s acts, practices and conduct to ensure adherence with North Carolina’s IAR registration provisions in violation of N.C.G.S. §78C‐19(a)(2)(j) and 18 NCAC 06A .1808.  On April 24, 2024, PNC Wealth Management signed a Consent Agreement and Order with the Pennsylvania Department of Banking and Securities. The Department alleged that from on or about December 2018 until December 2023, PNCWM failed to register at least one employee as an investment adviser representative in Pennsylvania in violation of Section 301(c.1)(1)(ii) of the Pennsylvania Securities Act of 1972 (“the 1972 Act”), 70 P.S. § 1‐301(c.1)(1)(ii). Without admitting or denying the findings in the Order, PNCWM agreed to pay a monetary fine of $100,000 and to comply with the relevant provision of the 1972 Act.  On September 3, 2024, PNC Wealth Management signed a Settlement Order with the Commonwealth of Virginia Division of Securities and Retail Franchising. The Division alleged that from on or about February 2019 to June 2024, PNCWM failed to register an investment advisor representative in Virginia in violation of § 13.1‐504 C (ii) of the Virginia Securities Act. Without admitting or denying the findings in the Order, PNCWM paid $10,000 in monetary penalties and $1,000 in investigation costs.  On September 18, 2024 PNC Wealth Management entered into an Administrative Consent Agreement and Order with the District of Columbia’s Department of Insurance, Securities and Banking alleging that from on or about August 2012 through February 2024, PNCWM failed to register three investment advisor representatives in D.C. in violation of D.C. Official Code §§ 31‐5602(b)(2) and 31‐5605.01(4). PNCWM paid $162,500 as a civil penalty and $1,080 in unpaid registration fees.  On June 16, 2025, PNC Wealth Management entered into an agreement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that from at least June 2021, it violated FINRA rules by failing to establish and maintain a reasonably designed supervisory system, including written supervisory procedures, for the surveillance and supervision of rates of deferred variable annuity exchanges. PNC Wealth Management was required to pay a $200,000 fine and to implement a supervisory system and written supervisory procedures reasonably designed to achieve compliance in surveilling registered representatives’ rates of deferred variable annuity exchanges consistent with applicable securities laws and regulations, and with applicable FINRA rules. Other Financial Industry Activities and Affiliations PNC Wealth Management’ principal business is that of a full‐service, general securities broker‐dealer and investment adviser, registered with the SEC and as a member of FINRA. Our primary retail brokerage activities include the sale of corporate equities, corporate debt, municipal securities and funds, mutual funds, ETFs and annuities. PNC Wealth Management is part of a broad financial services organization and is therefore affiliated with other Page 22 of 25 PNC Directions Program October 17, 2025  entities engaged in a variety of financial services businesses. In some cases, the firm has business arrangements with its affiliates that are material to its advisory business or to its clients. These are described in more detail below and, in some cases, cause PNC Wealth Management’ or a related person’s interests to diverge from the best interests of our clients. Through its parent company, The PNC Financial Services Group, Inc., PNC Wealth Management is affiliated with the following financial services entities with whom it may have material business arrangements:  PNC Bank, National Association (“PNC Bank”) is a wholly owned subsidiary of The PNC Financial Services Group, Inc., and is a full service bank engaged in traditional lending, cash and/or treasury management and other services.  PNC Capital Advisors, LLC is a wholly owned subsidiary of PNC Bank and provides discretionary fixed income investment advisory services to institutional accounts.  PNC Capital Markets, LLC is an indirect, wholly owned subsidiary of The PNC Financial Services Group, Inc. and offers loan syndication, public finance underwriting and advisory services, securities underwriting and trading, private placements, asset securitizations and merger and acquisition advisory services.  PNC Insurance Services, LLC is a wholly owned subsidiary of PNC Wealth Management and a licensed insurance agency. It provides a variety of insurance products and advice. Selected conflicts of interest that exist between PNC Wealth Management and its affiliates are discussed below. Although PNC Wealth Management is committed to acting in the best interests of our clients, in some situations there are conflicts of interest between the Firm’s interests and a client’s interests or there are conflicts in the interests of multiple clients. Many of these conflicts of interest are inherent in operating an investment advisory business. For example, PNC Wealth Management may have an incentive to resolve a matter in favor of clients that are Affiliates of the Firm over clients that are not Affiliates of the Firm. PNC Wealth Management has adopted policies and procedures that it believes are reasonably designed to help mitigate these conflicts of interest. Affiliates of PNC Wealth Management provide advice to their clients with respect to investment strategies that are similar to or the same as strategies offered by PNC Wealth Management. Those Affiliates may purchase on behalf of their clients the same securities that PNC Wealth Management may purchase for our clients. As a result, the interests of PNC Wealth Management’ clients may conflict with the interests of the clients of these Affiliates. For example, if an investment adviser Affiliate implements a portfolio management decision for its client ahead of, or contemporaneously with, a decision PNC Wealth Management makes for its client(s), the market impact of the decision made by the Affiliate could result in one or more of PNC Wealth Management’ clients receiving less favorable trading results than they otherwise would. PNC Wealth Management’ trade allocation and trade aggregation procedures do not typically apply to portfolio management decisions and trading executed by Affiliates on behalf of such Affiliates’ clients that are not clients of PNC Wealth Management. Funds Advised by Affiliates The potential conflicts of interest involved in recommending mutual funds or ETFs advised by Affiliates of PNC Wealth Management and the methods of mitigation employed by PNC Wealth Management with respect to Page 23 of 25 PNC Directions Program October 17, 2025  such conflicts are addressed at length previously in this Brochure, specifically in the sections relating to Fees and Selection of Funds. Please refer to those sections for more information. Affiliate Transactions PNC Wealth Management or its affiliates may from time to time recommend to their clients' investments in transactions in which PNC Wealth Management or its affiliates act as financial advisor or a broker‐dealer or in securities which are underwritten, issued, packaged or serviced by an affiliate. Moreover, PNC Wealth Management may act as a broker in executing your purchase or sale for your account of a debt security from or to PNC Capital Markets, a brokerage affiliate. Additionally, your Financial Advisor may recommend you purchase a mutual fund advised by PNC Capital Advisors, an affiliated registered investment adviser. These affiliates receive compensation as a result of these transactions, if these transactions were to occur. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PNC Wealth Management has adopted a Code of Ethics, which consists of certain general principles including the following:  Advisory personnel must place client interests before their own  The personal securities transactions of our personnel must avoid even the appearance of a conflict with client interests  Our personnel must avoid actions or activities that allow, or appear to allow, them to profit or benefit from their position with respect to clients, or that would otherwise bring into question their independence or judgment  From time to time, PNC Wealth Management personnel may accept training, business entertainment or gifts of de minimis value from product vendors. PNC Wealth Management has adopted policies and procedures reasonably designed to ensure any such activity does not impact our personnel’s ability to act in the best interests of our clients  In addition, the Code of Ethics requires our employees to report their personal securities transactions and holdings. A copy of our Code of Ethics will be provided to any client or prospective client upon request. Our employees are also subject to the PNC Employee Conduct Policies, which cover matters including compliance with law, conflicts of interest, insider trading, outside activities and safeguarding confidential information. Client Reports As part of the PNC Directions Program, we will provide periodic reports to assist you in monitoring and assessing the performance of your Account. These reports will contain information regarding trades, investment return, and selected benchmark comparisons. These reports may also contain letters, notices and other important information regarding the Model Managers and any changes to the Account during the period. Client Referrals and Other Compensation Your Financial Advisor may refer you to PNC Bank or other PNC Wealth Management affiliates for additional products or services and will generally receive compensation for such referrals. A portion of the fees charged for the Program services described in this Brochure may be paid to your Financial Advisor in connection with the introduction of accounts as well as for providing client‐related services within the Programs. This compensation Page 24 of 25 PNC Directions Program October 17, 2025  may be more or less than a Financial Advisor would receive if you paid separately for investment advice, brokerage and/or other services. Certain employees of PNC Bank’s Wealth Management and or Private Client Group who are registered with PNC Wealth Management receive compensation in connection with securities transactions that result from referrals to a PNC Wealth Management Financial Advisor. PNC Wealth Management has related persons who are investment advisers who act as general partners in partnerships in which our clients may be solicited. PNC Wealth Management, however, does not recommend such investments and thus, would generally not have knowledge of such solicitations should they occur, and consequently, would not be a participant in them, nor would we receive any compensation for them. Financial Information In certain circumstances, PNC Wealth Management would be required to provide you with financial information or disclosures about our financial condition. Currently, no such circumstances exist for PNC Wealth Management. PNC Wealth Management has no financial commitments that impair our ability to meet our contractual and fiduciary commitments to our clients and has never been the subject of a bankruptcy proceeding. Page 25 of 25 PNC Directions Program October 17, 2025 

Form ADV Part 2A Appendix 1 801-66195 Disclosure Document for the Portfolio Solutions Program An Investment Advisory Service of PNC Wealth Management LLC 300 Fifth Avenue Pittsburgh, Pennsylvania 15222 (800) 622-7086 www.pnc.com October 17, 2025 This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of PNC Wealth Management LLC with respect to the Portfolio Solutions Program (the “Program”). If you have any questions about the contents of this Brochure, please contact us at (800) 622-7086. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. PNC Wealth Management LLC, a registered investment adviser and broker-dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”) is a wholly owned subsidiary of The PNC Financial Services Group, Inc. Registration does not imply a certain level of skill or training. Additional information about PNC Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. • NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, PNC BANK, N.A. OR ANY OF ITS AFFILIATES • SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED  MATERIAL CHANGES ADV Part 2A dated October 17, 2025 The following change(s) have been made to the PNC Wealth Management Portfolio Solutions Program Brochure since the last Brochure dated July 16, 2025: On or about October 17, 2025, our firm’s legal and business name will change from PNC Investments LLC to PNC Wealth Management LLC. This change is administrative in nature and does not affect the ownership, management, operation, services, or fees of the firm. All references to PNC Investments LLC within the Brochure will be updated to PNC Wealth Management LLC. No other material changes have been made since our last Form ADV 2A Brochure was filed on July 16, 2025. Page 2 of 25 Portfolio Solutions Program October 17, 2025  Table of Contents About PNC Wealth Management LLC ............................................................................................... 4 SERVICES, FEES AND COMPENSATION The Portfolio Solutions Program Account Statements Account Termination Review of Accounts Fees and Expenses Additional Fees for Brokerage Services Other Expenses Cash Balances Financial Advisor Compensation Annuity and Structured Products Fees & Expenses ............................................................................................. 4 4 .................................................................................................. ..................................................................................................................... 8 .................................................................................................................... 8 ....................................................................................................................... 9 ........................................................................................................................ 9 11 ...................................................................................... ........................................................................................................................... 11 ............................................................................................................................. 14 ................................................................................................ 15 ............................................................................................... 16 ......................................................................................................................... 17 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients Collateral Accounts ...................................................................... ................................................................................... ..................................................................................................................... 18 18 18 PORTFOLIO MANAGER SELECTION AND EVALUATION PNC Wealth Management and Other Service Providers to the Program Risks of Investing in the Portfolio Solutions Program Trading Practices Proxy Voting .................................................................. .................................. ................................................................ ......................................................................................................................... ................................................................................................................................ 19 19 20 21 21 CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS ..................................................... 21 CLIENT CONTACT WITH PORTFOLIO MANAGERS ........................................................................... 21 ADDITIONAL INFORMATION Disciplinary Information Other Financial Industry Activities and Affiliations Affiliate Transactions Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Client Reports Client Referrals and Other Compensation Financial Information ........................................................................................................... ............................................................................................................. .................................................................... .................................................................................................................. .............. ............................................................................................................................. .................................................................................. .................................................................................................................. 21 21 23 24 24 25 25 25 Page 3 of 25 Portfolio Solutions Program October 17, 2025  About PNC Wealth Management LLC PNC Wealth Management LLC (“PNC Wealth Management,” “PNCWM” or the “Firm”) is an investment adviser and also a registered broker-dealer and member of FINRA and SIPC. The Firm offers retail brokerage and investment advisory services. PNC Wealth Management serves as the sponsor of, and in some cases as a portfolio manager for, wrap fee investment programs. PNC Wealth Management is a wholly owned subsidiary of PNC Bank, National Association (“PNC Bank”) and is a part of The PNC Financial Services Group, Inc. (“PNC”) which is a diversified financial services institution with roots in commercial banking and investment management dating back to the early 1800s. Throughout this document, the terms “client,” “you,” and “yours” are used to refer to the individual(s), institution(s) or organization(s) who contract with us for the services described here. “PNC Wealth Management,” “we,” “our,” “us” and “the firm” refer to PNC Wealth Management LLC, together (as applicable) with our affiliates, including but not limited to, PNC and its agents with respect to any services provided by those agents. Our affiliates include any entity that is controlled by, controls or is under common control with PNC Wealth Management, including but not limited to our parent company, The PNC Financial Services Group, Inc. Each affiliate is a separate legal entity and not responsible for the obligations of any other affiliate. “Account” means each brokerage and/or advisory account you open with us that is subject to the Portfolio Solutions Program investment management agreement (the “Investment Management Agreement”), including any and all mutual funds, exchange traded funds, money, securities, financial instruments and/or other property you have funded in such accounts. “Business Day” means Monday through Friday, excluding New York Stock Exchange holidays. “Wrap” refers to an Account that charges a quarterly or annual fee based on the average assets under management, where such fee covers administrative, commission, execution and management expenses. SERVICES, FEES AND COMPENSATION This Brochure is being provided pursuant to Section 204 of the Investment Advisers Act of 1940, as amended, and deals solely with the Program. In addition to the Program, PNC Wealth Management offers a variety of investment advisory services. These include, but are not limited to, the Capital Directions program, the PNC Directions program, the Portfolio Solutions Strategist program, the Guided Solutions program, and the Capital Directions Annuities program. More information about these programs and services is contained in the applicable PNC Wealth Management brochure and is available upon request from PNC Wealth Management or through the SEC’s website at https://adviserinfo.sec.gov/. For more information about these or other services that are available from PNC Wealth Management, please contact your Financial Advisor.1 Other advisory services are offered by our affiliates. The Portfolio Solutions Program make investment recommendations to you and provide continuous The Program is a non-discretionary wrap fee investment advisory program through which PNC Wealth Management and your Financial Advisor1 supervision over the assets in your Account. Our recommendations are based on your individual financial Page 4 of 25 1 We use the term “Financial Advisor” to refer to PNC Wealth Management’ branch-based and wealth Financial Advisors, as well as Advisor Direct Financial Advisors and Investment Services Consultants. Portfolio Solutions Program October 17, 2025  position and investment objectives. You retain full discretion over your Account and make all investment decisions. You will select one of five core asset allocation models, each associated with a distinct risk profile and comprised of a unique mix of investment assets that have been developed by PNC Bank’s Private Bank (the “Private Bank”) and approved by PNCWM’s Due Diligence Committee (IDD). Furthermore, PNC Wealth Management may also conduct its own research, including gaining insights from non-affiliated third parties, to be used in making asset allocation decisions for the Allocation Models, which from time-to-time may diverge from models developed by the Private Bank. Although each model is designed with the objective of minimizing volatility, relative to each risk profile, there can be no assurances that this objective will be achieved. Each model described below carries with it the potential for permanent loss of capital. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long-term investment objective. In all cases, PNC Wealth Management has sole discretion in approving and modifying the Allocation Models for the Program. The models are summarized below.  Conservative. The primary objective of the Conservative model is to generate a modest amount of current income, and secondarily to provide a modest amount of long-term capital growth, which should help offset some of the effects of inflation. Long-term growth of principal will be aided by income reinvestment. While the goal is to maintain a low-risk posture, investors should be willing to accept periodic declines in portfolio value. Although past performance is no guarantee of future results, generally any such decline should be less severe than the declines in the broader equity markets. The portfolio’s allocation between equity and fixed income securities, with an allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long-term investment objective.  Moderate. The objective of the Moderate model is to generate a moderate amount of current income with the potential for longer-term capital growth. The portfolio generally is split between equity and fixed income securities, with a small allocation to cash, and is constructed to provide both long-term capital appreciation in excess of inflation and a moderate amount of current income. While the current income generated could be available to meet your day-to-day expenses, reinvestment of income will increase the portfolio’s ability to exceed inflation over the long- term. The portfolio’s allocation between equity and fixed income securities, with an allocation to cash, exposes it to both the risk of rising interest rates and falling equity prices. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long-term investment objective.  Balanced. The primary objective of the Balanced model is to provide long-term capital growth in excess of inflation, with a modest amount of current income as a secondary objective. The portfolio is allocated between equities and fixed income securities, with a higher allocation to a variety of equity securities. The portfolio also contains a small allocation to cash. While the current income generated could be available to meet your day-to-day expenses, income reinvestment will increase the portfolio’s ability to exceed inflation over the long-term. This portfolio maintains a somewhat aggressive risk posture, and you should be willing to accept periodic declines in portfolio value. Because the portfolio is largely invested in equities, it can experience fluctuations – up Page 5 of 25 Portfolio Solutions Program October 17, 2025  or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long-term investment objective.  Growth. The primary objective of the Growth model is long-term capital growth. It may secondarily generate a minimal amount of current income by including some fixed income securities. The portfolio is concentrated in equity investments in order to earn returns exceeding the rate of inflation over the long- term. A small allocation to fixed income securities, as well as cash, is included primarily to help dampen volatility over the long-term. This portfolio maintains an aggressive risk posture, and you should be willing to accept potentially significant declines in portfolio value that may be similar to or exceed declines in the broader equity markets. Because the portfolio is predominantly invested in equities, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long-term investment objective.  Aggressive. The primary objective of the Aggressive model is long-term capital growth. An Aggressive portfolio is concentrated in equity investments for long-term growth. Returns in excess of the underlying rate of inflation are necessary to increase both principal and purchasing power. This portfolio maintains a highly aggressive risk posture, and you should be willing to accept potentially significant declines in portfolio value, similar to or greater than declines in the broader equity markets. The portfolio may contain a small allocation to fixed income securities as well as cash. Because the portfolio is predominantly invested in equity securities, it can experience sharp fluctuations – up or down – in value over short time periods. Your ability to keep your funds invested in the Program throughout declining markets helps, but does not guarantee, the possibility of achieving the portfolio’s long-term investment objective. Alternative strategy mutual funds (“Alternative Funds”) may also be available. The asset allocation models include an allocation to Alternative Funds that are registered with the SEC under the Investment Company Act of 1940 (the “Investment Company Act”). Alternative Funds can use one of many different strategies including, but not limited to, long/short, managed futures, or market neutral. PNC Wealth Management will select the Alternative Funds that are available in the Portfolio Solutions Program and the allocation to Alternative Funds in the asset allocation models. You will have the ability to use the Alternative Funds up to a certain maximum percentage of the total assets in your account. You will have the ability to modify the Alternative Funds and allocation selected. Alternative Funds seek to provide additional diversification benefits beyond those of a traditional portfolio of stocks and bonds. However, Alternative Funds are accompanied by risks that might be different from those associated with traditional investments. When used as part of an overall solution, alternatives may help to meet a client’s investment needs. Because Alternative Funds are regulated under the Investment Company Act, there are several ways in which they are structured to mitigate some liquidity risk, which may occur during severe market conditions, and differ from unregistered hedge funds and other alternative investments. You should carefully review the prospectus for any Alternative Fund you are considering for details on liquidity and other risks associated with them and review the manager’s ability to place limitations on liquidity. Alternative Funds are subject to: Page 6 of 25 Portfolio Solutions Program October 17, 2025  Limits on illiquid investments including a maximum of 15% of assets in illiquid investments; Limits on leveraging of no more than 33% of assets;    Diversification requirements including a maximum of 25% of assets invested in one issuer; and  Daily pricing and redeemability of fund shares. Alternative Funds are also prohibited from charging the types of management and performance based fees (e.g., a “2/20” fee) charged by some hedge funds. Before you open a Portfolio Solutions Account with us, you should carefully review our Client Relationship Summary (“Form CRS”) and consider whether an advisory relationship is right for your situation and circumstances. You may discuss any questions you have regarding our Form CRS or whether an advisory account is right for you with your Financial Advisor. Some things you may wish to consider are your preference for a fee-based versus a commission based relationship; your desire for on-going support and advice from your Financial Advisor; how much trading activity you expect to take place in your account; and the anticipated total costs. You should know that your Financial Advisor benefits when you open a Portfolio Solutions account, as described in more detail in the Financial Advisor Compensation section of this Brochure, and has a conflict of interest when recommending an advisory account to you. Once you decide that the Program is right for you, your Financial Advisor will help you complete an investor questionnaire that provides us with an understanding of your financial situation, investment objectives, risk tolerance and investment time horizon. Based on the information collected in the questionnaire and other information you share with your Financial Advisor, your Financial Advisor will recommend an investment strategy that is designed to help meet your investment objectives. Your Financial Advisors recommendation will be based on one of the five core allocation models defined above and may incorporate any of the following: equity securities, fixed income securities, certain options strategies, mutual funds, exchange traded funds (“ETFs”), unit investment trusts (“UITs”), and/or Structured Products (Market-Linked CDs or Buffered/Structured Notes) for purchase or sale, subject to your approval. With the exception of mutual funds and annuity sub-accounts, we will not include in our recommendations securities issued by or sub-accounts advised by any of our affiliates, including The PNC Financial Services Group, Inc. You will not be able to purchase those securities directly or own them in your Portfolio Solutions Account. Finally, our recommendations to you will be limited to those securities that have been approved by PNC Wealth Management for sale under the Program. The Portfolio Solutions Program is designed for investors who would like advice but wish to retain full discretion over the assets in their Account. Neither PNC Wealth Management nor your Financial Advisor will make investment decisions on your behalf. We will contact you with recommendations, but any trading in the Account will require your prior approval. Transactions resulting from our recommendations will be “Qualifying Transactions.” PNC Wealth Management has an obligation to demonstrate value for the Program Fee (defined below in “Fees and Expenses”) you pay us and, as a result, accounts without Qualifying Transactions over an extended period, generally 12- months or more, may be terminated, with 30-days written notice to you. Although you will retain discretion to approve purchases or sales recommended by PNC Wealth Management you will not have the ability to direct purchases in your Account but will retain the right to direct any sales from your Account. The Portfolio Solutions Program is not intended for market timing or excessive trading. We may limit the number of trades you can place in your account in a calendar quarter or year. We retain the right to terminate any account that is engaging in market timing or excessive trading activities with 30 days written notice. PNC Wealth Management may define at its sole discretion the terms “market timing” and “excessive Page 7 of 25 Portfolio Solutions Program October 17, 2025  trading.” Before you may establish a Portfolio Solutions Account, you must establish a brokerage account with PNC Wealth Management and agree to the terms and conditions of the PNC Wealth Management Brokerage Account Customer Agreement. Our Portfolio Solutions advisory relationship with you is defined in the Investment Management Agreement. When you are enrolled in the Program, we act as your introducing broker and we will also act as your investment advisor, but only for your Program Account and not for any other assets or accounts, unless otherwise separately agreed to by us in writing. As discussed in more detail below, we earn certain fees and other revenue in connection to our capacity as introducing broker to your account. This is a conflict of interest because we would not earn such fees or revenue if we did not serve as your introducing broker. Our advisory relationship with you begins when we enter into an Investment Management Agreement with you, which occurs at the later of the date of acceptance of the signed Investment Management Agreement by PNC Wealth Management or the date on which you have contributed the required minimum level of assets to your Account. Preliminary discussions or recommendations before we enter into an Investment Management Agreement with you are not intended as investment advice under the Investment Advisers Act and should not be relied on as such. Portfolio Solutions accounts must meet minimum standards for portfolio diversification at the security and asset class level. If your account does not meet these minimum standards, your Financial Advisor will contact you to recommend corrective action. If you choose not to accept this recommendation, we may terminate your Account with 30-days written notice to you. You will not be able to purchase securities on margin under the Program. Account Statements You will receive a monthly statement following any month in which there is investment activity in your Account, confirming all transactions in your Account, including additions, disbursements, purchases, sales, and advisory fees paid to PNC Wealth Management or fees paid to Model Providers. For periods in which there is no investment activity in your Account, statements will be provided quarterly. You will also receive a quarterly performance report that tracks the performance of your portfolios against relevant benchmarks. You will be reminded quarterly to contact your Financial Advisor if you should have any questions, or if there have been material changes in your financial goals or needs that would affect your investment strategy. Account Termination Either party may terminate the Investment Management Agreement on 30 days’ written notice to the other party. You are also entitled to terminate such agreement within five (5) business days of your execution of it without incurring a Program Fee, defined below; you may, however, be subject to certain other fees incurred with respect to the Account for the relevant period. Upon the termination of the Investment Management Agreement, PNCWM will be under no obligation to provide advice on any holdings in your Account. Any transactions executed by you after the termination of the Investment Management Agreement will be subject to fees and commissions described in the PNC Wealth Management Overview of Products and Services (the “Overview of Products and Services”). You may obtain a copy of our current Overview of Products and Services, at any time, by contacting your Financial Advisor, by contacting us at (800) 622-7086 or online at www.pnc.com/investments-relationship-summary. In addition, upon learning of the death of any account owner, PNCWM will immediately terminate the Investment Management Agreement. You should be aware that any transactions executed by your heirs or beneficiaries after your death will be subject to fees and commissions described in the Overview of Products and Services, unless waived by us in our sole discretion. Please see the agreement governing your Portfolio Solutions Program Account for more information. The Investment Management Agreement will continue in effect until terminated by you or PNC Wealth Page 8 of 25 Portfolio Solutions Program October 17, 2025  Management upon 30 days’ written notice to the other party. Review of Accounts When you open a Portfolio Solutions Program Account, we review and must approve your investment objectives and strategy for consistency with Portfolio Solutions Program guidelines. Thereafter, we will monitor the Account to ensure it remains aligned to your investment goals and objectives. We will also monitor to ensure the Account remains in compliance with Program guidelines. Factors we monitor may include, but are not limited to, trading activity, alignment with the allocation model selected, and Account investment performance. Your Financial Advisor may contact you to suggest changes or updates to your Program Account when any issue is identified through our monitoring process. You are not required to accept any suggestions made to you, however, we may terminate your Account, with 30-days written notice to you, if our review finds that your continuation in the Program is not in your best interest. We will attempt to contact you at least semiannually, including by mail or email (if you have authorized us to send you electronic communications), to request that you review your Account and inform us of any changes to your financial profile or investment objectives. You should promptly inform your Financial Advisor of any changes to your financial profile or investment objectives as they occur. Finally, your Financial Advisor will be reasonably available to you for consultation about the Account. We encourage you to please contact your Financial Advisor if you have any questions. Fees and Expenses The fee you pay to PNC Wealth Management for the Portfolio Solutions Program (“Program Fee”) covers administrative, commission, execution and management expenses for your Account. The Program Fee covers the cost of brokerage commissions and other transaction fees only for transactions executed through our custodian, National Financial Services LLC (“National Financial”), on an agency basis. You should be aware that your account is subject to the Program Fee whether you make or lose money on the investments. The fee is charged quarterly in advance and will be based on the average daily market value in your Portfolio Solutions Account over the prior calendar quarter, including cash holdings, or portion thereof. However, cash holdings in excess of 7.5% (operational cash purposes i.e., trading and account maintenance needs) will be excluded from the average daily market value calculation when the Program Fee is calculated. In certain circumstances, the Program Fee may be negotiable. The Program Fee for Portfolio Solutions is in addition to any of the specific product fees and expenses that are discussed in more detail below and in the Annuity and Structured products section. You may be charged commissions or service charges for transactions executed prior to establishing your Portfolio Solutions account; you should discuss your options for funding your account with your Financial Advisor. For purposes of calculating the Program Fee above, when an annuity is purchased as part of your Account, the annuity account value is determined by the aggregation of the values of subaccounts or index segments and does not include any additional rider or death benefit values. You may contact your Financial Advisor if you have any questions regarding the fees charged to your account. Upon your request we will provide you with a detailed explanation of the fee calculation, which will allow you to recalculate the fee should you so desire. All of the fees incurred by your Account will be paid from the cash balance in the Account. If your Account does not have a sufficient cash, we will sell securities as necessary to pay the fees. Selling securities to pay fees is subject to the short-term trading policies of Funds and, if your account is taxable, will create tax consequences Page 9 of 25 Portfolio Solutions Program October 17, 2025  for you. The Program Fee is based on the total assets under management, including any portion of the Account maintained in cash or in short-term vehicles including, but not limited to, unallocated cash swept to a deposit account at our affiliate, PNC Bank, or money market funds. As the aggregate market value of the Program Account and if applicable, other managed accounts in the billing household reach a higher tier, as shown in the table below, the assets within that higher tier are charged a lower rate. Our standard Program Fee schedule is as follows: Assets Under Management Maximum Program Fee First $250,000 2.00% Next $250,000 1.75% Next $500,000 1.50% Next $1,000,000 1.25% Next $2,000,000 1.00% Over $4,000,000 Negotiable From time to time, we offer discounting programs at our discretion. For example, current employees of PNCWM and their immediate family members are eligible for employee pricing. Your Financial Advisor has discretion to negotiate a Program Fee that varies from the standard schedule above. This can depend on certain factors, including the type and size of your Account, the range of services provided and the total amount you or other members of your household have invested with PNC Wealth Management. The Program Fee for your Account is referenced in the fee schedule included as part of the Proposal completed and accepted by you. The minimum account size is generally $250,000, however, the Program minimum for accounts that include a tactical allocation to variable annuities is $275,000 with a minimum allocation of $25,000 to the variable annuity. We may also charge an annual fee of $35 for IRA accounts with a market value under $25,000. If your Account is new, you will pay an initial fee after the date that National Financial, the custodian, receives the initial assets of your Account. An adjustment to the next quarterly fee will be made for any significant contributions or distributions that occur during the inception quarter of your Account. With your initial contribution and for any additional contribution or distribution adjustments, your fee will be calculated for that portion of the ongoing quarterly Program Fee that relates to the number of days remaining in the calendar quarter as of the date your Account becomes subject to the Investment Management Agreement or that you make the additional contribution or distribution, as applicable. This Program Fee will be based on the total market value of assets in your Account on that date. Page 10 of 25 If your Account is terminated by you or PNC Wealth Management during a calendar quarter, the fee for that quarter will be prorated over the number of days that the Account was open during the quarter. Any overpayment will be refunded to you after the Account is closed. Fees are not prorated for contributions or withdrawals made during a calendar quarter, except in the case of a new or terminated Account, as outlined above. If you terminate your Portfolio Solutions account within 90 calendar days of initial investment, PNC Wealth Management reserves the right to charge you commissions, according to the Overview of Products and Portfolio Solutions Program October 17, 2025  Services, for transactions executed on your behalf during the time your account was managed, less any pro- rated advisory fee paid by you. Additional Fees for Brokerage Services PNC Wealth Management will charge its standard fees for additional brokerage account services that are not included in the Program. Such fees include, but are not limited to, account termination/ transfer fees, wire transfer fees, IRA fees and stop payment fees. You should be aware that in some cases, PNCWM retains this entire fee or marks up the fee our clearing firm, National Financial, charges to PNCWM for these services. This is a conflict of interest for us because PNCWM has an incentive to utilize a clearing firm that allows us to mark- up designated fees. PNCWM also has incentive to recommend to you services that have been marked-up. Please refer to the Account Level Fees section of the Overview of Products and Services for details. Your Financial Advisor will only recommend securities that have been approved through our due diligence process for inclusion in the Program. As an accommodation to you, PNC Wealth Management may (but is not obligated to) allow you to hold certain securities in your account that are not on PNC Wealth Management’ list of approved securities for the Program (collectively “Un-Approved Securities”), for example if you transferred that security into the account or if we previously approved the security for inclusion in the Program. Un-Approved Securities are excluded from the billing calculation for your Account. Neither your Financial Advisor nor PNC Wealth Management will perform due diligence on any Un-Approved Securities. Because your Financial Advisor’s compensation with respect to your Account is based on the Program Fee we receive, you should be aware that your Financial Advisor has an incentive to recommend you that replace your Un-Approved Securities with approved securities. The Program Fee includes non-discretionary investment advice and services, custody and brokerage commissions, except as described below. The fee covers the cost of brokerage commissions and other transaction fees only for those transactions executed through PNC Wealth Management. We will not, however, negotiate brokerage fees or charges (including commissions) for transactions executed through PNC Wealth Management, and volume discounts may not be obtained. Depending on the number of transactions that occur in your Account, the Program Fee may be more or less than commissions you would pay if commissions were negotiated and paid separately. Other Expenses Each of the mutual funds, including money market mutual funds, in which Program assets are invested pay separate operating expenses, management fees and distribution fees. As a shareholder of these funds, you, along with other shareholders of the funds, will bear a proportionate share of the funds’ expenses, including, as permitted by applicable law, certain management and other fees which may be payable to PNC Wealth Management or our affiliates. Each fund’s prospectus or other disclosure document contains a description of its fees and expenses. These fees and expenses will reduce your investment returns. Some mutual funds may also impose redemption fees to discourage short-term trading. Redemption charges are retained from the proceeds of the sale by the fund company. Other classes of mutual funds have lower fund-level fees and expenses than those used in this Program. Please review the relevant Funds’ prospectuses for a full explanation of fund expenses and charges. Redemption charges are in addition to the Program Fee paid to us and are reflected on your monthly statement. For specific information regarding other expenses related to variable annuities and structured products, please reference the “Fees and Expenses” section under the Annuity and Structured Products heading below. Page 11 of 25 PNC Wealth Management includes in the Program only “Approved Share Classes” of mutual funds, which are Portfolio Solutions Program October 17, 2025  share classes that generate revenue sharing payments, as described below, to PNCWM. PNCWM will select Approved Share Classes that are either (i) share classes that trade on our custodian’s Institutional No- Transaction Fee platform (“INTF Eligible” share classes); or (ii) if no such INTF Eligible share class is available, the least expensive non-INTF Eligible share class eligible for inclusion in the Program. PNC Wealth Management uses INTF Eligible share classes in order to reduce PNC Wealth Management’ overall program trading costs, which costs would otherwise be payable by PNC Wealth Management. These selection criteria represent a conflict of interest for us because they enable PNC Wealth Management to avoid costs, but also may result in you purchasing a share class that is more expensive than other share classes of the same fund for which you are eligible. You acknowledge that when you establish a Program Account, you authorize and direct PNC Wealth Management to purchase for your Account only Approved Share Classes using the criteria described above and you waive any obligation of PNC Wealth Management, if applicable, to purchase any other share classes for your Account, even if less expensive share classes are available. A higher cost share class will adversely affect the investment performance of your account. INTF Eligible share classes do not typically charge shareholders 12b-1 fees or pay those fees to us or our custodian, which reduces costs to you, as compared to share classes that do pay 12b- 1 fees. Please note that the mutual funds included in the Program may provide compensation such as fees for omnibus accounting, sub-administration, shareholder services, recordkeeping, print mail services or other related fees (“Mutual Fund Compensation”). While we do not expect to receive such fees, PNC Wealth Management will credit to your Account any Mutual Fund Compensation or 12b-1 fees paid to us in connection with the holdings in your Account. As described more fully below, money market funds held in your Account typically charge 12b-1 fees, but we will rebate any such fees we receive. Our custodian or other entities not affiliated with PNC Wealth Management may receive Mutual Fund Compensation. PNC Wealth Management is not a party to such arrangements and we will not credit your Account for Mutual Fund Compensation received by such entities. You should be aware that any Mutual Fund Compensation paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. Additionally, in limited circumstances, at your direction, PNC Wealth Management may allow you to hold a mutual fund that is not an Approved Share Class in your Program account. We will credit to your account any 12b-1 fees we receive on such shares. Exchange-traded funds, or ETFs, are similar to mutual funds in that they invest in a basket of securities, such as stocks, bonds, or other asset classes. Unlike mutual funds, however, ETFs trade on an exchange and their price can change throughout the day and may vary from the value of the underlying assets in the investment portfolio. There are three different types of ETFs: Index based or Passive – which track a specified index such as the S&P 500 or NASDAQ Composite Index, Smart beta – which invest in factors through a rules-based index (low-volatility, equal-weight, etc.), and actively managed – which are not tied to an index and offer portfolio manager flexibility and security selection with the intent to outperform a benchmark. Most ETFs publish their holdings daily. ETFs have internal operating expenses that reduce investment returns. Active ETFs generally, have higher internal operating expenses than other ETF types. ETFs typically have lower expenses than mutual funds that are actively managed. However, even though a mutual fund in the same asset class as an ETF may be more expensive, other factors such as ETFs that trade less frequently could make a mutual fund more advantageous. PNC Wealth Management receives an annual credit from National Financial (the “ETF Revenue Share Credit”). The ETF Revenue Share Credit is projected based on future sales of actively managed ETFs through National Financial. PNCWM's receipt of the ETF Revenue Share Credit is dependent on National Financial sharing a portion of its actively managed ETF revenue. With the receipt of the ETF Revenue Share Credit, we are incentivized to recommend actively managed ETFs over other ETFs and products in which we either receive less Page 12 of 25 Portfolio Solutions Program October 17, 2025  or no revenue share as compared to the ETF Revenue Share Credit. We are also incentivized to select and continue our relationship with National Financial to receive the ETF Revenue Share Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. We will retain the ETF Revenue Share Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the ETF Revenue Share Credit. You should be aware that any ETF Revenue Share Credit paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. PNC Wealth Management receives an annual credit from National Financial (the “Business Development Credit”). PNCWM is incentivized to select and continue its relationship with National Financial to receive the Business Development Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. The Business Development Credit is not related to the sale or offer of any specific products or services, nor is it dependent upon assets under management. If received, we will retain the Business Development Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the Business Development Credit. Additionally, if under certain circumstances our clearing arrangement with National Financial is terminated prior to the expiration of our agreement, PNCWM is subject to certain contractual fees and penalties (collectively, the “Termination Fee”). The Termination Fee creates a strong disincentive for PNCWM to consider clearing relationships other than National Financial. This creates a conflict of interest for us as we expect to benefit from the continued recommendation of National Financial as our clearing firm. Additionally, PNCWM is further incentivized to continue the relationship with National Financial as we may not receive the same incentives from other clearing firm arrangements, such as receiving particular credits from National Financial or having the ability to mark-up certain fees to clients. Purchasing securities in the Program may cost you more or less than purchasing the securities directly from the funds or through agents of the funds without enrolling in the Program, including through a brokerage account at PNC Wealth Management. PNC Wealth Management uses INTF Eligible share classes in order to reduce PNC Wealth Management’ overall program trading costs. This represents a conflict of interest for us because the INTF Eligible share class that we include in the Program may be more expensive than other share classes you may be eligible to purchase. From time to time, PNC Wealth Management may convert non INTF Eligible share classes held in Program accounts to INTF Eligible share classes. The timing of any such conversion will be at the discretion of PNC Wealth Management and will be completed without any cost or tax consequences to your account. This may result in your account converting to share classes that are more costly than what was previously held. You should consult with your Financial Advisor if you have any concerns about the impacts of any such conversion on your account. In addition, you should know that our custodian may periodically modify the INTF Eligible list, which may change the lowest cost INTF Eligible share class. Page 13 of 25 PNC Wealth Management receives additional compensation, referred to as revenue sharing, from the advisors or distributors of the mutual funds offered in the Program, which compensates us for administrative services we provide to them and is based on the amounts our customers invest in those mutual funds in the Program. Our independent due diligence process for selecting mutual funds and ETFs for the Program is designed so that products are selected based on objective, investment related criteria and does not take into account compensation to PNC Wealth Management. However, only funds for which we receive revenue sharing are considered for inclusion in this due diligence process. This is a conflict of interest for us because funds and or certain ETFs that may otherwise meet our investment criteria are not included in the Program because their advisors or distributors do not offer revenue sharing to PNC Wealth Management. In addition, we receive a higher revenue share amount on mutual funds than ETFs. This is a conflict of interest for us when there are Portfolio Solutions Program October 17, 2025  similar products offered in both product categories as we will be paid more revenue share when recommending mutual funds than if an ETF is recommended. We will not credit your Accounts for any revenue sharing payments we receive. Although we include only mutual funds and certain ETFs whose sponsors pay PNCWM revenue sharing, we believe this conflict is mitigated by the large and diverse universe of Funds we make available in our programs which meet our clients’ needs. You should also be aware that we will discontinue due diligence coverage of mutual funds and or certain ETFs held in your Account if the advisors or distributors of those funds discontinue their participation in our revenue sharing program. In such cases, those mutual funds and or certain ETFs will become Un-Approved Securities, as defined above. PNC Wealth Management offers other advisory programs that include Funds whose advisors and distributors do not participate in revenue sharing. You can discuss our other advisory program options with your Financial Advisor if you wish to invest in Funds outside our revenue sharing program. Similarly, we will also only consider annuities for inclusion in the Program if their distributors participate in the revenue sharing program. We will not credit your Account for any revenue sharing payments we receive. For details on revenue sharing received by PNC Wealth Management from advisors or distributors, please see the following link: https://www.pnc.com/content/dam/pnc-com/pdf/personal/wealth-management/Additional-Compensation- Disclosure.PDF For more information around the compensation a particular mutual fund provider may pay, please refer to the mutual fund’s prospectus and/or Statement of Additional Information. In addition, Structured Product issuers will pay PNC Wealth Management a structuring fee through InspereX as detailed in the offering documents and described in more detail in the Overview of Products and Services. Finally, your Account may be invested in mutual funds or annuity sub-accounts for which PNC Wealth Management or one of our affiliates acts as an advisor, sub-advisor, or administrator, and receives a fee for such services. Therefore, PNC Wealth Management or an affiliate receives fees for the services provided to the Funds. The level of advisory or sub-advisory fees paid to PNC Wealth Management or its affiliates by such Funds, is disclosed in the Prospectus and/or Statement of Additional Information of such Funds. The maximum amount of your Account assets that may be invested in Funds, which pay advisory or sub-advisory fees to PNC Wealth Management or its affiliates will depend on many factors, but in certain circumstances may reach 100% of your Account assets. You should ask your Financial Advisor about these advisory or sub- advisory fees, and you may terminate your Investment Management Agreement with PNC Wealth Management at any time if you have any concerns about the level of these fees or the incentives that they create. PNC Wealth Management has an obligation to invest your assets in a manner that considers your best interests first. To that end, PNC Wealth Management will take steps to minimize potential conflicts of interest that arise from investing with Funds that pay PNC Wealth Management or its affiliates advisory or sub-advisory fees, to the extent required by applicable federal or state laws. PNC Wealth Management evaluates the appropriateness of investing your assets in Funds managed by affiliates of PNC Wealth Management, in the same manner as it evaluates all other Funds available through the Program. Cash Balances Unallocated cash will be automatically swept through the Bank Deposit Sweep Program (“BDSP”) into an interest-bearing deposit account (“Deposit Account”) at our affiliate, PNC Bank (and, as noted above, are included in the assets on which Program Fees are charged). The interest rate (“BDSP interest rate”) for BDSP assets held in the Deposit Account is determined by PNC Bank with input from PNC Wealth Management such as objective competitive market data. BDSP is the only cash sweep option available to your Program Account. The only exception is in very limited Page 14 of 25 Portfolio Solutions Program October 17, 2025  situations where your account type is not eligible for BDSP (such as participant accounts of employer sponsored qualified plans) and your funds will be invested in a money market mutual fund selected by us. You should be aware that although assets held in the Deposit Account are protected by FDIC insurance neither PNC Wealth Management nor PNC Bank will monitor whether BDSP deposits, individually or in combination with other deposits you hold at PNC Bank, exceed FDIC insurance limitations. You should review your cash balance held in the Deposit Account and other PNC Bank accounts to ensure that cash balances do not exceed FDIC insurance coverage levels, or alternatively, in the event your cash balance exceeds FDIC insurance limitations, that you are comfortable with the risks associated with having uninsured cash. The rate of return you receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to such cash balances. PNC Bank uses the BDSP program assets to fund its lending activities, allowing PNC Bank to earn revenue based on the difference between the rate paid to you and the higher rate of interest earned by lending the assets to its customers. Moreover, PNC Wealth Management receives revenue from PNC Bank based on the assets in the BDSP, this revenue amount varies depending on market conditions, but will not exceed the current Federal Funds Target Rate Range – Upper Limit rate (available online at https://fred.stlouisfed.org/series/DFEDTARU) plus 0.50%. This means PNC Wealth Management benefits in two ways from placing assets in the BDSP (i.e., the Program Fee and the revenue share from our affiliate). We will not credit any portion of this revenue to your Program Account. Note that the revenue earned by PNC Wealth Management and our affiliate PNC Bank will significantly exceed the interest credited to your Program Account from the allocation to BDSP. The revenue we receive is a conflict of interest for us, because we, and our affiliate, PNC Bank, obtain a financial benefit when your unallocated cash is held through the BDSP in a Deposit Account. This financial benefit is greater than the financial benefit we would receive if your unallocated cash was invested through a different cash sweep vehicle such as a money market fund, which could pay you a higher rate of interest. For information pertaining to the interest rate spread earned by PNC on all loans, including those generated from BDSP assets, please see the Net Interest Margin discussion in the most recent Annual Report on Form 10- K and subsequent Quarterly Reports on Form 10-Q for The PNC Financial Services Group, Inc., available at, https://investor.pnc.com/financial-information/financial-results. Account assets invested through the BDSP typically will pay you less interest – and in some market conditions, much less interest – than they would if invested in alternative cash sweep vehicles that are available to PNC Wealth Management such as a money market fund. Accordingly, you should not participate in the Program if you wish to hold your unallocated cash in another sweep vehicle. (Please note that while BDSP is used as the sweep option to hold unallocated cash, if your account has an investment allocation to cash, that allocation will typically be held in money market mutual funds or other short duration securities.) The rate of return you receive on cash balances will, in certain market conditions, be less than the Program Fees attributable to such cash balances. For more information regarding BDSP, including information about FDIC insurance limitations, please see the PNCWM BDSP Disclosure Document, you may also review the current BDSP interest rate at the following link: https://www.pnc.com/en/personal-banking/investments-and-retirement/sweep-program- rates.html. Additionally, information about FDIC insurance can be found on https://www.fdic.gov/resources/deposit-insurance/ Financial Advisor Compensation A portion of the fees charged for Program services generally will be paid to your Financial Advisor in connection with opening and managing your Account, as well as for providing client-related services within the Program. In Page 15 of 25 Portfolio Solutions Program October 17, 2025  addition, certain Financial Advisors who typically work with higher net worth clients can earn enhanced upfront compensation when customers establish a new advisory account or add new assets into an existing advisory account with us. This compensation creates a conflict of interest because these Financial Advisors have an additional incentive to encourage clients to place their funds in investment advisory accounts. This compensation may be more or less than a Financial Advisor would receive if you transacted in a brokerage account, rather than a managed account in the Portfolio Solutions Program, and paid separately for investment advice, brokerage and other services covered by the Program Fee. Therefore, your Financial Advisor may have greater financial incentive to offer a managed product over a brokerage product. As disclosed above, certain of our Programs charge a negotiable Program Fee and others charge a negotiable Program Fee plus a Model Provider Fee, which in certain circumstances may be waived but is not negotiable. Differences in fees for Model Providers in Programs with a third-party manager, or the absence of such fees in any Program, create a conflict of interest as such differences provide an opportunity for Financial Advisors to negotiate a higher Fee for a strategy with lower or no separate Model Provider Fees than they would for strategies that charge a higher Model Provider Fee. The opportunity to negotiate a higher fee also creates a financial incentive for Financial Advisors to recommend such Programs and/or Model Providers. The ability of the Financial Advisor to negotiate a higher Program Fee in these circumstances also provides a financial benefit to PNC Wealth Management, which retains a portion of the Program Fee. Occasionally, Program Accounts may be reassigned from the originating Financial Advisor to a new Financial Advisor because the originating Financial Advisor leaves our firm, takes a new position, or for other reasons. Financial Advisors receive less compensation for accounts reassigned to them (“Reassigned Accounts”) than accounts they originated and therefore have a conflict of interest because they have a financial incentive to provide better service to accounts that they have originated versus Reassigned Accounts. Financial Advisors receive additional compensation when clients add funds to Reassigned Accounts and have incentive to encourage additional deposits to Reassigned Accounts. PNC Wealth Management has established policies and procedures reasonably designed to ensure that any recommendation made is suitable for your unique circumstances. From time to time, PNC Wealth Management initiates incentive programs for its employees, including Financial Advisors. These programs include, but are not limited to, programs that compensate them for attracting new assets and clients, or for referring business to our affiliates (such as referrals for mortgages, trusts or insurance services); programs that reward them for promoting investment advisory services, , in some circumstances by enhancing revenue credits paid to them in connection with new advisory accounts or additions to existing advisory accounts, for participating in advanced training, and for improving client service; and programs that reward Financial Advisors who meet total production criteria. Financial Advisors who participate in these incentive programs are rewarded with cash and/or non-cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. These programs may be partly subsidized by external vendors or our affiliates, such as mutual fund companies, insurance carriers or money managers. Therefore, our Financial Advisors have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services that we offer. Additionally, please note our Financial Advisors are still subject to our reasonably designed policies and procedures to ensure that any recommendation made is suitable for your unique circumstances. Annuity and Structured Products Structured Products Structured products are debt securities in which returns are tied to the performance of an underlying reference asset such as a basket of stocks or a broad based index like the S&P 500. Structured products Page 16 of 25 Portfolio Solutions Program October 17, 2025  offer various levels of downside protection against losses and come in a variety of types such as market- linked CDs, principal protected notes, buffered notes and barrier notes. Features, benefits, risks and other characteristics of Structured Products offered by PNC Wealth Management are addressed in detail in the PNC Wealth Management Structured Products Disclosure document, which you should review carefully prior to investing in any Structured Product. Structured products are intended to be held to full maturity. Selling a structured product prior to maturity will most likely result in receiving an amount less than the underlying security value. There is no guarantee of a secondary market to sell a structured product after you purchase it. The issuer may make a secondary market available but is not required to do so and can discontinue any such secondary market at any time. The statement value of your structured product will not be a prediction of the price you may be able to sell your structured product for in the secondary market. Structured Products represent unique characteristics and risks, and you should be sure that you understand those risks before investing in any Structured Product. Before you may invest in certain Structured Products, PNC Wealth Management will review and must approve your Account. The terms of each Structured Product are described in the offering document which you should review prior to investing. You should also carefully review the PNC Wealth Management Structured Products Disclosure document and discuss any Structured Product you are considering with your Financial Advisor prior to investing. Variable Annuity Variable annuities are not currently available for purchase in new accounts. A variable annuity (VA) is a deferred annuity that provides investment returns based on the performance of market-based subaccounts or indexed-linked segments. VAs are flexible contracts that can provide clients with a variety of solutions, including the option to provide for guaranteed living and death benefits. VAs are market based and can lose value based on market performance. Before purchasing a VA, please review the product’s prospectus in detail for all the features, risks, and benefits. Annuities are not FDIC insured and all guarantees are subject to the claims paying ability of the issuing insurance carrier. Annuity contracts are subject to federal income tax penalties for withdrawals prior to age 59 ½. Additionally, VAs held in a tax-qualified account (including IRAs) receive the same tax benefits as those held outside of a tax-qualified account. No additional tax benefits result from purchasing or holding an annuity in a tax qualified account. If an annuity is purchased within the Account, you will retain a direct contract with the insurance company. Your Advisor will continue to act as the servicing agent on the contract and will be entitled to all rights you assign to your Advisor as determined in the annuity contract. As a part of the managed account, your Advisor will recommend an asset allocation within your annuity contract in alignment with the previously described five core allocation models. As contract owner, you will retain the ability to reallocate your annuity contract directly with the carrier. Reallocations without PNC Wealth Management input or oversight will limit PNC Wealth Management’ ability to effectively serve as Investment Advisor on the account and may compromise performance. If material reallocations or changes to the annuity contract are identified, your Financial Advisor may contact you to recommend changes that will realign your annuity with the allocation model selected. If you choose not to accept this recommendation, we may terminate your Account with 30-days written notice to you. Subaccount transactions within your annuity account may also be subject to restrictions and/or limitations, please refer to the contract and/or product prospectus for details. Fees & Expenses Page 17 of 25 Portfolio Solutions Program October 17, 2025  If a structured product is purchased in your account, additional fees may be charged by the issuing company. VA contracts charge Mortality, Expense & Administration (sometimes referred to as M&E or M&E&A) fees and other fees assessed by the annuity carrier. Any additional riders may be subject to an additional fee. These charges are assessed against the contract’s account value. M&E fees and other fees related to an annuity contract are explicitly outlined in each product’s prospectus. Investment in the insurance company’s subaccounts may also be subject to additional fund expense fees. The product’s prospectus should be thoroughly reviewed for a full explanation of the assessment of all fees and expenses. All fees assessed by the annuity carrier are in addition to any Program Fees charged by PNC Wealth Management. In addition, if an annuity is held, the insurance company will provide trading and operational services for your contract held within a Portfolio Solutions accounts. The insurance company will provide the owner with annual or quarterly statements of the contract values, along with change confirmations and tax notifications. The value of your contract will also be reflected on your Portfolio Solutions account statement. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients The minimum account size is $250,000, however, the Program minimum for accounts that include a tactical allocation to variable annuities is $275,000 with a minimum allocation of $25,000 to the variable annuity. We may also charge an annual fee of $35 for IRA accounts with a market value under $25,000. PNC Wealth Management may terminate the advisory services on any Account that falls below minimum account value guidelines established by the firm on 30-days’ written notice to the Account holder. To avoid termination, you may be required to deposit additional assets in your Account to remain in the Program. Under certain limited circumstances, we may waive the minimum account size requirement. Collateral Accounts Under certain circumstances you may elect to pledge the assets in your non-IRA/ERISA Account as collateral for a general purpose loan with our affiliate, PNC Bank or other financial institution (collectively the “Lending Arrangements”). When your Account assets are pledged or otherwise used as collateral in connection with Lending Arrangements, you give the lender certain rights and powers over the assets in the Account. Importantly, lenders have the right to direct PNC Wealth Management to sell or redeem any and all assets pledged as collateral for the loan. In the event of a collateral call on the Account, securities will be liquidated from the Account, which may be contrary to your interests and/or inconsistent with the investment strategy for the Account because positions may be redeemed or liquidated more rapidly (and/or at significantly lower prices) than might be desirable. You or your Financial Advisor may not be provided with prior notice of the liquidation of the securities in the Account. Furthermore, you and your Financial Advisor may not be entitled to choose the securities to be liquidated. After the execution of a collateral call, any remaining securities in the Account may be lower in value than the investment minimums required for the Portfolio Solutions Program and the Account may be subject to termination as described above. You may wish to discuss with your Financial Advisor how a collateral call could impact you if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. Any action taken by us, or an affiliate, with respect to the assets held in your Account pursuant to the Lending Arrangements will not constitute a breach of our fiduciary duties as an investment adviser to you under the Portfolio Solutions Program. Page 18 of 25 Portfolio Solutions Program October 17, 2025  The costs associated with the Lending Arrangements are not included in the Program Fee you pay under the Program. Your transaction costs may rise as a result of a collateral call, because securities may be liquidated under unfavorable market conditions. You should consult with your own independent tax advisor in order to fully understand the tax implications associated with the Lending Arrangements. The securities subject to the collateral call will not be liquidated in a manner that considers tax efficiency. PNC Wealth Management does not provide legal, tax or accounting advice. You are encouraged to speak with your Financial Advisor to the extent you have questions about the Program, the Lending Arrangements and how they may impact the management of your Account. You should be aware that PNC Wealth Management and your Financial Advisor have a conflict of interest because PNC Wealth Management and your Financial Advisor’s compensation is based on the assets held in your account and benefits if you enter into a Lending Arrangement instead of withdrawing funds from your account. In addition, you should be aware that PNC Wealth Management and your Financial Advisor will be compensated based on the amounts you draw on the credit line. This is a conflict of interest for your Financial Advisor because he or she has an incentive to recommend Lending Arrangements as opposed to other potential funding sources, because your Financial Advisor is not compensated for other options. In addition, PNC Bank generates revenue by charging interest on any loan underwritten by PNC Bank, which represents a further conflict of interest for PNC Wealth Management. Qualification criteria and requirements, including but not limited to, approval criteria, underwriting standards, loan to value requirements, maintenance requirements and asset eligibility vary by program. You should refer back to the Lending Arrangements and associated documents for the specific terms governing the Lending Arrangements. PORTFOLIO MANAGER SELECTION AND EVALUATION The Portfolio Solutions Account is managed to diversify your investments and may include investments in equity and fixed-income securities, options, ETFs, mutual funds, money market instruments and structured products. Accounts are managed on an individual basis, and our asset allocation and investment recommendations are determined by and based on our understanding of your financial situation, investment objectives and risk tolerance. You may impose further reasonable restrictions and guidelines on your Account, but these will affect the composition and performance of your portfolio. The mutual funds recommended under the Portfolio Solutions Program may include mutual fund portfolios advised by investment management affiliates of PNC Wealth Management, which receives compensation for their investment advisory and other services. The services provided by our affiliates and the fees they collect for these services vary and generally are disclosed in each Fund’s prospectus. These fees are paid directly by the Fund and affect the total return of a shareholder’s investment. We will not treat those entities and Funds any differently from investment managers and Funds that are not affiliated with PNC Wealth Management. Mutual funds recommended under the Program also include mutual funds sub-advised by affiliates of PNC Wealth Management, which receive revenue for their sub-advisory services. Sub-advisory fees received by our affiliates are disclosed in each Fund’s prospectus. These fees are paid directly by the Fund and affect the total return of a shareholder’s investment. We will not treat those entities and Funds any differently from investment managers and Funds that are not affiliated with PNC Wealth Management. PNC Wealth Management and Other Service Providers to the Program PNC Wealth Management was formed in 2003, and is a direct, wholly owned subsidiary of PNC Bank. PNC Bank is a wholly-owned subsidiary of The PNC Financial Services Group, Inc., a financial holding company. Page 19 of 25 Portfolio Solutions Program October 17, 2025  PNC Wealth Management does not receive performance-based fees calculated as a share of capital gains on, or capital appreciation of, the funds or any portion of the funds or other investments in a client’s Account. National Financial provides trading, custody and operational services for the Portfolio Solutions Program. National Financial carries client Accounts, is the custodian for the investments in your Account, reports all the trades in your Account and effects many such trades. National Financial will provide you with trade confirmations, monthly statements, and income tax reporting. PNC Wealth Management has also engaged a service provider to perform certain support services in connection with the Program. This service provider is responsible for calculating and preparing quarterly performance reports for client accounts. The grandfathered annuity contract available in Portfolio Solutions are offered through the issuing insurance company. Details of the services provided are referenced in the “Annuity and Structured Products” section above. Risks of Investing in the Portfolio Solutions Program Investing in securities, including the investments offered through the Program, involves risk of loss that you should be prepared to bear. There is no guarantee that the elements of the Program, including the asset allocation models, selection of individual investments or research recommendations will protect against such loss. Other risks include:  Market Risk. Market risk is the risk that the price of securities will fall over short or extended periods of time. Historically, the prices of equity securities have moved in cycles and the value of an Account’s investments will fluctuate from day to day. When individual companies are negatively impacted by industry or economic trends or report poor operating results, the price of securities issued by those companies will typically decline in response. These factors contribute to price volatility.  Allocation Risk. A client Account is subject to the risk that asset allocation decisions will not anticipate market trends correctly. For example, weighting an Account too heavily in equities during a stock market decline may cause a loss of value. Conversely, investing too heavily in fixed income securities during a period of stock market appreciation may result in lower total returns.  Credit Risk. The value of debt securities is affected by the ability of issuers to make principal and interest payments. If an issuer cannot meet its payment obligations or if its credit rating is lowered, the value of its debt securities will typically fall.  Interest Rate Risk. The value of fixed-income investments will typically decline because of an increase in market interest rates. In addition, in certain low-yield interest rate environments, some short-term investments may produce negative yield, after accounting for fees, inflation and other expenses.  Liquidity Risk. The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in unusually wide bid-ask spreads or large price movements (especially to the downside)  Stock-Specific (Unsystematic) Risk. Unsystematic risk is unique to a specific company or industry. Also known as “nonsystematic risk,” “specific risk,” “diversifiable risk” or “residual risk,” in the context of an investment portfolio, unsystematic risk can be reduced through diversification. The Program is intended to be a long-term investment program and does not support market-timing or Page 20 of 25 Portfolio Solutions Program October 17, 2025  frequent trading. You will be limited to one model change per calendar quarter, except as warranted by changes to your financial situation as agreed by you and your Financial Advisor. Frequent or excessive trading in Portfolio Solutions accounts are grounds for account termination, with 30 days’ written notice, by PNC Wealth Management, even if the rules above are not violated. The determination of frequent and/or excessive trading is solely at the discretion of PNC Wealth Management. Trading Practices PNC Wealth Management is an introducing broker-dealer, clearing transactions related to the Program Accounts through National Financial. PNC Wealth Management has a best execution committee (“BEC”) that meets regularly to rigorously review data for equity orders executed by National Financial including those orders that are sent by the Investment Delegate. Such data includes, among other things, speed of execution and price improvement provided by the execution venues selected by National Financial. PNC Wealth Management does not receive any payment for order flow from the execution venues. The BEC also reviews data for fixed income trades executed through trading systems used by PNC Wealth Management to ensure that the net prices obtained are reasonable under the circumstances. Proxy Voting You will retain proxy-voting authority over securities held in your Accounts. Neither PNC Wealth Management nor your Financial Advisor take any action or give advice regarding the voting of proxies to the issuers of securities on the assets in your Program Account. You will retain proxy-voting authority and are responsible for voting proxies over securities held in your Accounts. Our custodian, National Financial, will forward annual reports, shareholder and proxy information to you received by National Financial on the applicable assets in your Program Account. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS This item is not applicable to the Portfolio Solutions Program because portfolio managers are not used in administration of the Program. Your Financial Advisor will recommend an allocation of equity securities, fixed income securities, certain options strategies, mutual funds, exchange traded funds, unit investment trusts, Annuities, and/or Structured Products (Market-Linked CDs or Buffered/Structured Notes) in an effort to meet your investment objectives and financial goals. You retain full discretion over the Account. CLIENT CONTACT WITH PORTFOLIO MANAGERS Your PNC Wealth Management Financial Advisor will act as the sole investment advisor to your account. He or she will be solely responsible for recommending individual securities to you. As such, your account will not be managed by a separate portfolio manager. You may contact your Financial Advisor during normal business hours to discuss your account or to notify him or her of any changes to your financial profile or investment objectives. ADDITIONAL INFORMATION Disciplinary Information  On April 11, 2016, PNC Wealth Management entered into a settlement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that it failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales and failed to apply such waivers to mutual fund purchases by certain retirement plan customers that were eligible to purchase Class A shares in certain mutual funds without a front-end sales charge. The findings also stated that PNC Wealth Management failed to maintain adequate written policies and procedures or to provide adequate training to assist financial advisors in determining when sales Page 21 of 25 Portfolio Solutions Program October 17, 2025  charge waivers were available for retirement plan customers. PNC Wealth Management was not required to pay a fine, but consented to be censured and to pay restitution to eligible customers who did not receive sales charge waivers for fund purchases since July 1, 2009.  On April 6, 2018, PNC Wealth Management entered into a settlement (“Order”) with the Securities and Exchange Commission (“SEC”). Without admitting or denying the findings, PNC Wealth Management consented to the findings that, as a result of the conduct described below, PNCWM willfully violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)-7 thereunder. The Order finds that the violations resulted from the following conduct of PNCWM: (1) PNCWM, without adequate disclosure of the associated conflicts of interest, invested advisory clients in mutual fund share classes with 12b-1 fees instead of available lower-cost share classes of the same funds without 12b-1 fees; (2) PNCWM did not disclose a conflict of interest regarding marketing support payments paid on such mutual fund share classes that charged 12b1 fees; (3) PNCWM improperly charged advisory fees to client accounts where the investment adviser representative departed the firm (“Orphaned Accounts”) and where PNCWM failed to assign a new investment adviser representative within thirty days; and (4) PNCWM failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices and treatment of Orphaned Accounts. The Order requires PNCWM to cease and desist from committing or causing any violations and any future violations of Advisers Act Sections 206(2), 206(4), and 207 and Rule 206(4)-7; censures PNCWM; and requires PNCWM to pay disgorgement of $5,234,856, and prejudgment interest of $612,344, to compensate advisory clients who were affected by certain conduct detailed in the Order. PNCWM will pay, in addition to the disgorgement and prejudgment interest described above, disgorgement of $497,144 in marketing support fees and prejudgment interest thereon of $63,426 to the SEC for the transfer to the general fund of the United States Treasury. Lastly, PNCWM will pay a civil monetary penalty of $900,000.  On April 22, 2024, PNC Wealth Management signed a Final Order with the State of North Carolina Department of the Secretary of State Securities Division. Without admitting or denying the findings, PNCWM was ordered to pay civil penalties in the amount of $7,500 and costs of investigation in the amount of $1,000 resulting from the following conduct: (1) PNCWM and one investment adviser representative (“IAR”) failed to comply with North Carolina’s IAR registration requirements in violation of N.C.G.S. §78C-16(a1) in which the IAR transacted advisory business in North Carolina from on or about December 2021 through on or about October 2023 without being IAR registered; (2) PNCWM was in violation of N.C.G.S. §78C-18(b) and 18 NCAC 06A .1801(a)(18) by employing the IAR in North Carolina without the appropriate registration and by not furnishing this information to the IAR’s PNCWM advisory clients; and (3) PNCWM failed to supervise the IAR’s acts, practices and conduct to ensure adherence with North Carolina’s IAR registration provisions in violation of N.C.G.S. §78C- 19(a)(2)(j) and 18 NCAC 06A .1808.  On April 24, 2024, PNC Wealth Management signed a Consent Agreement and Order with the Pennsylvania Department of Banking and Securities. The Department alleged that from on or about December 2018 until December 2023, PNCWM failed to register at least one employee as an investment adviser representative in Pennsylvania in violation of Section 301(c.1)(1)(ii) of the Pennsylvania Securities Act of 1972 (“the 1972 Act”), 70 P.S. § 1-301(c.1)(1)(ii). Without admitting or denying the findings in the Order, PNCWM agreed to pay a monetary fine of $100,000 and to comply Page 22 of 25 Portfolio Solutions Program October 17, 2025  with the relevant provision of the 1972 Act.  On September 3, 2024, PNC Wealth Management signed a Settlement Order with the Commonwealth of Virginia Division of Securities and Retail Franchising. The Division alleged that from on or about February 2019 to June 2024, PNCWM failed to register an investment advisor representative in Virginia in violation of § 13.1-504 C (ii) of the Virginia Securities Act. Without admitting or denying the findings in the Order, PNCWM paid $10,000 in monetary penalties and $1,000 in investigation costs.  On September 18, 2024 PNC Wealth Management entered into an Administrative Consent Agreement and Order with the District of Columbia’s Department of Insurance, Securities and Banking alleging that from on or about August 2012 through February 2024, PNCWM failed to register three investment advisor representatives in D.C. in violation of D.C. Official Code §§ 31-5602(b)(2) and 31-5605.01(4). PNCWM paid $162,500 as a civil penalty and $1,080 in unpaid registration fees.  On June 16, 2025, PNC Wealth Management entered into an agreement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that from at least June 2021, it violated FINRA rules by failing to establish and maintain a reasonably designed supervisory system, including written supervisory procedures, for the surveillance and supervision of rates of deferred variable annuity exchanges. PNC Wealth Management was required to pay a $200,000 fine and to implement a supervisory system and written supervisory procedures reasonably designed to achieve compliance in surveilling registered representatives’ rates of deferred variable annuity exchanges consistent with applicable securities laws and regulations, and with applicable FINRA rules. Other Financial Industry Activities and Affiliations PNC Wealth Management’ principal business is that of a full-service, general securities broker-dealer and investment adviser, registered with the SEC and as a member of FINRA. Our primary retail brokerage activities include the sale of corporate equities, corporate debt, municipal securities and funds, mutual funds, ETFs and annuities. PNC Wealth Management is part of a broad financial services organization and is therefore affiliated with other entities engaged in a variety of financial services businesses. In some cases, the firm has business arrangements with its affiliates that are material to its advisory business or to its clients. These are described in more detail below and, in some cases, cause PNC Wealth Management’ or a related person’s interests to diverge from the best interests of our clients. PNC Wealth Management is affiliated with the following financial services entities through its parent, The PNC Financial Services Group, Inc.:  PNC Bank, National Association is a wholly owned subsidiary of The PNC Financial Services Group, Inc., and is a full-service bank engaged in traditional lending, cash and/or treasury management and other services.  PNC Capital Advisors, LLC is a wholly owned subsidiary of PNC Bank and provides discretionary fixed income investment advisory services to institutional accounts.  PNC Capital Markets LLC is an indirect, wholly owned subsidiary of The PNC Financial Services Group, Inc. and offers loan syndication, public finance underwriting and advisory services, securities underwriting and trading, private placements, asset securitizations and merger and acquisition advisory Page 23 of 25 Portfolio Solutions Program October 17, 2025  services.  PNC Insurance Services, LLC is a wholly owned subsidiary of PNC Wealth Management and a licensed insurance agency. It provides a variety of insurance products and advice. Selected conflicts of interest that exist between PNC Wealth Management and its affiliates are discussed below. Although PNC Wealth Management is committed to acting in the best interests of our clients, in some situations there are conflicts of interest between the firm’s interests and a client’s interests, or there are conflicts in the interests of multiple clients. Many of these conflicts of interest are inherent in operating an investment advisory business. For example, PNC Wealth Management may have an incentive to resolve a matter in favor of clients that are affiliates of the firm over clients that are not affiliates of the firm. PNC Wealth Management has adopted policies and procedures that it believes are reasonably designed to help mitigate these conflicts of interest. Affiliates of PNC Wealth Management provide advice to their clients with respect to investment strategies that are similar to or the same as strategies offered by PNC Wealth Management. Those advisory affiliates may purchase on behalf of their clients the same securities that PNC Wealth Management may purchase for our clients. As a result, the interests of PNC Wealth Management’ clients may conflict with the interests of the clients of these affiliated advisers. For example, if an investment adviser affiliate implements a portfolio management decision for its client ahead of, or contemporaneously with, a decision PNC Wealth Management makes for its client(s), the market impact of the decision made by the firm’s advisory affiliate could result in one or more of PNC Wealth Management’ clients receiving less favorable trading results than they otherwise would. PNC Wealth Management’ trade allocation and trade aggregation procedures do not typically apply to portfolio management decisions and trading executed by investment advisory affiliates for their clients that are not clients of PNC Wealth Management. Affiliate Transactions PNC Wealth Management or its affiliates may from time to time recommend investments in transactions in which PNC Wealth Management or its affiliates act as financial advisor or a broker-dealer, or in securities which are underwritten, issued, packaged or serviced by an affiliate. Moreover, PNC Wealth Management may act as a broker in executing your purchase or sale for your account of a debt security from or to PNC Capital Markets, a brokerage affiliate. PNC Capital Markets receive compensation as a result of these transactions, if these transactions were to occur. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PNC Wealth Management has adopted a Code of Ethics, which consists of certain general principles, including the following:  Advisory personnel must place client interests before their own  The personal securities transactions of our personnel must avoid even the appearance of a conflict with client interests  Our personnel must avoid actions or activities that allow, or appear to allow, them to profit or benefit from their position with respect to clients, or that would otherwise bring into question their independence or judgment Page 24 of 25 Portfolio Solutions Program October 17, 2025   From time to time, PNC Wealth Management personnel may accept training, business entertainment or gifts of de minimis value from product vendors. PNC Wealth Management has adopted policies and procedures reasonably designed to ensure any such activity does not impact our personnel’s ability to act in the best interests of our clients  In addition, the Code of Ethics requires our employees to report their personal securities transactions and holdings. A copy of our Code of Ethics will be provided to any client or prospective client upon request. Our employees are also subject to the PNC Employee Conduct Policies, which cover matters including compliance with law, conflicts of interest, insider trading, outside activities and safeguarding confidential information. Client Reports As part of the Program, we will provide periodic reports to assist you in monitoring and assessing the performance of your Account. These reports will contain information regarding trades, investment return, and selected benchmark comparisons. These reports may also contain letters, notices and other important information regarding the Account during the period. Client Referrals and Other Compensation Your Financial Advisor may refer you to PNC Bank or other PNC Wealth Management affiliates for additional products or services and will generally receive compensation for such referrals. A portion of the fees charged for the Portfolio Solutions Program services described in this Brochure are paid to your Financial Advisor in connection with the introduction of Accounts as well as for providing client-related services within the Programs. This compensation may be more or less than a Financial Advisor would receive if you paid separately for investment advice, brokerage and/or other services. Certain employees of PNC Bank’s Wealth Management and or Private Client Group receive compensation in connection with referrals to PNC Wealth Management. PNC Wealth Management has related persons who are investment advisers who act as general partners in partnerships in which our clients may be solicited. PNC Wealth Management would not have knowledge of such solicitations should they occur, and consequently, would not be a participant in them, nor would we receive any compensation for them. Financial Information In certain circumstances, PNC Wealth Management would be required to provide you with financial information or disclosures about our financial condition. Currently, no such circumstances exist for PNC Wealth Management. PNC Wealth Management has no financial commitments that impair our ability to meet our contractual and fiduciary commitments to our clients and has never been the subject of a bankruptcy proceeding. Page 25 of 25 Portfolio Solutions Program October 17, 2025 

Form ADV Part 2A Appendix 1 801‐66195 Disclosure Document for the Portfolio Solutions Strategist Program An Investment Advisory Service of PNC Wealth Management LLC 300 Fifth Avenue Pittsburgh, Pennsylvania 15222 (800) 622‐7086 www.pnc.com October 17, 2025 This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of PNC Wealth Management, LLC with respect to the Portfolio Solutions Strategist Program (the “Program”). If you have any questions about the contents of this Brochure, please contact us at (800) 622‐7086. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. PNC Wealth Management LLC, a registered investment adviser and broker‐dealer and member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”), is a wholly owned subsidiary of The PNC Financial Services Group, Inc. Registration does not imply a certain level of skill or training. Additional information about PNC Wealth Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. • NOT FDIC INSURED • NOT INSURED BY ANY FEDERAL GOVERNMENT AGENCY • NOT A DEPOSIT OR OTHER OBLIGATION OF, OR GUARANTEED BY, PNC BANK, N.A. OR ANY OF ITS AFFILIATES • SUBJECT TO INVESTMENT RISKS, INCLUDING POSSIBLE LOSS OF THE PRINCIPAL AMOUNT INVESTED  Material Changes ADV Part 2A dated October 17, 2025 The following change(s) have been made to the PNC Wealth Management Portfolio Solutions Strategist Program Brochure since the last Brochure dated July 16, 2025: On or about October 17, 2025, our firm’s legal and business name will change from PNC Investments LLC to PNC Wealth Management LLC. This change is administrative in nature and does not affect the ownership, management, operation, services, or fees of the firm. All references to PNC Investments LLC within the Brochure will be updated to PNC Wealth Management LLC. No other material changes have been made since our last Form ADV 2A Brochure was filed on July 16, 2025.  Table of Contents About PNC Wealth Management LLC 4 ................................................................................................ SERVICES, FEES AND COMPENSATION ............................................................................................... .................................................................................... ....................................................................................................................... ...................................................................................................................... ...................................................................................................................... ........................................................................................ ..................................................................................................... ............................................................................................................................................. ........................................................................................................................ ......................................................................................................... ........................................................................................ .......................................................................................................... ............................................................................................................................. ............................................................................................................................... .................................................................................................. The Portfolio Solutions Strategist Program Account Statements Account Termination Review of Accounts Securities Transferred into an Account Withdrawals from an Account Taxes Fees and Expenses Calculation of Account Fees Additional Fees for Brokerage Services Deduction of Account Fees Other Expenses Cash Balances Financial Advisor Compensation 4 4 9 9 10 10 11 11 11 15 16 16 17 19 20 ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS ........................................................................ ..................................................................................... ....................................................................................................................... Account Minimums and Types of Clients Collateral Accounts 21 21 21 .................................................................... ........................................................................... .................................... .................................................. .......................................................................................................................... ................................................................................................................................. PORTFOLIO MANAGER SELECTION AND EVALUATION Model and Strategist Selection and Evaluation PNC Wealth Management and Other Service Providers to the Program Risks of Investing in the Portfolio Solutions Strategist Program Trading Practices Proxy Voting 22 23 23 23 24 26 ....................................................... CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS 26 ............................................................................. CLIENT CONTACT WITH PORTFOLIO MANAGERS 26 ............................................................................................................ ............................................................................................................... ...................................................................... .................................................................................................................... ............... ............................................................................................................................... ................................................................................... ................................................................................................................... ADDITIONAL INFORMATION Disciplinary Information Other Financial Industry Activities and Affiliations Affiliate Transactions Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Client Reports Client Referrals and Other Compensation Financial Information 26 26 28 29 29 30 30 30 Page 3 of 30 Portfolio Solutions Strategist Program October 17, 2025  About PNC Wealth Management LLC PNC Wealth Management LLC (“PNC Wealth Management” or the “Firm”) is an investment adviser and also a registered broker‐dealer and member of FINRA and SIPC. The Firm offers retail brokerage and investment advisory services. PNC Wealth Management serves as the sponsor of, and in some cases as a portfolio manager for, wrap fee investment programs. PNC Wealth Management is a wholly owned subsidiary of PNC Bank, National Association (“PNC Bank”) and is a part of The PNC Financial Services Group, Inc. (“PNC”) which is a diversified financial services institution with roots in commercial banking and investment management dating back to the early 1800s. Throughout this document, the terms “client,” “you,” and “yours” are used to refer to the individual(s), institution(s) or organization(s) who contract with us for the services described here. “PNC Wealth Management,” “we,” “our,” “us” and “the firm” refer to PNC Wealth Management LLC, together (as applicable) with our affiliates, including but not limited to, PNC and its agents with respect to any services provided by those agents. Our affiliates include any entity that is controlled by, controls or is under common control with PNC Wealth Management, including but not limited to our parent company, The PNC Financial Services Group, Inc. Each affiliate is a separate legal entity and not responsible for the obligations of any other affiliate. “Account” means each brokerage and/or advisory account you open with us that is subject to the Portfolio Solutions Strategist Program investment management agreement (the “Investment Management Agreement”), including any and all mutual funds, exchange traded funds, money, securities, financial instruments and/or other property you have funded in such accounts. “Business Day” means Monday through Friday, excluding New York Stock Exchange holidays. “Wrap” refers to an Account that charges a quarterly or annual fee based on the average assets under management, where such fee covers administrative, commission, execution and management expenses. SERVICES, FEES AND COMPENSATION Other advisory services are This Brochure is being provided pursuant to Section 204 of the Investment Advisers Act of 1940, as amended, and deals solely with our Portfolio Solutions Strategist Program. In addition to the Program, PNC Wealth Management offers a variety of investment advisory services. These include the Capital Directions Program, the Capital Directions Annuities Program, the Portfolio Solutions Program, the PNC Directions Program, and the Guided Solutions Program. More information about these programs and services is contained in the applicable PNC Wealth Management brochure and is available upon request from PNC Wealth Management or through the SEC’s website at https://adviserinfo.sec.gov/. For more information about these or other services that are available from PNC Wealth Management, please contact your Financial Advisor. 1 offered by our affiliates. The Portfolio Solutions Strategist Program The Portfolio Solutions Strategist Program is a discretionary investment advisory platform that provides clients an integrated set of model investment strategies through a single advisory account. We will help you We use the term “Financial Advisor” to refer to PNC Wealth Management’ branch‐based and wealth Financial Page 4 of 30 1 Advisors, as well as Advisor Direct Financial Advisors and Investment Services Consultants. Portfolio Solutions Strategist Program October 17, 2025  formulate an investment strategy based on many factors including but not limited to your investment objectives, risk and return considerations and tax status. Your strategy will be implemented through the use of one or more approved investment models (“Investment Model or Investment Models”) provided by professional asset managers (“Strategists”) available through the Program. In constructing the Investment Models, the Strategists may elect to utilize mutual funds and/or exchange traded funds (collectively “Funds”) as well as individual equity or fixed income securities. PNC Wealth Management, as the investment adviser to the program, will exercise its discretion to invest your Account in the Investment Model(s) you have selected. PNC Wealth Management has contracted with Envestnet Asset Management, Inc., an unaffiliated investment adviser (the “Investment Delegate”) to perform certain duties for the program. PNC Wealth Management will select for the Program various Investment Models offered by the Strategists from a list of Investment Models made available to PNC Wealth Management by the Investment Delegate. In managing the Investment Models, Strategists will use various investment strategies such as tax aware investing, specific investment outcomes, income generation and Responsible Investing, among others. The Investment Delegate will implement Strategists’ Investment Models (excluding Strategist Traded Models, as described below) and will facilitate execution of trades in your Account as instructed by PNC Wealth Management. Strategist Traded Models are fixed income Investment Models, and trades for those Investment Models are implemented by the Strategist rather than by PNC Wealth Management or the Investment Delegate. Utilizing a proprietary methodology, the Investment Delegate will evaluate the risk characteristics of each Investment Model and assign each Investment Model a risk score (the “Risk Score”). The Risk Score is generally reflective of each Investment Model’s maximum equity exposure and is evaluated annually and adjusted as needed. PNC Wealth Management reviews each Investment Model’s Risk Score and may adjust a Risk Score based on its own review of the Investment Model. Before you open an Account in the Portfolio Solutions Strategist Program, you should carefully review our Client Relationship Summary (“Form CRS”) and consider whether an advisory relationship is right for your situation and circumstances. You may discuss any questions you have regarding our Form CRS or whether an advisory account is right for you with your Financial Advisor. Some things you may wish to consider are your preference for a fee‐ based versus a commission based relationship, your preference for on‐going support, costs and advice from your Financial Advisor, and how much trading activity you expect to take place in your account. You should know that your Financial Advisor benefits when you open a Portfolio Solutions Strategist account, as described in more detail in the Financial Advisor Compensation section of this Brochure, and has a conflict of interest when recommending an advisory account to you. Once you decide that the Program is right for you, your Financial Advisor will help you complete an investor questionnaire (“Client Profile”) that provides us with an understanding of your financial situation, investment objectives, risk tolerance and investment time horizon. Based on the information collected in the Client Profile and other information you share with your Financial Advisor, your Financial Advisor will assist you to select from a variety of approved Investment Models offered by Strategists, available through the Program. If one Investment Model is selected, the Risk Score of the Investment Model must match your risk profile as determined by the Client Profile. If more than one Investment Model is combined to create an allocation model (“Allocation Model”), the weighted average Risk Score of the selected Investment Models must match your risk profile, as determined by the Client Profile. We will present our recommendation to you in the form of a proposal (the “Proposal”) for your acceptance and approval. From time to time, your Financial Advisor may recommend changes to the Investment Model(s) you have selected. You may also request changes to your selected Investment Model(s), subject to certain restrictions described in this brochure. We may also, at our discretion, change the account allocation to any Investment Page 5 of 30 Portfolio Solutions Strategist Program October 17, 2025  Model available in the Program. Finally, PNC Wealth Management will periodically exercise its discretion to adjust the risk scoring associated with an Investment Model or remove Investment Models or Strategists from our approved list. This will result in PNC Wealth Management using its investment discretion to change the Investment Models utilized in your account. In all of these circumstances, PNC Wealth Management will update your account and Investment Models you have selected accordingly and the Investment Delegate will execute transactions to align your account to these changes. Note that you will not be sent a new Proposal in these circumstances, unless requested through your Financial Advisor. PNC Wealth Management retains the authority to limit the availability of any Investment Model offered by a Strategist, or Fund, and/or to terminate or replace any Investment Model when circumstances are such that PNC Wealth Management believes a change is in your best interest. If an Investment Model is terminated or otherwise removed from the Program, PNC Wealth Management will use commercially reasonable efforts to select a replacement Investment Model that is substantively similar to the Investment Model that has been removed or, alternatively, assume management of the portion of your Account allocated to the removed Investment Manager in a manner that PNCWM or its designee believes is consistent with your Client Profile. In either case, we will sell your holdings in the terminated Investment Model and purchase shares in the substituted Investment Model or as we, or our designee, have determined is consistent with your Client Profile, without any prior notice to you. Certain of these changes will result in an increase/decrease to the fees discussed further herein (see Services, Fees and Compensation – Fees and Expenses). For example, if PNC Wealth Management removes an Investment Model from the program, the replacement Investment Model may be more expensive than the replaced Investment Model. Although you will not be sent an updated Proposal in some circumstances described above, any changes to the Account’s fees will be reflected on future Account statements summarizing the activity in your Account. Before you may establish a Portfolio Solutions Strategist Account, you must establish a brokerage account with PNC Wealth Management and agree to the terms and conditions of the PNC Wealth Management Brokerage Account Customer Agreement. By accepting and signing the Investment Management Agreement, you grant discretion over your Account to PNC Wealth Management and you authorize us to delegate our discretion to the Investment Delegate in order for the Investment Delegate to invest and reinvest the assets in your Account in Investment Models. The scope of any investment advisory relationship we have with you is defined in the Investment Management Agreement. When you are enrolled in the Program, we act as your introducing broker and we will also act as your investment advisor, but only for your Program Account and not for any other assets or accounts, unless otherwise separately agreed to by us in writing. As discussed in more detail below, we earn certain fees and other revenue in connection to our capacity as introducing broker to your Account. This is a conflict of interest because we would not earn such fees or revenue if we did not serve as your introducing broker. Our Portfolio Solutions Strategist Program advisory relationship with you begins when we enter into an Investment Management Agreement with you, which occurs at the later of the date of acceptance of the signed Investment Management Agreement by PNC Wealth Management or the date on which you have contributed the required minimum level of assets to your Account. Preliminary discussions or recommendations before we enter into an Investment Management Agreement with you are not intended as investment advice under the Investment Advisers Act and should not be relied on as such. The Portfolio Solutions Strategist Program is designed for investors who wish to give PNC Wealth Management discretion with respect to the assets in their Account and to have those assets invested by the Investment Delegate to according to Investment Model(s) selected. Once you are approved for the Program, you will not Page 6 of 30 Portfolio Solutions Strategist Program October 17, 2025  have the ability to directly buy or sell individual securities in your Account, or to direct your Financial Advisor, the Investment Delegate or any Strategist to buy or sell securities in your Portfolio Solutions Strategist Account. You will not be able to obtain a margin loan using the securities in your Account as collateral. You will retain, however, the ability to place reasonable restrictions on the securities that may be purchased for or held in your Account, subject to the review and approval of PNC Wealth Management. In general, you may impose individual security restrictions, including mutual funds, ETFs and specific equity securities or industry restrictions. You may also have the ability to restrict certain bond characteristics, such as years to maturity, credit quality or duration. PNC Wealth Management will determine which specific securities fall within an industry restriction and will implement any industry restrictions in a manner it determines in its sole discretion from time to time. If an individual security restriction is reasonable, PNC Wealth Management, the Investment Delegate and/or the Strategist will generally allocate assets that would have been invested in a restricted security to cash or one or more substitute securities, which may include ETFs, on a pro rata basis. Any restrictions you impose on individual securities are subject to the approval of PNC Wealth Management and the Investment Delegate and will not apply to the underlying holdings of mutual funds or ETFs. PNC Wealth Management will be responsible for monitoring and maintaining the Investment Models available through the Portfolio Solutions Strategist Program. PNC Wealth Management has delegated its discretion to buy and sell securities for your Account in accordance with the selected Investment Model(s) to the Investment Delegate. Depending on the Investment Model(s) chosen, Investment Delegate will make investments in, without limitation, equity securities, fixed income securities, cash (and/or short‐term investments including, but not limited to, money market funds), Funds, and other financial instruments. Investment Delegate will also be responsible for rebalancing your Account to keep it within the acceptable allocation ranges for the specified Investment Model. PNC Wealth Management may, at its discretion, remove an Investment Model from the schedule of available Investment Models and replace it with another Investment Model, without any prior notice to you. If you elect to, you may enroll two or more of your related Program Accounts in a multi‐account management relationship (“MAM”). When you enroll two or more of your Program Accounts in MAM (collectively “MAM Accounts”) PNC Wealth Management will apply a single Allocation Model across all MAM Accounts. All MAM Accounts will be managed pursuant to a single household‐level Allocation Model as shown on your Proposal. Only accounts that you would like managed pursuant to the Allocation Model should be included in the MAM. If you have other managed accounts at PNC Wealth Management that have a different time horizon or risk tolerance, they should not be included in MAM. You will receive a single Quarterly Report for all associated MAM Accounts. You should be aware that deposits or withdrawals made into a MAM Account will in most cases cause substantial trading in both that account as well as other MAM Accounts in order to keep them allocated pursuant to the Allocation Model in the aggregate. Similarly, adding or removing a Program Account from MAM will in most cases cause substantial trading in all MAM Accounts. Such trading may also result in you incurring redemption fees from certain mutual funds and will result in tax consequences in taxable Program Accounts. MAM is designed to allow flexibility with respect to the placement of assets in different account types for tax efficiency and to use a tax‐aware strategy when making trades in MAM Accounts. If both qualified and non‐ qualified accounts are included in MAM, MAM will utilize an asset location preference where Investment Options are allocated to non‐qualified or qualified accounts based on their relative tax inefficiency (calculated based on the pre‐tax and post‐tax returns that are reported by Fund companies). Some assets tend to be more tax efficient, such as equities and equity‐based Funds, and generally represent greater investment risk. Taxable MAM Accounts generally carry a disproportionate amount of the investment risk in a MAM relationship. You should only combine non‐qualified and qualified accounts in a single MAM relationship if you understand this and are comfortable with this allocation between accounts. Page 7 of 30 Portfolio Solutions Strategist Program October 17, 2025  You may choose to discontinue MAM with respect to one or more MAM Accounts. In addition, PNCWM may in its discretion elect to discontinue offering MAM. In such event or if any MAM Account’s IMA is terminated for any reason, unless you provide different instructions ahead of the termination, each remaining MAM Account will be rebalanced to individually meet the target Allocation Model. This may cause significant tax impacts to any non‐qualified account. You are urged to discuss MAM with your tax professional. You may select an optional tax‐overlay service for your non‐qualified Program Account (“Tax‐Overlay Service”). When you select the Tax‐Overlay Service, your Financial Advisor will work with you to establish short and long‐ term tax budgets and the Investment Delegate will attempt to manage your Program Account in such a way as to prevent realized short and long‐term taxable gains from exceeding agreed upon budgets. The Investment Delegate will do this by timing the purchase and sales of equity securities in such a way as to attempt to minimize the tax impacts to your Program Account. The Investment Delegate will also actively seek opportunities to realize taxable losses in your non‐qualified Program Account by selling certain securities that have depreciated in value. These realized losses can be utilized to offset realized gains in your Program Account or other taxable accounts. Note that the Investment Delegate will actively seek to realize losses only in equity positions held in Investment Models and will not actively realize losses in Funds held in your Program Account. Additionally, the Tax‐Overlay Service will cause the holdings in your Program Account to deviate from holdings of other accounts utilizing the same Investment Model. Finally, you should be aware that no strategy, including the Tax‐Overlay Service, will prevent the realization of taxable gains from your investments. The Tax‐Overlay Service seeks to minimize the current impact of taxes on your Program Account but will not eliminate the eventual realization of imbedded gains from your Program Account. If you elect to terminate the Tax‐Overlay Service for your Program Account, you need to be aware that any unrealized embedded taxable gains will likely be realized as a result. You should carefully review the unrealized embedded taxable gains in your Program Account before electing to terminate the Tax‐Overlay Service. Withdrawals from your Program Account will likely force the Investment Delegate to liquidate securities and exceed the short and/or long‐term tax budgets. When you select the Tax‐Overlay Service, PNC Wealth Management will review and must approve your Program Account for the service. PNC Wealth Management, your Financial Advisor and the Investment Delegate do not provide tax advice. If you are considering the Tax‐Overlay Service, you should review your tax situation with your independent tax adviser to fully evaluate how you may benefit from it. The annual fee for the Tax‐Overlay Service is 0.15% (the “Tax Overlay Fee”) which is calculated and charged similarly to the Program Fee, described in detail below. In certain circumstances, the Tax Overlay Fee may exceed the tax benefit, in any given tax year. You should be aware, although, the Investment Delegate will actively manage taxes only in the equity positions in your Program Account, the Tax‐Overlay Service fee will apply to the full account balance, including assets held in cash and other positions that are not being actively managed through the Tax‐Overlay Service. You may also select one of several responsible investing models (the “RI Models”) made available by Strategists and approved by PNCWM (collectively, the “RI Strategists”). In the RI Models, the applicable RI Strategist seeks to incorporate various responsible investing characteristics as part of the investment selection process. Responsible investing can be defined very differently by individuals, PNCWM utilizes data from Morningstar to assist in assessing the responsible investing characteristics of the RI Models. PNCWM will seek to include RI Models that are intentionally managed using environmental, social, or governance (“ESG”) screening or other values‐based criteria or based on their scores for ESG Risk or Controversy Level, as measured by Sustainalytics, a Morningstar Company. In general, RI Models exhibiting the following responsible investing characteristics are favored: clear incorporation of ESG criteria in their security analysis and investment decision‐making; seek to Page 8 of 30 Portfolio Solutions Strategist Program October 17, 2025  have an impact on thematic issues; utilize negative screening to avoid investments that violate norms‐based, faith‐based, or other values‐based criteria; practice a form of active ownership through which they engage with corporate management on ESG issues; have actively supported ESG arrangements through their proxy voting; holding companies with lower risk related to ESG issues or misconduct, as scored by Sustainalytics. Note that funds may exhibit any one or more of the preceding characteristics. Responsible investing priorities are a matter of personal preferences, and there is no assurance that criteria utilized by a particular RI Strategist or PNCWM will match your personal responsible investing priorities. You should carefully review the prospectus, Form ADV, or other offering documents for the RI Models and evaluate if the applicable RI Strategists’ ESG or other values‐based criteria and strategy match your own priorities. Additionally, you should know that, while RI Strategists may apply responsible investing or ESG criteria to their proxy voting decision making process, where PNCWM votes proxies on your behalf, discussed further below, PNCWM, through its delegate Envestnet, will apply our standard proxy voting policies and will not apply any responsible investing or ESG related criteria to proxies we vote on your behalf in the RI Models. PNCWM expects that the RI Models will typically include one or more Funds without a specific responsible investment mandate. RI Strategists may include Funds without a specific responsible investing mandate when they are unable to identify suitable responsible investing Funds to fulfil a particular portfolio allocation. PNCWM does not set a minimum percentage allocation to Funds with a responsible investment mandate for the RI Models. Finally, all investment strategies, including responsible investing related strategies, carry the risk of loss, and there is no assurance that a responsible investing strategy can guarantee a profit or protect against loss. In addition, there is no assurance that any responsible investing related strategy, including the RI Models, will provide any investment benefit relative to similarly constructed non‐responsible investing related strategies. In addition to RI Models, PNCWM offers values‐based investments, with categories such as gender, minority, religion, sustainability or environment, which seek to reflect a customer’s values by avoiding or increasing exposure to specific companies, sectors or practices. Certain religious values‐based investment managers invest in companies that generate income and returns inconsistent with a particular religion’s philosophies. In cases where this occurs, it is the customer’s responsibility to determine the amount, if any, of non‐compliant generated income and/or gains. For more information about how to address these types of non‐compliant income or returns, please refer to the religious values‐based investment’s prospectus or disclosure agreement. Account Statements You will receive a monthly statement following any month in which there is investment activity in your Account, confirming all transactions in your Account, including additions, disbursements, purchases, sales, and advisory fees paid to PNC Wealth Management or fees paid to Strategists. For periods in which there is no investment activity in your Account, statements will be provided quarterly. You will also receive a quarterly performance report that tracks the performance of your portfolios against relevant benchmarks. You will be reminded quarterly to contact your Financial Advisor if you should have any questions, or if there have been material changes in your financial goals or needs that would affect your investment strategy. Account Termination Either party may terminate the Investment Management Agreement on 30 days’ written notice to the other party. You are also entitled to terminate such agreement within five (5) business days of your execution of it without incurring a Program Fee, defined below; you may, however, be subject to certain other fees incurred with respect to the Account for the relevant period. Upon the termination of the Investment Management Agreement, PNCWM will be under no obligation to provide advice on any holdings in your Account. Any transactions executed by you after the termination of the Investment Management Agreement will be subject to Page 9 of 30 Portfolio Solutions Strategist Program October 17, 2025  fees and commissions described in the PNC Wealth Management Overview of Products and Services (the “Overview of Products and Services”). You may obtain a copy of our current Overview of Products and Services, at any time, by contacting your Financial Advisor, by contacting us at (800) 622‐7086 or online at www.pnc.com/investments‐relationship‐summary. In addition, upon learning of the death of any account owner, PNCWM will immediately terminate the Investment Management Agreement. You should be aware that any transactions executed by your heirs or beneficiaries after your death will be subject to fees and commissions described in the Overview of Products and Services, unless waived by us in our sole discretion. Please see the agreement governing your Portfolio Solutions Strategist Program Account for more information. Review of Accounts When you open a Portfolio Solutions Strategist Program Account, we review and must approve your investment objectives and strategy for consistency with Portfolio Solutions Strategist Program guidelines. Thereafter, we will continuously monitor the Account, including its performance, the appropriateness of the individual securities in it, and any investment restrictions that might apply. We will attempt to contact you at least annually, including by mail or email (if you have authorized us to send you electronic communications), to request that you review your Account and inform us of any changes to your financial profile or investment objectives. You should inform your Financial Advisor of any changes to your financial profile or investment objectives as they occur. Your Financial Advisor will communicate any changes about you to PNC Wealth Management. You will have very limited, if any, direct contact with the Strategist selected for your Account. Therefore, it is very important that you maintain contact and communication with your Financial Advisor. You should direct any inquiries about your Account, allocations to Investment Models, or any Strategists to your Financial Advisor or by calling us at 800‐622‐7086. Finally, your Financial Advisor will be reasonably available to you for consultation about the Account. We encourage you to please contact your Financial Advisor if you have any questions. Securities Transferred into an Account You should be aware that if you transfer securities into a Portfolio Solutions Strategist Account, any transferred securities that are not part of the recommended investments for your Account will be liquidated upon or shortly after transfer. Typically, this means that we will liquidate all of the securities you transfer into your account prior to investing your account in the recommended investments. If your account is not tax‐exempt, you will incur tax consequences as well as a result of these transactions. You should consult with your tax adviser to review these consequences. Additionally, if you liquidate securities prior to transferring your account to PNC Wealth Management or liquidate your securities prior to establishing your Portfolio Solutions Strategist account, you will likely incur transaction costs for those transactions. PNC Wealth Management will not reimburse you for transactions executed at another firm. Please note that if you transfer illiquid securities into a Portfolio Solutions Strategist Account, it will delay management of that Account until such securities are transferred out or otherwise removed. You may, at your election, chose an optional Dollar Cost Averaging (“DCA”) feature when adding funds to your Program Account. With the DCA feature, you have the ability to deploy free cash to your Allocation Model over a defined period and in pre‐determined amounts. The DCA feature can enable clients to slowly invest excess cash over time, rather than make one lump‐sum investment. You have no obligation to complete scheduled DCA transactions and may terminate the DCA feature at any time, by providing notice to us, at least 5 business days prior to the next scheduled DCA transaction. You should know that if sufficient cash is not available in your Account at the time of a scheduled DCA transaction, that transaction, and all future scheduled DCA transactions will be canceled. You should also be aware that cash pending investment under an optional DCA plan will be treated as unallocated cash and Page 10 of 30 Portfolio Solutions Strategist Program October 17, 2025  swept to a deposit account at our affiliate bank, as described below. The parameters of DCA requests are subject to our approval. Withdrawals from an Account You should also be aware that if you request a withdrawal from a Portfolio Solutions Strategist Account, PNC Wealth Management or the Investment Delegate will need to liquidate a portion of the Account to cover the requested withdrawal amount if the cash in your Account is insufficient to accommodate the requested withdrawal. If your account is taxable, you will incur tax consequences as a result. These transactions are subject to short‐term trading policies of Funds held in your account. Liquidation requests are processed according to our standard procedures and your liquidation request may not be completed on the day it was submitted. This is more likely if your request is submitted late in the day or during periods of severe market volatility. Cash is available for distribution three to five business days after the initial request is made, however, you should also be aware that liquidation transactions are at the discretion of the Investment Delegate and could exceed this timeframe. Taxes You need to be aware that the Program operates in a manner that will likely cause non‐retirement Portfolio Solutions Strategist accounts to more frequently experience taxable gains and losses than a brokerage account holding individual securities for the same amount of time. When we, at our discretion, or the Investment Delegate sell securities to rebalance your asset allocation or to adjust your account to changes in the Investment Model, the transaction will likely create a capital gain or loss for you. Additionally, any securities that you sell in order to raise cash to open and or be deposited into your account will likely create a capital gain or loss. These capital gains and losses are in addition to dividends and capital gains paid by the securities in the account. You should consider this and discuss the potential tax implications of opening and maintaining a Portfolio Solutions Strategist account with your tax adviser. Fees and Expenses You will pay both a program fee (the “Program Fee”) and a separate strategist fee (the “Strategist Fee”) for the services provided under the Portfolio Solutions Strategist Program. The Program Fee and Strategist Fee will be combined and reflected on your account statement as the management fees (the “Management Fee”). You should be aware that your account is subject to the Management Fee whether you make or lose money on the investments. Each fee is calculated as a percentage of assets under management and will vary depending on the services provided to you. Generally, a commission or service charge per trade will be charged to your brokerage account when liquidating assets to establish the Portfolio Solutions Strategist Account; you should discuss your options for funding your account with your Financial Advisor. The Program Fee is based on the total assets under management, including any portion of the Account maintained in cash or in short‐term vehicles including, but not limited to, unallocated cash swept to a deposit account at our affiliate, PNC Bank, or money market funds. As the aggregate market value of the Program Account and if applicable other managed accounts in the billing household reaches a higher tier, as shown in the table below, the assets within that higher tier are charged a lower rate. Our standard Program Fee schedule is as follows: Assets Under Management Maximum Program Fee First $250,000 2.00% Page 11 of 30 Portfolio Solutions Strategist Program October 17, 2025  Next $250,000 1.75% Next $500,000 1.50% Next $1,000,000 1.25% Next $2,000,000 1.00% Over $4,000,000 Negotiable From time to time, we offer discounted pricing programs at our discretion. For example, current employees of PNCWM and their immediate family members are eligible for employee pricing. Your Financial Advisor has discretion to negotiate a Program Fee that varies from the standard schedule above. This can depend on certain factors, including the type and size of your Account, the range of services provided and the total amount you or other members of your household have invested with PNC Wealth Management. The Program Fee for your Account is referenced in the fee schedule included as part of the Proposal completed and accepted by you. The Program Fee you pay to PNC Wealth Management for the Portfolio Solutions Strategist Program is charged quarterly in advance and will be based on the average daily balance in your Portfolio Solutions Strategist Account over the prior calendar quarter or portion thereof (except in the case of a new account, as outlined below). The Program Fee covers the cost of brokerage commissions and other transaction fees only for transactions executed through National Financial Services LLC (“National Financial”) on an agency basis. The Investment Delegate will typically route trades to National Financial for execution. From time to time, the Investment Delegate will trade with Broker Dealers other than National Financial when the Investment Delegate determines, in their sole discretion that this is in your best interest. Trades executed away from National Financial are described as “trading away” or “step‐out trades”. You will bear the cost of any brokerage commissions incurred on transactions executed through other brokers, dealer markups, markdowns and spreads when the Investment Delegate Trades Away from National Financial. See the Additional Fees for Brokerage Services and Trading Practices section below for details. In addition to the Program Fee, you will pay a separate Strategist Fee for the services provided by the investment manager(s) that provide the Investment Model(s) you have selected. The Strategist Fee is based on the average daily balance of assets under advisement invested pursuant to the applicable Investment Model(s), including any portion of the Account maintained in cash, or in short‐term vehicles including, but not limited to, unallocated cash swept to a deposit account at our affiliate, PNC Bank, or money market funds, over the prior calendar quarter, or portion thereof. PNCWM will bill Program Accounts on behalf of Strategists and will remit payment to the appropriate Strategists on behalf of Program Accounts. PNCWM does not anticipate retaining any portion of the Strategist Fee. Current Strategist Fees are set forth in the table below. From time to time, Strategists may change their fees without notice to PNC Wealth Management or you. Annual Fee 0.4 Model Provider Morningstar All‐Cap Equity Annual Fee 0.5 Model Provider AB Concentrated International Growth Equity AB Concentrated US Growth Alger Capital Appreciation Alger Mid Cap Growth Aristotle Value Equity 0.4 0.4 0.4 0.45 Morningstar Dividend Managed Morningstar Dividend Non‐MLP Morningstar Hare Non‐MLP Morningstar Tortoise Non‐MLP 0.5 0.5 0.5 0.5 Page 12 of 30 Portfolio Solutions Strategist Program October 17, 2025  0.45 Neuberger Small Cap Intrinsic Value (SCIV) 0.55 Baird Chautauqua International Growth Equity Baird Mid‐Cap Growth Equity Baird Small/Mid Cap Growth BlackRock Capital Appreciation 0.4 0.4 0.38 0.45 0.38 0.17 0.38 0.27 Neuberger Berman International ADR Nuveen Dividend Growth Nuveen Intermediate Municipal Fixed Income Nuveen Limited Maturity Municipal Nuveen Long Term Municipal Nuveen Municipal Ladder 10‐25 Years 0.28 0.28 0.17 0.4 Nuveen Municipal Ladder 1‐10 Years 0.17 0.27 Nuveen Municipal Ladder 1‐15 Years 0.17 0.27 Nuveen Municipal Ladder 1‐7 Years 0.17 0.15 Nuveen Municipal Ladder 5‐15 Years 0.17 PIMCO 1‐5 yr Corporate Ladder 0.23 0.15 0.15 0.38 PIMCO Low Duration PIMCO Municipal Income Opportunity 0.4 0.28 0.27 PIMCO Total Return 0.4 0.27 Polen Capital Focus Growth 0.4 0.27 Polen Global Growth ADR 0.5 Polen U.S. Small Company Growth Poplar Forest Contrarian Value Partners 0.6 0.4 0.5 0.4 0.45 Principal US Small Cap Equity 0.45 0.3 Principal US Small Cap Value 0.45 0.45 0.38 BlackRock Global Dividend Income ADR 0.4 BlackRock Equity Dividend BlackRock Fundamental Core Taxable Fixed Income BlackRock Intermediate Municipal Fixed Income BlackRock Intermediate Taxable Fixed Income BlackRock Laddered Municipal (10‐20 Year) Fixed Income BlackRock Laddered Municipal (1‐10 Year) Fixed Income BlackRock Laddered Municipal (1‐5 Year) Fixed Income BlackRock Large Cap Value BlackRock Long‐Term Municipal Fixed Income BlackRock Short‐Term Municipal Fixed Income BlackRock Short‐Term Taxable Fixed Income BNYM Walter Scott International Stock ADR Boston Partners All Cap Boston Partners International Equity ADR Boyd Watterson All ETF Ultra Enhanced Core Boyd Watterson Investment Grade Intermediate Boyd Watterson Limited Duration* Boyd Watterson Ultra Enhanced Core* 0.3 0.3 0.2 0.3 Principal Real Estate Securities Principal Spectrum Tax Advantaged Preferred Securities QRG QP: Market Series All Cap Core** Brown Advisory Large‐Cap Sustainable Growth Causeway Global Value ADR 0.38 0.2 Causeway International Value ADR Cincinnati High Yield Fixed Corp Bond 0.45 0.4 QRG QP: Market Series All Cap Core ‐ Low Minimum** 0.2 QRG QP: Market Series Global** QRG QP: Market Series Emerg Mrkts ADR** 0.4 Page 13 of 30 Portfolio Solutions Strategist Program October 17, 2025  ClearBridge Appreciation ESG 0.4 0.4 ClearBridge Dividend ESG Strategy ClearBridge Dividend Strategy 0.48 0.48 0.25 0.25 ClearBridge International Value ADR ClearBridge Large Cap Value 0.43 0.43 0.15 0.15 Cohen & Steers US Realty Total Return 0.32 0.2 ClearBridge Small Cap Growth 0.43 0.2 Columbia Contrarian Core 0.48 0.2 Columbia Dividend Income 0.4 0.2 Dana Large Cap Equity Dana Municipal Bond* 0.4 0.45 0.2 0.2 0.2 0.2 0.2 0.2 Dana Small Cap Core Equity Dean Capital Mid Cap Value Diamond Hill Large Cap EARNEST Partners Mid Cap Core 0.3 0.45 0.4 0.48 EARNEST Partners Mid Cap Value 0.48 0.45 Earnest Partners Small Cap Core EARNEST Partners Small Cap Value 0.5 0.5 0.3 0.3 Federated Core Plus 0.35 0.25 0.25 Federated International Strategic Value 0.45 Federated Strategic Value Dividend 0.4 0.25 0.2 0.2 0.3 0.45 QRG QP: Market Series Emerg Mrkts ADR ‐ Low Minimum** QRG QP: Market Series Intl ADR** QRG QP: Market Series Intl ADR ‐Low Minimum** QRG QP: Market Series Large Cap Core** QRG QP: Market Series Large Cap Core ‐ Low Minimum** QRG QP: Market Series Large Cap Dividend Income** QRG QP: Market Series Large Cap Dividend Income ‐ Low Minimum** QRG QP: Market Series Large Cap Growth** QRG QP: Market Series Large Cap Growth ‐ Low Minimum** QRG QP: Market Series Large Cap Value** QRG QP: Market Series Large Cap Value ‐ Low Minimum** QRG QP: Market Series Mid Cap Growth** QRG QP: Market Series Mid Cap Value** QRG QP: Market Series Small Cap Core** QRG QP: Market Series Small Cap Core ‐ Low Minimum** QRG QP: Sustainable Emerging Markets ADR Portfolio** QRG QP: Sustainable International ADR** QRG QP: Sustainable Large Cap Core ‐ Catholic Values** QRG QP: Sustainable Large Cap Core‐ Gender and Diversity** QRG QP: Sustainable Large Cap Core Portfolio ‐ ESG** QRG QP: Sustainable Small Cap Core Portfolio ‐ ESG** QRG QP: SustainableGlobal Climate** QRG: 1‐10 Yr Corp Ladder QRG: 1‐10 Yr Muni Ladder RNC Genter Muni Quality Intermediate 0.3 0.095 0.095 0.3 0.15 0.3 0.23 0.45 Franklin Intermediate Fixed Income Franklin Intermediate Muni* GW&K Core Bond* Harding Loevner International Equity ADR Invesco Investment Grade Floating Bond Invesco Tax Free Limited Term Sage Advisory Tactical ETF Core Plus Fixed Income Managed Account Schafer Cullen Global High Dividend Value ADR Managed Account Page 14 of 30 Portfolio Solutions Strategist Program October 17, 2025  Ithaka Growth 0.4 0.45 0.45 Janus Henderson Mid Cap Growth 0.44 0.45 0.48 Jennison International Equity Opportunities Jennison Large Cap Growth Equity 0.4 0.45 Jensen Quality Growth Discipline 0.45 0.4 0.48 John Hancock US Small Cap Core 0.5 0.38 JP Morgan Equity Income 0.4 0.38 Kayne Anderson Rudnick Small Cap 0.5 0.5 0.5 0.4 Lazard Emerging Markets Equity Select ADR Lazard US Equity Select Tax‐Aware 0.4 0.4 Leeward Mid Cap Value 0.4 0.4 0.45 0.27 Schafer Cullen International High Dividend ADR Managed Account Schroders International Alpha ADR Managed Account Segall Bryant & Hamill Small Cap Growth Managed Account Stonebridge Tax‐Advantaged QDI Preferred Securities Managed Account Suncoast Large Cap Growth Managed Account T. Rowe International Core Equity Managed Account T. Rowe Price US Growth Stock Managed Account T. Rowe Price US Value Equity Managed Account T. Rowe US Large‐Cap Core Equity Managed Account The London Company Income Equity Managed Account The London Company SMID Managed Account Tributary Small Cap Core TS&W Mid Cap Value Managed Account Vaughan Nelson Select Managed Account 0.42 0.4 0.4 0.27 0.55 Leeward Small Cap Value Loomis Sayles Large Cap Growth Lord Abbett Intermediate Tax‐Exempt Fixed Income Lord Abbett Long Tax Exempt Fixed Income Madison Mid‐Cap Equity 0.45 0.55 Mar Vista Strategic Growth 0.4 0.45 0.45 0.5 0.45 0.42 0.6 0.43 0.55 0.02 WCM Quality Global Growth Managed Account WCM Focused Growth International Managed Account Westfield Mid Cap Growth Equity Managed Account Westwood Small Cap Managed Account Westwood Salient MLP Westwood SMidCap Managed Account WST Asset Manager Credit Select Risk Managed Account Martin Currie Emerging Markets MFS Large Cap Growth Miller/Howard MLP Strategy Morningstar Absolute Return Strategy‐ BNY *Strategist Traded Model **Tiered Fee Schedule ‐ Maximum Rate is Displayed Calculation of Account Fees The Program Fee and the Strategist Fee will be paid in advance following the end of each calendar quarter for the upcoming quarter and will be calculated on the last business day of the quarter as follows. The Program Fee is calculated based upon the average daily market value of the total assets in the Account over the prior Page 15 of 30 Portfolio Solutions Strategist Program October 17, 2025  calendar quarter, including cash holdings. Cash holdings in excess of 7.5% (operational cash purposes i.e., trading and account maintenance needs) will be excluded from the average daily market value calculation when the Program fee is calculated. The Strategist Fee is calculated based on the average daily market value of assets in the Account invested pursuant to the applicable Investment Model(s), including any portion of such assets maintained in cash, money market funds or other short‐term vehicles pursuant to the applicable Investment Model(s), over the prior calendar quarter. Because the Strategist Fee differs based upon the investment options selected for the Account, the actual aggregate fees charged to the Account will be based upon the fees attributable to the investment options included in the Account at the time of the fee calculation (i.e., the last business day of the calendar quarter). Accordingly, it is important to note that changes in the Account’s asset allocation caused by rebalancing, as well as changes among the types of investment options, during a particular calendar quarter will cause the aggregate of the Program Fee and the Strategist Fee to be higher or lower than such aggregate amount would have been if calculated based on the composition of the investment options actually held in the Account during the relevant calendar quarter. Upon your request, we will provide you with a detailed explanation of the fee calculation which will allow you to recalculate the fees should you so desire. If your Account is new, you will pay an initial fee after the date that National Financial, the custodian, receives the initial assets of your Account. An adjustment to the next quarterly fee will be made for any significant contributions or distributions that occur during the inception quarter of your Account. With your initial contribution and for any additional contribution or distribution adjustments, your fee will be calculated for that portion of the ongoing quarterly Program Fee that relates to the number of days remaining in the calendar quarter as of the date your Account becomes subject to the Investment Management Agreement or that you make the additional contribution or distribution, as applicable. This Program Fee will be based on the total market value of assets in your Account on that date. If your Account is terminated by you or PNC Wealth Management during a calendar quarter, the fee for that quarter will be prorated over the number of days that the Account was open during the quarter. Any overpayment will be refunded to you after the Account is closed. Fees are not prorated for contributions or withdrawals made during a calendar quarter, except in the case of a new or terminated Account, as outlined above. If you terminate your Portfolio Solutions Strategist account within 90 calendar days of initial investment, PNC Wealth Management reserves the right to charge you commissions, according to the Overview of Products and Services, for transactions executed on your behalf during the time your account was managed, less any pro‐ rated advisory fee paid by you. Additional Fees for Brokerage Services PNC Wealth Management will charge its standard fees for additional brokerage account services that are not included in the Program. Such fees include, but are not limited to, account termination/transfer fees, wire transfer fees, IRA fees and stop payment fees. You should be aware that in some cases, PNCWM retains this entire fee or marks up the fee our clearing firm, National Financial, charges to PNCWM for these services. This is a conflict of interest for us because PNCWM has an incentive to utilize a clearing firm that allows us to mark up designated fees. PNCWM also has incentive to recommend to you services that have been marked‐up. Please refer to the Account Level Fees section of the Overview of Products and Services for details. Deduction of Account Fees All fees incurred by the Account will be paid from the cash balance or by selling shares of a money market mutual fund. If the Account does not have a sufficient cash balance or enough money market mutual fund shares to cover the fees, we will liquidate other securities as necessary to pay them. Selling securities to pay fees is subject to the short‐term trading policies of Funds and, if your account is taxable, will create tax consequences Page 16 of 30 Portfolio Solutions Strategist Program October 17, 2025  for you. You may contact your Financial Advisor if you have any questions regarding the fees charged to your Account. Other Expenses Each Fund in which your Account is invested charges its own separate fund‐level fees and operating expenses, including, for example, administrative, custody, transfer agent, legal and audit fees and expenses, investment advisory or management fees, shareholder servicing fees, omnibus accounting fees, fees for sub‐administration, recordkeeping, print mail services and other expenses. These fees and operating expenses are ultimately borne by the shareholders invested in the Fund, including you, and will reduce your investment returns. Other classes of mutual funds have lower fund‐level fees and expenses than those used in this Program. Please review the relevant Funds’ prospectuses for a full explanation of fund expenses and charges. While it is the responsibility of each Strategist to select the share class of mutual funds used in its Investment Model, it is anticipated that Strategists will primarily select share classes eligible for no‐transaction fee trading available through our custodian’s Institutional No‐Transaction Fee or No‐Transaction Fee programs (collectively “INTF/NTF Eligible” share classes). INTF/NTF Eligible share classes reduce PNC Wealth Management’ overall program trading costs, which costs would otherwise by payable by PNC Wealth Management. This represents a conflict of interest for us because it enables PNC Wealth Management to avoid costs and because the INTF/NTF Eligible share class of a fund that is included in an Investment Model may be more expensive than other share classes of the same fund that you are eligible to purchase. PNC Wealth Management will not direct any Strategist to select a specific share class in their Investment Model, however, we may decline to approve Strategists or Investment Models not expected to use INTF/NTF Eligible share classes. This will limit investment options available to you in the Program. INTF/NTF Eligible share classes do not typically charge shareholders 12b‐1 fees or pay those fees to us or our custodian, which reduces costs to you, as compared to share classes that do pay 12b‐1 fees. Please note that the mutual funds included in the Program may provide compensation such as fees for omnibus accounting, sub‐ administration, shareholder services, recordkeeping, print mail services or other related fees (“Mutual Fund Compensation”). While we do not expect to receive such fees, PNC Wealth Management will credit to your Account any Mutual Fund Compensation or 12b‐1 fees paid to us in connection with the holdings in your Account. Our custodian or other entities not affiliated with PNC Wealth Management may receive Mutual Fund Compensation. PNC Wealth Management is not a party to such arrangements and we will not credit your Account for Mutual Fund Compensation received by such entities. You should be aware that any Mutual Fund Compensation paid to entities not affiliated with PNC Wealth Management increases Fund expenses and, consequently, reduces the investment performance of your account. PNC Wealth Management receives an annual credit from National Financial (the “Business Development Credit”). PNCWM is incentivized to select and continue its relationship with National Financial to receive the Business Development Credit, which is contingent on the fully disclosed clearing agreement with National Financial remaining in effect. The Business Development Credit is not related to the sale or offer of any specific products or services, nor is it dependent upon assets under management. If received, we will retain the Business Development Credit in its entirety, and we will not pass along any portion of it to you. Your Financial Advisor does not receive any portion of the Business Development Credit. Additionally, if under certain circumstances our clearing arrangement with National Financial is terminated prior to the expiration of our agreement, PNCWM is subject to certain contractual fees and penalties (collectively, the “Termination Fee”). The Termination Fee creates a strong disincentive for PNCWM to consider clearing Page 17 of 30 Portfolio Solutions Strategist Program October 17, 2025  relationships other than National Financial. This creates a conflict of interest for us as we expect to benefit from the continued recommendation of National Financial as our clearing firm. Additionally, PNCWM is further incentivized to continue the relationship with National Financial as we may not receive the same incentives from other clearing firm arrangements, such as receiving particular credits from National Financial or having the ability to mark‐up certain fees to clients. PNC Wealth Management receives additional compensation, referred to as revenue sharing, from the advisors or distributors of the mutual funds offered by PNC Wealth Management, which compensates us for administrative services we provide to them and is based on the level of assets invested in the mutual funds they advise or distribute. PNC Wealth Management does not receive revenue sharing payments on assets invested in the Portfolio Solutions Strategist Program and assets invested in Program Accounts are specifically excluded from revenue sharing calculations. Nevertheless, this creates a conflict of interest for us because PNC Wealth Management has an incentive to recommend our other advisory programs that do participate in our revenue sharing program. Additionally, PNC Wealth Management has an incentive to utilize investment managers that participate in our revenue sharing program. Our independent due diligence process for selecting mutual funds for our investment advisory programs, excluding Portfolio Solutions Strategist, is designed so that mutual funds are selected based on objective, investment related criteria and does not take into account compensation to PNC Wealth Management. However, only funds for which we receive revenue sharing are considered for inclusion in this due diligence process. We will not credit your Account for any revenue sharing payments we receive. For details on revenue sharing received by PNC Wealth Management from advisors or distributors, please see the following link: https://www.pnc.com/content/dam/pnc‐com/pdf/personal/wealth‐ management/Additional‐Compensation‐Disclosure.PDF For more information around the compensation a particular mutual fund provider may pay, please refer to the mutual fund’s prospectus and/or Statement of Additional Information. Additionally, some Funds impose redemption fees depending on the share class, if they are redeemed within a specified time period, to discourage short‐term trading or for other reasons. The relevant Fund company retains these redemption charges from the proceeds of the redemption for the benefit of the remaining shareholders of the Fund. Refer to the prospectus or Statement of Additional Information of relevant Funds for details on each Funds’ short‐term trading policies. The amount of such fees and charges retained will be reflected on your account trade confirmations. Purchasing securities in the Program may cost you more or less than purchasing the securities directly from the funds or through agents of the funds without enrolling in the Program, including through a brokerage account at PNC Wealth Management. By purchasing mutual funds outside of the Program, you may invest in a single fund family and obtain “breakpoints” that could lower the cost of the Funds. However, if you purchase mutual fund shares directly, you may not receive the asset allocation and account monitoring services available via the Program and may not qualify to invest in share classes available to investors through the Program. In addition, mutual funds purchased outside the Program may charge commissions, front‐end or back‐end sales charges, and redemption fees, depending on the share class. Finally, Strategists may purchase, for Program Accounts, Fund share classes that are not eligible to be held outside of the Program. If you own any such share classes in your Program Account, they will be liquidated upon the termination of your Account from the Program. If your Account is taxable, this will create tax consequences for you. Your Account may be invested in Funds for which PNC Wealth Management or one of our affiliates acts as an advisor, sub‐advisor, or administrator, and receives a fee for such services. Therefore, PNC Wealth Management Page 18 of 30 Portfolio Solutions Strategist Program October 17, 2025  or an affiliate receives fees for the services provided to the Funds. The level of advisory or sub‐advisory fees paid to PNC Wealth Management or its affiliates by such Funds, is disclosed in the Prospectus and/or Statement of Additional Information of such Funds. The maximum amount of your Account assets that may be invested in Funds, which pay advisory or sub‐advisory fees to PNC Wealth Management or its affiliates will depend on many factors, but in certain circumstances may reach 100% of your Account assets. You should ask your Financial Advisor about these advisory or sub‐advisory fees, and you may terminate your Investment Management Agreement with PNC Wealth Management at any time if you have any concerns about the level of these fees or the incentives that they create. PNC Wealth Management has an obligation to invest your assets in a manner that considers your best interests first. To that end, PNC Wealth Management will take steps to minimize potential conflicts of interest that arise from investing with Funds that pay PNC Wealth Management or its affiliates advisory or sub‐advisory fees, to the extent required by applicable federal or state laws. PNC Wealth Management evaluates the appropriateness of investing your assets in Funds managed by affiliates of PNC Wealth Management, in the same manner as it evaluates all other Funds available through the Program. Strategists may also select for your Account Funds for which the Strategist or an affiliate of the Strategist acts as an advisor, sub‐advisor, or administrator. In these cases, the Strategist or its affiliate will receive fees for the services provided to the Funds. PNC Wealth Management’ evaluation of Strategists includes an evaluation of total fees and costs associated with each Strategist. PNC Wealth Management evaluates the appropriateness of the fee structure of each Strategist and has made a determination that the fee structure is appropriate. You may ask your Financial Advisor about any conflicts of interest this creates for Strategists and may terminate your Investment Management Agreement with PNCWM or select a different Strategist if you have any concerns about the level of fees or the incentives that they create for applicable Strategists. Cash Balances Unallocated cash will be automatically swept through the Bank Deposit Sweep Program (“BDSP”) into an interest‐bearing deposit account (“Deposit Account”) at our affiliate, PNC Bank (and, as noted above, are included in the assets on which Management Fees are charged). The interest rate (“BDSP interest rate”) for BDSP assets held in the Deposit Account is determined by PNC Bank with input from PNC Wealth Management such as objective competitive market data. BDSP is the only cash sweep option available to your Program Account. The only exception is in very limited situations where your account type is not eligible for BDSP (such as participant accounts of employer sponsored qualified plans) and your funds will be invested in a money market mutual fund selected by us. You should be aware that although assets held in the Deposit Account are protected by FDIC insurance neither PNC Wealth Management nor PNC Bank will monitor whether BDSP deposits, individually or in combination with other deposits you hold at PNC Bank, exceed FDIC insurance limitations. You should review your cash balance held in the Deposit Account and other PNC Bank accounts to ensure that cash balances do not exceed FDIC insurance coverage levels, or alternatively, in the event your cash balance exceeds FDIC insurance limitations, that you are comfortable with the risks associated with having uninsured cash. The rate of return you receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to such cash balances. Additional information about FDIC insurance can be found on https://www.fdic.gov/resources/deposit‐insurance/ PNC Bank uses the BDSP program assets to fund its lending activities, allowing PNC Bank to earn revenue based on the difference between the rate paid to you and the higher rate of interest earned by lending the assets to its customers. Moreover, PNC Wealth Management receives revenue from PNC Bank based on the assets in the BDSP, this revenue amount varies depending on market conditions, but will not exceed the current Federal Page 19 of 30 Portfolio Solutions Strategist Program October 17, 2025  Funds Target Rate Range – Upper Limit rate (available online at https://fred.stlouisfed.org/series/DFEDTARU) plus 0.50%. This means PNC Wealth Management benefits in two ways from placing assets in the BDSP (i.e., the Management Fee and the revenue share from our affiliate). We will not credit any portion of this revenue to your Program Account. Note that the revenue earned by PNC Wealth Management and our affiliate PNC Bank will significantly exceed the interest credited to your Program Account from the allocation to BDSP. The revenue we receive is a conflict of interest for us, because we, and our affiliate, PNC Bank, obtain a financial benefit when your unallocated cash is held through the BDSP in a Deposit Account. This financial benefit is greater than the financial benefit we would receive if your unallocated cash was invested through a different cash sweep vehicle such as a money market fund, which could pay you a higher rate of interest. For information pertaining to the interest rate spread earned by PNC on all loans , including those generated from BDSP assets, please see the Net Interest Margin discussion in the most recent Annual Report on Form 10‐K and subsequent Quarterly Reports on Form 10‐Q for The PNC Financial Services Group, Inc., available at, https://investor.pnc.com/financial‐information/financial‐results. Account assets invested through the BDSP typically will pay you less interest – and in some market conditions, much less interest – than they would if invested in alternative cash sweep vehicles that are available to PNC Wealth Management such as a money market fund. Accordingly, you should not participate in the Program if you wish to hold your unallocated cash in another sweep vehicle. (Please note that while BDSP is used as the sweep option to hold unallocated cash, if your account has an investment allocation to cash, that allocation will typically be held in money market mutual funds or other short duration securities.) The rate of return you receive on cash balances will, in certain market conditions, be less than the Management Fees attributable to such cash balances. You should also know that Strategists utilized in your Program Account will have discretion to select the vehicle (BDSP, money market mutual fund or other short duration security) for any cash in the Investment Model. For more information regarding BDSP, including information about FDIC insurance limitations, please see the PNCWM BDSP Disclosure Document, you may also review the current BDSP interest rate at the following link: https://www.pnc.com/en/personal‐banking/investments‐and‐retirement/sweep‐program‐rates.html. Financial Advisor Compensation A portion of the fees charged for Program services generally will be paid to your Financial Advisor in connection with opening your Account, as well as for providing client‐related services within the Program. This compensation may be more or less than a Financial Advisor would receive if you transacted in a brokerage account, rather than a managed account in the Portfolio Solutions Strategist Program, and paid separately for investment advice, brokerage and other services covered by the Program Fee. Therefore, your Financial Advisor may have greater financial incentive to offer a managed product over a brokerage product. As disclosed above, certain of our Programs charge a negotiable Program Fee and others charge a negotiable Program Fee plus a Model Provider Fee, which in certain circumstances may be waived but is not negotiable. Differences in fees for Model Providers in Programs with a third‐party manager, or the absence of such fees in any Program, create a conflict of interest as such differences provide an opportunity for Financial Advisors to negotiate a higher Fee for a strategy with lower or no separate Model Provider Fees than they would for strategies that charge a higher Model Provider Fee. The opportunity to negotiate a higher fee also creates a financial incentive for Financial Advisors to recommend such Programs and/or Model Providers. The ability of the Financial Advisor to negotiate a higher Program Fee in these circumstances also provides a financial benefit to PNC Wealth Management, which retains a portion of the Program Fee. Occasionally, Program Accounts may be reassigned from the originating Financial Advisor to a new Financial Advisor because the originating Financial Advisor leaves our firm, Page 20 of 30 Portfolio Solutions Strategist Program October 17, 2025  takes a new position, or for other reasons. Financial Advisors receive less compensation for accounts reassigned to them (“Reassigned Accounts”) than accounts they originated and therefore have a conflict of interest because they have a financial incentive to provide better service to accounts that they have originated versus Reassigned Accounts. Financial Advisors receive additional compensation when clients add funds to Reassigned Accounts and have incentive to encourage additional deposits to Reassigned Accounts. PNC Wealth Management has established policies and procedures reasonably designed to ensure that any recommendation made is suitable for your unique circumstances. PNC Wealth Management typically will advance to Financial Advisors a portion of the first year’s estimated fees for clients who invest in the Program. In addition, certain Financial Advisors who typically work with higher net worth clients can earn enhanced upfront compensation when customers establish a new advisory account or add new assets into an existing advisory account with us. This compensation creates a conflict of interest because these Financial Advisors have an additional incentive to encourage clients to place their funds in investment advisory accounts. From time to time, PNC Wealth Management initiates incentive programs for its employees including Financial Advisors. These programs include, but are not limited to, programs that compensate them for attracting new assets and clients, or for referring business to our affiliates (such as referrals for mortgages, trusts, or insurance services); programs that reward them for promoting investment advisory services, in some circumstances by enhancing revenue credits paid to them in connection with new advisory accounts or additions to existing advisory accounts, for participating in advanced training, and for improving client service; and programs that reward Financial Advisors s who meet total production criteria. Financial Advisors who participate in these incentive programs are rewarded with cash and/or non‐cash compensation, such as deferred compensation, bonuses, training symposiums and recognition trips. These programs may be partly subsidized by external vendors or our affiliates, such as mutual fund companies, insurance carriers or money managers. Therefore, our Financial Advisors have a financial incentive to recommend the programs and services included in these incentive programs over other available products and services that we offer. ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS Account Minimums and Types of Clients The minimum account size for the Portfolio Solutions Strategist Program is $250,000. PNC Investment may in certain instances lower the required minimum account size for Accounts invested in certain Investment Models. We may terminate the advisory services on any Account that falls below minimum account value guidelines established by the firm on 30 days’ written notice to the Account holder. To avoid termination, you may be required to deposit additional assets in your Account to remain in the Portfolio Solutions Strategist Program. Under certain limited circumstances, we may waive the minimum account size requirement. In addition, Strategists utilized for the Program typically impose their own investment minimums and may limit or terminate the availability of their Investment Model for Accounts that fall below this minimum. Upon receipt of such account minimum notices from a Strategist, PNC Wealth Management will use commercially reasonable efforts to identify another Strategist that is consistent with or substantively similar to the Investment Model and/or Strategist that has terminated the availability of their Investment Model and resume a continuous investment program for the Account. The replacement Investment Model may be more expensive than the Investment Model it replaces. PNC Wealth Management has limited or no ability to waive Strategist minimums. Collateral Accounts Under certain circumstances you may elect to pledge the assets in your non‐IRA/ERISA Account as collateral for Page 21 of 30 Portfolio Solutions Strategist Program October 17, 2025  a general purpose loan with our affiliate, PNC Bank, or other financial institution (collectively the “Lending Arrangements”). When your Account assets are pledged or otherwise used as collateral in connection with Lending Arrangements, you give the lender certain rights and powers over the assets in the Account. Importantly, lenders have the right to direct PNC Wealth Management to sell or redeem any and all assets pledged as collateral for the loan. In the event of a collateral call on the Account, securities will be liquidated from the Account, which may be contrary to your interests and/or inconsistent with the investment strategy for the Account because positions may be redeemed or liquidated more rapidly (and/or at significantly lower prices) than might be desirable. You or your Financial Advisor may not be provided with prior notice of the liquidation of the securities in the Account. Furthermore, you and your Financial Advisor may not be entitled to choose the securities to be liquidated. After the execution of a collateral call, any remaining securities in the Account may be lower in value than the investment minimums required for the Portfolio Solutions Strategist Program and the Account may be subject to termination as described above. You may wish to discuss with your Financial Advisor how a collateral call could impact you if your pledged Account makes up all, or substantially all, of your overall net worth or investible assets. Any action taken by us, or an affiliate, with respect to the assets held in your Account pursuant to the Lending Arrangements will not constitute a breach of our fiduciary duties as an investment adviser to you under the Portfolio Solutions Strategist Program. The costs associated with the Lending Arrangements are not included in the Program Fee you pay under the Program. Your transaction costs may rise as a result of a collateral call, because securities may be liquidated under unfavorable market conditions. You should consult with your own independent tax advisor in order to fully understand the tax implications associated with the Lending Arrangements. The securities subject to the collateral call will not be liquidated in a manner that considers tax efficiency. PNC Wealth Management does not provide legal, tax or accounting advice. You are encouraged to speak with your Financial Advisor to the extent you have questions about the Program, the Lending Arrangements and how they may impact the management of your Account. You should be aware that PNC Wealth Management and your Financial Advisor have a conflict of interest because PNC Wealth Management and your Financial Advisor’s compensation is based on the assets held in your account and benefits if you enter into a Lending Arrangement instead of withdrawing funds from your account. In addition, you should be aware that PNC Wealth Management and your Financial Advisor will be compensated based on the amounts you draw on the credit line. This is a conflict of interest for your Financial Advisor because he or she has an incentive to recommend Lending Arrangements as opposed to other potential funding sources, because your Financial Advisor is not compensated for other options. In addition, PNC Bank generates revenue by charging interest on any loan underwritten by PNC Bank, which represents a further conflict of interest for PNC Wealth Management. Qualification criteria and requirements, including but not limited to, approval criteria, underwriting standards, loan to value requirements, maintenance requirements and asset eligibility vary by program. You should refer back to the Lending Arrangements and associated documents for the specific terms governing the Lending Arrangements. PORTFOLIO MANAGER SELECTION AND EVALUATION The Portfolio Solutions Strategist Account is managed to diversify your investments and, depending on the Page 22 of 30 Portfolio Solutions Strategist Program October 17, 2025  Investment Model(s) selected, may include investments in equity and fixed‐income securities, options, Funds and money market instruments. Accounts are managed on an individual basis, and our asset allocation and investment recommendations are determined by and based on our understanding of your financial situation, investment objectives and risk tolerance. You may impose further reasonable restrictions and guidelines on your Account, but these will affect the composition and performance of your portfolio. Model and Strategist Selection and Evaluation We select the Investment Models and Strategists that are available in the program. The factors influencing the inclusion of any Investment Model on our list of available Investment Models may include, among other things, investment objective, past performance, management style, quality of the relevant Strategist, its investment process, the number and continuity of investment professionals, and its client servicing capabilities. While PNC Wealth Management is the sole sponsor of the Program, we receive research and assistance in selecting and reviewing Strategists and Investment Models from affiliates or third parties we contract to provide such services. Expenses for these services are paid by PNC Wealth Management. We ask relevant Strategists to complete a questionnaire and provide database information on the firm and statistical analysis of the Strategist’s track record. We may also conduct interviews with members of the Strategist management. This process is an ongoing one, and Investment Models or Strategists are added or removed from the Program based on many factors, either internal or external to a Strategist management. Returns reported by Strategists are derived from sources believed to be reliable, but we make no representations or warranties as to the accuracy of such performance information. The Investment Models included in the Program include holdings of products managed by investment management affiliates of PNC Wealth Management including PNC Capital Advisors, LLC, which receive compensation for their investment advisory and other services. The services provided by our affiliates and the fees they collect for these services vary and generally are disclosed in each Fund’s prospectus. These fees are paid directly by the Fund and affect the total return of a shareholder’s investment. PNC Wealth Management and Other Service Providers to the Program PNC Wealth Management was formed in 2003, and is a direct, wholly owned subsidiary of PNC Bank. PNC Bank is a wholly owned subsidiary of The PNC Financial Services Group, Inc., a financial holding company. PNC Wealth Management is registered with the SEC as an investment advisor and a broker‐dealer. PNC Wealth Management is a member of FINRA and SIPC and serves as the sponsor of the Program. PNC Wealth Management does not receive performance‐based fees calculated as a share of capital gains on, or capital appreciation of, the funds or any portion of the funds or other investments in a client’s Account. National Financial provides trading, custody and operational services for the Program. National Financial carries client Accounts, is the custodian for the investments in your Account, reports all the trades in your Account and effects many such trades. National Financial will provide you with trade confirmations, monthly statements, and income tax reporting. PNC Wealth Management has also engaged a service provider to perform certain support services in connection with the Program, including account rebalancing for the asset allocation models. This service provider is also responsible for calculating and preparing quarterly performance reports for client accounts and may calculate the Program Fees and Strategist Fees. Risks of Investing in the Portfolio Solutions Strategist Program Page 23 of 30 Portfolio Solutions Strategist Program October 17, 2025  Investing in securities, including the investments offered through the Program, involves risk of loss that you should be prepared to bear. There is no guarantee that the elements of the Program, including the asset allocation models, selection of investment manager models and/or research recommendations will protect against such loss. Other risks include:  Market Risk. Market risk is the risk that the price of securities will fall over short or extended periods of time. Historically, the prices of equity securities have moved in cycles, and the value of an Account’s investments will fluctuate from day to day. When individual companies are negatively impacted by industry or economic trends or report poor operating results, the price of securities issued by those companies will typically decline in response. These factors contribute to price volatility.  Allocation Risk. A client Account is subject to the risk that asset allocation decisions will not anticipate market trends correctly. For example, weighting an Account too heavily in equities during a stock market decline may cause a loss of value. Conversely, investing too heavily in fixed income securities during a period of stock market appreciation may result in lower total returns.  Concentration/Diversification Risk. Concentration risk occurs when a client Account holds significant positions in certain securities, sectors or geographic regions. Concentrated positions can be more volatile and present a greater risk of loss, especially over the short term.  Credit Risk. The value of debt securities is affected by the ability of issuers to make principal and interest payments. If an issuer cannot meet its payment obligations or if its credit rating is lowered, the value of its debt securities will typically fall.  Interest Rate Risk. The value of fixed‐income investments will typically decline because of an increase in market interest rates. In addition, in certain low‐yield interest rate environments, some short‐term investments may produce negative yield, after accounting for fees, inflation and other expenses.  Liquidity Risk. The risk stemming from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. Liquidity risk is typically reflected in unusually wide bid‐ask spreads or large price movements (especially to the downside).  Stock-Specific (Unsystematic) Risk. Unsystematic risk is unique to a specific company or industry. Also known as “nonsystematic risk,” “specific risk,” “diversifiable risk” or “residual risk,” in the context of an investment portfolio, unsystematic risk can be reduced through diversification. The Program is intended to be a long‐term investment program and does not support market‐timing or frequent trading. You will be limited to one account level model change per calendar quarter, except as warranted by changes to your financial situation as agreed by you and PNC Wealth Management. In addition, you will be limited to one investment manager model change per quarter, except as may be agreed by you and PNC Wealth Management. Frequent or excessive trading in Portfolio Solutions Strategist accounts are grounds for account termination, with 30 days’ written notice, by PNC Wealth Management, even if the rules above are not violated. The determination of frequent and/or excessive trading is solely at the discretion of PNC Wealth Management. Trading Practices PNC Wealth Management is an introducing broker‐dealer, clearing transactions related to the Program Accounts through National Financial. PNC Wealth Management has a best execution committee (“BEC”) that meets regularly to rigorously review data for equity orders executed by National Financial including those orders that Page 24 of 30 Portfolio Solutions Strategist Program October 17, 2025  are sent by the Investment Delegate. Such data includes, among other things, speed of execution and price improvement provided by the execution venues selected by National Financial. PNC Wealth Management does not receive any payment for order flow from the execution venues. The BEC also reviews data for fixed income trades executed through trading systems used by PNC Wealth Management to ensure that the net prices obtained are reasonable under the circumstances. The Program Fee includes the costs of trades executed only for transactions executed through National Financial on an agency basis. The Program Fee does not include any additional trading expenses incurred when the Investment Delegate determines to trade away from National Financial, for trades executed in Strategist Traded Models (as directed by the Strategists) or for transactions where National Financial acts as principal. The Investment Delegate will trade away from National Financial when the Investment Delegate determines it is in your best interest to do so. This can occur when the Investment Delegate is implementing a model change simultaneously across accounts with many different introducing firms, such as PNC Wealth Management. In these instances, the Investment Delegate may group together trades from several different introducing firms and execute those trades through a single broker‐dealer. This process is known as Block Trading (“Block Trading”). Block Trading is intended to reduce the market impact of executing large transactions in a particular security and can allow clients to get better overall execution prices than if the trades were placed individually. The Investment Delegate may also trade away from National Financial when it determines that a broker‐dealer other than National Financial is capable of obtaining a better execution price for the trade. This can typically occur in thinly traded securities or in fixed‐income securities. Additionally, Strategist Traded Models are implemented directly by the Strategist rather than by PNC Wealth Management or the Investment Delegate. A Strategist of a Strategist Traded Model may trade away from National Financial for the same reasons as described above. Strategists historically implement substantially all trades in Strategist Traded Models away from National Financial. Strategists for Strategist Traded Models typically trade fixed income securities away from National Financial. These trades will incur additional costs per bond or on a per transaction basis. These costs are embedded in the net price you receive and are not separately disclosed by the executing broker in your confirmation or statement. PNCWM does not receive any benefit when the Investment Delegate or Strategist elect to trade away. In either case, it is important that you understand that you will typically pay any commissions, mark‐ups or mark‐downs incurred, in addition to the Program Fee when the Investment Delegate or a Strategist elects to trade away from National Financial or for transactions where National Financial acts as principal. For additional information on the trading practices of the Investment Delegate and the Strategists, please see the following link: https://www.pnc.com/content/dam/pnc‐com/pdf/personal/wealth‐investments/PNCWM/Trade‐Practice‐ Disclosure.pdf. Information regarding Investment Delegate and Strategist trading practices is based upon data provided to us by both the Investment Delegate and the Strategists. We make no representations regarding the accuracy of the information presented and cannot guarantee that the trading practices reflected in the information presented will be followed by the Investment Delegate or Strategists in the future. You should be aware that certain Strategists provide their model portfolio updates to the Investment Delegate after they make changes to accounts that they manage directly. In these instances, this will impact execution prices for your Account relative to other accounts in the same investment strategy that are managed directly by the Strategist. Depending on various factors, including price movements and variations in trade execution, the performance of your Account will differ from, and be better or worse than, the performance of such other accounts managed directly by the Strategist. You should also review the Form ADV Part 2 for the Investment Delegate and, if applicable, the Strategist you have selected, for additional information regarding that firm’s execution practices. Page 25 of 30 Portfolio Solutions Strategist Program October 17, 2025  Proxy Voting PNC Wealth Management will vote all proxies for securities held in the Program Account on your behalf, unless you direct otherwise. PNC Wealth Management has retained and delegated our proxy voting power to Envestnet, a third‐party service provider, to receive proxy statements and to vote shares. Envestnet votes proxies based on the recommendations of Glass‐Lewis & Co. (“Glass‐Lewis”), an independent third‐party research provider. Glass‐Lewis issues voting recommendations based on its own internal guidelines, which assist in limiting possible conflicts of interest in voting your proxies. We will not vote proxies in accordance with voting instructions received from you. PNC Wealth Management has adopted policies and procedures to address any conflicts that arise in connection with voting proxies. PNC Wealth Management may depart from its stated guidelines in order to avoid voting decisions believed to be contrary to the best interests of its clients. More information regarding our policies and procedures regarding proxies can be obtained by contacting your Financial Advisor or by calling PNC Wealth Management at (800) 622‐7086. If you choose, you may request to vote your own proxies by providing us with written instructions to deliver all proxy related materials directly to you for consideration and execution. If you choose this option, proxy materials typically will be forwarded to you by the custodian for your Account. If this option is selected, PNC Wealth Management, or its third‐party service provider, will no longer be in a position to vote proxies for any securities for your Account, including securities over which PNC Wealth Management has investment discretion. PNC Wealth Management will not advise or act for you with respect to any legal matters for securities held in your Account, including class actions or bankruptcies. Documents received with respect to such matters will be forwarded directly to you for your consideration. CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS As part of the acceptance and approval process, and by signing the Investment Management Agreement, you grant us discretionary trading authority over your Account. PNC Wealth Management utilizes information regarding your financial circumstances, investment goals and objectives and any special written instructions you may wish to give regarding your Account. Client information is not provided to Strategists. CLIENT CONTACT WITH PORTFOLIO MANAGERS Your Financial Advisor will communicate any changes about you to PNC Wealth Management. You will have very limited, if any, direct contact with the individuals responsible for making investment decisions for the Program and will have no direct contact with the provider of any Manager Model you might select. You should direct any inquiries regarding the investment manager to your Financial Advisor. ADDITIONAL INFORMATION Disciplinary Information  On April 11, 2016, PNC Wealth Management entered into a settlement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that it failed to reasonably supervise the application of sales charge waivers to eligible mutual fund sales and failed to apply such waivers to mutual fund purchases by certain retirement plan customers that were eligible to purchase Class A shares in certain mutual funds without a front‐end sales charge. The findings also stated that PNC Wealth Management failed to maintain adequate written policies and procedures Page 26 of 30 Portfolio Solutions Strategist Program October 17, 2025  or to provide adequate training to assist financial advisors in determining when sales charge waivers were available for retirement plan customers. PNC Wealth Management was not required to pay a fine, but consented to be censured and to pay restitution to eligible customers who did not receive sales charge waivers for fund purchases since July 1, 2009.  On April 6, 2018, PNC Wealth Management entered into a settlement (“Order”) with the Securities and Exchange Commission (“SEC”). Without admitting or denying the findings, PNC Wealth Management consented to the findings that, as a result of the conduct described below, PNCWM willfully violated Sections 206(2), 206(4) and 207 of the Investment Advisers Act of 1940 (“Advisers Act”) and Rule 206(4)‐ 7 thereunder. The Order finds that the violations resulted from the following conduct of PNCWM: (1) PNCWM, without adequate disclosure of the associated conflicts of interest, invested advisory clients in mutual fund share classes with 12b‐1 fees instead of available lower‐cost share classes of the same funds without 12b‐1 fees; (2) PNCWM did not disclose a conflict of interest regarding marketing support payments paid on such mutual fund share classes that charged 12b1 fees; (3) PNCWM improperly charged advisory fees to client accounts where the investment adviser representative departed the firm (“Orphaned Accounts”) and where PNCWM failed to assign a new investment adviser representative within thirty days; and (4) PNCWM failed to adopt and implement written compliance policies and procedures reasonably designed to prevent violations of the Advisers Act and the rules thereunder in connection with its mutual fund share class selection practices and treatment of Orphaned Accounts. The Order requires PNCWM to cease and desist from committing or causing any violations and any future violations of Advisers Act Sections 206(2), 206(4), and 207 and Rule 206(4)‐7; censures PNCWM; and requires PNCWM to pay disgorgement of $5,234,856, and prejudgment interest of $612,344, to compensate advisory clients who were affected by certain conduct detailed in the Order. PNCWM will pay, in addition to the disgorgement and prejudgment interest described above, disgorgement of $497,144 in marketing support fees and prejudgment interest thereon of $63,426 to the SEC for the transfer to the general fund of the United States Treasury. Lastly, PNCWM will pay a civil monetary penalty of $900,000.  On April 22, 2024, PNC Wealth Management signed a Final Order with the State of North Carolina Department of the Secretary of State Securities Division. Without admitting or denying the findings, PNCWM was ordered to pay civil penalties in the amount of $7,500 and costs of investigation in the amount of $1,000 resulting from the following conduct: (1) PNCWM and one investment adviser representative (“IAR”) failed to comply with North Carolina’s IAR registration requirements in violation of N.C.G.S. §78C‐16(a1) in which the IAR transacted advisory business in North Carolina from on or about December 2021 through on or about October 2023 without being IAR registered; (2) PNCWM was in violation of N.C.G.S. §78C‐18(b) and 18 NCAC 06A .1801(a)(18) by employing the IAR in North Carolina without the appropriate registration and by not furnishing this information to the IAR’s PNCWM advisory clients; and (3) PNCWM failed to supervise the IAR’s acts, practices and conduct to ensure adherence with North Carolina’s IAR registration provisions in violation of N.C.G.S. §78C‐19(a)(2)(j) and 18 NCAC 06A .1808.  On April 24, 2024, PNC Wealth Management signed a Consent Agreement and Order with the Pennsylvania Department of Banking and Securities. The Department alleged that from on or about December 2018 until December 2023, PNCWM failed to register at least one employee as an investment adviser representative in Pennsylvania in violation of Section 301(c.1)(1)(ii) of the Pennsylvania Securities Act of 1972 (“the 1972 Act”), 70 P.S. § 1‐301(c.1)(1)(ii). Without admitting or denying the Page 27 of 30 Portfolio Solutions Strategist Program October 17, 2025  findings in the Order, PNCWM agreed to pay a monetary fine of $100,000 and to comply with the relevant provision of the 1972 Act.  On September 3, 2024, PNC Wealth Management signed a Settlement Order with the Commonwealth of Virginia Division of Securities and Retail Franchising. The Division alleged that from on or about February 2019 to June 2024, PNCWM failed to register an investment advisor representative in Virginia in violation of § 13.1‐504 C (ii) of the Virginia Securities Act. Without admitting or denying the findings in the Order, PNCWM paid $10,000 in monetary penalties and $1,000 in investigation costs.  On September 18, 2024 PNC Wealth Management entered into an Administrative Consent Agreement and Order with the District of Columbia’s Department of Insurance, Securities and Banking alleging that from on or about August 2012 through February 2024, PNCWM failed to register three investment advisor representatives in D.C. in violation of D.C. Official Code §§ 31‐5602(b)(2) and 31‐5605.01(4). PNCWM paid $162,500 as a civil penalty and $1,080 in unpaid registration fees.  On June 16, 2025, PNC Wealth Management entered into an agreement (an “AWC”) with FINRA. Without admitting or denying the findings, PNC Wealth Management consented to the entry of findings that from at least June 2021, it violated FINRA rules by failing to establish and maintain a reasonably designed supervisory system, including written supervisory procedures, for the surveillance and supervision of rates of deferred variable annuity exchanges. PNC Wealth Management was required to pay a $200,000 fine and to implement a supervisory system and written supervisory procedures reasonably designed to achieve compliance in surveilling registered representatives’ rates of deferred variable annuity exchanges consistent with applicable securities laws and regulations, and with applicable FINRA rules. Other Financial Industry Activities and Affiliations PNC Wealth Management’ principal business is that of a full‐service, general securities broker‐dealer and investment adviser, registered with the SEC and as a member of FINRA. Our primary retail brokerage activities include the sale of corporate equities, corporate debt, municipal securities and funds, mutual funds, ETFs and annuities. PNC Wealth Management is part of a broad financial services organization and is therefore affiliated with other entities engaged in a variety of financial services businesses. In some cases, the firm has business arrangements with its affiliates that are material to its advisory business or to its clients. These are described in more detail below and, in some cases, cause PNC Wealth Management’ or a related person’s interests to diverge from the best interests of our clients. PNC Wealth Management is affiliated with the following financial services entities through its parent, The PNC Financial Services Group, Inc.:  PNC Bank, National Association is a wholly owned subsidiary of The PNC Financial Services Group, Inc., and is a full‐service bank engaged in traditional lending, cash and/or treasury management and other services.  PNC Capital Advisors, LLC is a wholly owned subsidiary of PNC Bank and provides discretionary fixed income investment advisory services to institutional accounts.  PNC Capital Markets LLC is an indirect, wholly owned subsidiary of The PNC Financial Services Group, Page 28 of 30 Portfolio Solutions Strategist Program October 17, 2025  Inc. and offers loan syndication, public finance underwriting and advisory services, securities underwriting and trading, private placements, asset securitizations and merger and acquisition advisory services.  PNC Insurance Services, LLC is a wholly owned subsidiary of PNC Wealth Management and a licensed insurance agency. It provides a variety of insurance products and advice. Selected conflicts of interest that exist between PNC Wealth Management and its affiliates are discussed below. Although PNC Wealth Management is committed to acting in the best interests of our clients, in some situations there are conflicts of interest between the firm’s interests and a client’s interests, or there are conflicts in the interests of multiple clients. Many of these conflicts of interest are inherent in operating an investment advisory business. For example, PNC Wealth Management may have an incentive to resolve a matter in favor of clients that are affiliates of the firm over clients that are not affiliates of the firm. PNC Wealth Management has adopted policies and procedures that it believes are reasonably designed to help mitigate these conflicts of interest. Affiliates of PNC Wealth Management provide advice to their clients with respect to investment strategies that are similar to or the same as strategies offered by PNC Wealth Management. Those advisory affiliates may purchase on behalf of their clients the same securities that PNC Wealth Management may purchase for our clients. As a result, the interests of PNC Wealth Management’ clients may conflict with the interests of the clients of these affiliated advisors. For example, if an investment advisor affiliate implements a portfolio management decision for its client ahead of, or contemporaneously with, a decision PNC Wealth Management makes for its client(s), the market impact of the decision made by the firm’s advisory affiliate could result in one or more of PNC Wealth Management’ clients receiving less favorable trading results than they otherwise would. PNC Wealth Management’ trade allocation and trade aggregation procedures do not typically apply to portfolio management decisions and trading executed by investment advisory affiliates for their clients that are not clients of PNC Wealth Management. Affiliate Transactions PNC Wealth Management or its affiliates may from time to time recommend investments in transactions in which PNC Wealth Management or its affiliates act as financial advisor or a broker‐dealer, or in securities which are underwritten, issued, packaged or serviced by an affiliate. Moreover, PNC Wealth Management may act as a broker in executing your purchase or sale for your account of a debt security from or to PNC Capital Markets, a brokerage affiliate. Additionally, your Financial Advisor may recommend you purchase a mutual fund advised by PNC Capital Advisors, an affiliated registered investment adviser. These affiliates receive compensation as a result of these transactions, if these transactions were to occur. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PNC Wealth Management has adopted a Code of Ethics, which consists of certain general principles, including the following:  Advisory personnel must place client interests before their own  The personal securities transactions of our personnel must avoid even the appearance of a conflict with client interests Page 29 of 30 Portfolio Solutions Strategist Program October 17, 2025   Our personnel must avoid actions or activities that allow, or appear to allow, them to profit or benefit from their position with respect to clients, or that would otherwise bring into question their independence or judgment  From time to time, PNC Wealth Management personnel may accept training, business entertainment or gifts of de minimis value from product vendors. PNC Wealth Management has adopted policies and procedures reasonably designed to ensure any such activity does not impact our personnel’s ability to act in the best interests of our clients  In addition, the Code of Ethics requires our employees to report their personal securities transactions and holdings. A copy of our Code of Ethics will be provided to any client or prospective client upon request. Our employees are also subject to the PNC Employee Conduct Policies, which cover matters including compliance with law, conflicts of interest, insider trading, outside activities and safeguarding confidential information. Client Reports As part of the Portfolio Solutions Strategist Program, we will provide periodic reports to assist you in monitoring and assessing the performance of your Account. These reports will contain information regarding trades, investment return, and selected benchmark comparisons. These reports may also contain letters, notices and other important information regarding the Model Managers and any changes to the Account during the period. Client Referrals and Other Compensation Your Financial Advisor may refer you to PNC Bank or other PNC Wealth Management affiliates for additional products or services and will generally receive compensation for such referrals. A portion of the fees charged for the Portfolio Solutions Strategist Program services described in this Brochure may be paid to your Financial Advisor in connection with the introduction of Accounts as well as for providing client‐related services within the Programs. This compensation may be more or less than a Financial Advisor would receive if you paid separately for investment advice, brokerage and/or other services. Certain employees of PNC Bank’s Wealth Management and or Private Client Group receive compensation in connection with referrals to PNC Wealth Management. PNC Wealth Management has related persons who are investment advisors who act as general partners in partnerships in which our clients may be solicited. PNC Wealth Management would not have knowledge of such solicitations should they occur, and consequently, would not be a participant in them, nor would we receive any compensation for them. Financial Information In certain circumstances, PNC Wealth Management would be required to provide you with financial information or disclosures about our financial condition. Currently, no such circumstances exist for PNC Wealth Management. PNC Wealth Management has no financial commitments that impair our ability to meet our contractual and fiduciary commitments to our clients and has never been the subject of a bankruptcy proceeding. Page 30 of 30 Portfolio Solutions Strategist Program October 17, 2025