Overview

Assets Under Management: $606 million
Headquarters: PRINCETON, NJ
High-Net-Worth Clients: 183
Average Client Assets: $4 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Educational Seminars

Fee Structure

Primary Fee Schedule (PRINCETON GLOBAL ASSET MANAGEMENT, LLC FORM ADV PART 2A: FIRM BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 1.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $15,000 1.50%
$5 million $75,000 1.50%
$10 million $150,000 1.50%
$50 million $750,000 1.50%
$100 million $1,500,000 1.50%

Clients

Number of High-Net-Worth Clients: 183
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 84.40
Average High-Net-Worth Client Assets: $4 million
Total Client Accounts: 1,001
Discretionary Accounts: 991
Non-Discretionary Accounts: 10

Regulatory Filings

CRD Number: 146644
Last Filing Date: 2025-01-29 00:00:00
Website: https://princetonglobal.com

Form ADV Documents

Primary Brochure: PRINCETON GLOBAL ASSET MANAGEMENT, LLC FORM ADV PART 2A: FIRM BROCHURE (2025-05-13)

View Document Text
PRINCETON GLOBAL ASSET MANAGEMENT, LLC 17 Hulfish Street, Suite 240 Princeton, NJ 08542 A SEC Registered Advisory Firm1 FIRM BROCHURE, MAY 2025 This brochure provides information about the qualifications and business practices of Princeton Global Asset Management, LLC (“PGAM”). If you have any questions about the content of this brochure, please contact us at (609) 945-1781 and/or www.princetonglobal.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about PGAM is available on the SEC’s website at www.adviserinfo.sec.gov 1 SEC or State registration does not and should not imply any certain level of skill or training. Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 2 Item 2. Material Changes In 2024, PGAM has added an estate planning service provider. Please refer to Item 4 for additional information. There have not been any other material changes to PGAM’s advisory business or personnel since the filing of its 2024 Annual ADV Disclosure Brochure. Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 3 Item 3. Table of Contents Item 4. Advisory Business ......................................................................................................... 4 Item 5. Fees and Compensation ................................................................................................ 6 Item 6. Performance Based Fees and Side by Side Management ............................................ 7 Item 7. Types of Clients ............................................................................................................ 7 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss..................................... 8 Item 9. Disciplinary Information .............................................................................................. 8 Item 10. Other Financial Industry Activities and Affiliations ................................................... 8 Item 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................................................................................................................... 9 Item 12. Brokerage Practices ................................................................................................... 10 Item 13. Review of Accounts .................................................................................................... 11 Item 14. Client Referrals and Other Compensation ................................................................. 11 Item 15. Custody ...................................................................................................................... 12 Item 16. Investment Discretion ............................................................................................... 12 Item 17. Voting Client Securities ............................................................................................. 12 Item 18. Financial Information ................................................................................................ 12 Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 4 Item 4: Advisory Business PGAM was founded on January 31, 2008. PGAM is principally owned and managed by Paul J. Gerard and Brett M. Shaver. PAUL GERARD, Chairman of PGAM, has over 40 years of investment experience. Paul earned a B.S. from the University of California, Berkeley, and an M.B.A. from New York University Graduate School of Business Administration. Paul is a CFA® Charterholder and is a member of the New York Society of Security Analysts (NYSSA).Prior to forming PGAM, Paul was a Managing Director and Senior Portfolio Manager for BlackRock/Merrill Lynch Investment Managers from 1986 to 2007. (Merrill Lynch Investment Managers (MLIM) combined with BlackRock in 2006.) Paul was a member of the domestic Investment Policy and Strategy Committee and served as Chairman of the International Policy and Strategy Committee. Before joining MLIM in 1986, Paul was associated with Equitable Investment Management Corporation in New York for 13 years. BRETT M. SHAVER is President and Portfolio Manager of PGAM. As a leader of the Investment Team, Brett focuses on providing customized investment advice to PGAM’s clients. Prior to joining PGAM in 2016 as a Partner, Brett was a Senior Research Analyst for BlackRock and managed the fundamental investment analysis within the Technology, Consumer and Energy sectors for large cap equity strategies. Before joining BlackRock via the combination with Merrill Investment Managers in 2006, Brett served as a generalist fundamental analyst on a team led by President and Chief Investment Officer of MLIM and served as an analyst for equity and balanced separately managed accounts. Brett earned a BSBA degree from Bucknell University in 2002 where he majored in Management and minored in Economics. Brett is a CFA® Charterholder and is a member of the CFA Society New York. In 2015 he completed the Columbia University Graduate School of Business Executive Education program in Financial Analysis and Valuation. ERICA S BULLINGER is Chief Operating Officer of PGAM, primarily responsible for the day-to- day operations of the firm. Prior to joining PGAM in 2025, Erica was a Managing Director and Product Strategist for BlackRock, responsible for product management for the Global Allocation Platform across retail and institutional clients globally. Erica joined BlackRock as part of the 2007 analyst class, and held different roles within the product strategy group during her 18 years with the firm. Erica earned a BS degree from Villanova University in 2007 where she majored in Finance and Economics. She is a CFA® Charterholder and is a member of the CFA Society New York. Investment Management Services: PGAM furnishes “investment supervisory services,” defined as giving continuous advice to Clients on the investment of their funds based on their individual needs. We provide US, International and Global investment strategies that are customized to our Clients’ investment objectives and needs through equity, fixed income and balanced accounts. Our customization considers risk tolerance, time horizon, liquidity needs, tax considerations, and Client directed restrictions such as, but not limited to, social concerns, and all other pertinent issues of our Clients. We provide investment advice based on information Clients provide us about personal, financial and tax statuses, and investment objectives and policies, as well as any updates or changes to their information. We impose no restrictions on the ability of Clients to contact and consult with us. Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 5 Use of Independent Managers: In certain situations, PGAM may allocate a portion of their clients’ assets by and/or among certain independent investment managers (“Independent Managers”), based upon the stated investment objectives of the client. Currently, PGAM uses certain managers for municipal bond management and income enhancement and option overlay strategies. Thes Independent Managers are accessible through Schwab’s Managed Account Marketplace. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between PGAM, the client and the designated Independent Managers. PGAM monitors and reviews the account performance and investments to ensure they align with the client’s investment objectives. PGAM Clients also receive each Independent Manager’s ADV Brochure. Pension/Endowment/Foundation Consulting Services PGAM also provides investment planning, implementation advice, and portfolio management recommendations to primarily an institutional client base. Typical clients include corporate and public retirement plans; foundations and endowments. As part of its services, PGAM works with its clients to develop Investment Policy Statements, asset allocation models and investment manager recommendations which are tailored to the individual needs of clients. PGAM delivers comprehensive written reports for review and discussion, on a monthly and quarterly basis, which include performance evaluations of each investment manager, and each portfolio; comparative performance for established benchmarks, and for peer institutions; assessment of asset allocation and need, if any, for rebalancing. PGAM does not participate in wrap fee programs. AUM/AUA As of December 31, 2024, PGAM maintained approximately $782 million in clients’ assets under management (AUM) primarily on a discretionary basis. In addition, PGAM provides consulting advisory services to more than $58 Millon, on an asset under advisement basis (AUA). Collectively PGAM provides advisory services to more than $840 million in client assets. Investment Management Services for “Held Away” Accounts We offer an additional investment management service for “Held Away accounts,” such as 401(k), 403(b) plan accounts. We use a third-party platform, Pontera, to leverage an Order Management System to implement asset allocation and opportunistic rebalancing strategies on behalf of clients. We regularly review the available investment options in these accounts, monitor them, and rebalance and implement our strategies in the same way we do other accounts, though using different tools, as necessary. A link will be provided to Clients allowing them to connect account(s) to the platform. Once a client’s account is connected to the platform, we will review the current account allocations. When deemed necessary, we will rebalance the account considering the Client’s investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed and allocation changes will be made as deemed necessary. The Pontera’s platform allows us to avoid having custody of Clients’ funds Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 6 since we do not have direct access to Client log-in credentials. We are not affiliated with Pontera and receive no compensation from Pontera for using their platform. Financial Planning Services: PGAM provides its clients with financial planning and consultation services (e.g., review of goals and objectives, analysis and recommendations for cash flow planning, asset allocation/investment planning, income tax planning, insurance planning, estate planning, retirement planning, education planning, real estate/mortgage planning, etc.). Estate Planning Services: Through our partnership with an independent third-party technology company, Wealth, Inc. ("Wealth”), PGAM can facilitate the preparation of various estate planning documents for clients. Such services are generally separate from any investment management and/or financial planning services that we may render to a client, and the exact scope of such estate planning services will depend on the nature of a client’s specific estate planning needs. As a condition of utilizing Wealth, you must agree to the terms and conditions available at wealth.com. PGAM may pay for your access to Wealth. For the avoidance of doubt, neither PGAM nor Wealth render legal advice or services. Wealth offers the ability to consult with licensed attorneys in various jurisdictions at an additional charge, and subject to additional terms Item 5: Fees and Compensation PGAM’s fees are generally charged in arrears on a quarterly basis as a percentage of assets under management. However, upon agreement between a Client and PGAM, fees may also be charged in advance, on a schedule other than quarterly, or at a fixed rate. When charged as a percentage of assets under management, fees are calculated based on the quarter end’s market value as determined by the Client’s custodian. This market value is multiplied by the agreed upon annual fee percentage. One quarter (¼) of this annual fee will then be charged. Fees are usually deducted from the Client's account by the custodian with the Client’s prior authorization upon receipt of an invoice from PGAM and transferred to PGAM. However, other methods of payment, such as payment from another account, are possible. Clients may incur brokerage commissions, other trade-related fees, custodian fees, and fees associated with any investment company securities (e.g., closed- or open-end mutual funds and ETFs) their accounts may contain. Clients also have the option to purchase investment products that PGAM recommends through other brokers or agents that are not affiliated with PGAM. Further details about our brokerage practices can be found in Item 12: Brokerage Practices. Independent Manager utilized by PGAM assess an advisory fee in addition to PGAM’s advisory fee. Such fee is debited separately and paid directly to the Independent Manager. The terms and conditions of these fees are set forth in the agreement between the client and the Independent Manager. PGAM’s advisory fees are generally negotiated based on a number of factors including, but not limited to, the size and type of account, securities held, strategies implemented, and the number and types of Client restrictions applied. However, PGAM will not assess any advisory fee in excess of 1.50%. Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 7 Clients can terminate their Discretionary Management Agreement with PGAM at any time. In the event an Agreement includes a fee paid in advance and is terminated before a fee period’s end, any unearned fee will be returned to the Client by a mutually agreed upon method. Financial Planning Fees: PGAM’s financial planning and consulting fees are negotiable, but generally are $300 on an hourly rate basis, and from $1,000 to $25,000 on a fixed fee basis, depending upon the level and scope of the service(s) required and the professional(s) rendering the service(s). Prior to engaging PGAM to provide financial planning or consulting services, clients will be required to enter into a Financial Planning Agreement with PGAM setting forth the terms and conditions of the engagement, describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to PGAM commencing services. Item 6: Performance Based Fees and Side-By-Side Management PGAM does not charge performance-based fees. Item 7: Types of Clients PGAM serves individual, high net worth individuals, pension, retirement and profit-sharing plans partnerships, estates, trusts and corporations. PGAM generally maintains a minimum account value of $1 million, however it reserves the right to negotiate this and other conditions for starting or maintaining an account. We also reserve the right not to provide investment advisory services to a Client when it is not in the Client’s or our best interests. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss PGAM’s primary method of analysis is fundamental analysis. We also consider global market conditions, country and regional fiscal and monetary policies, macro-economic developments, currency trends, and geo-political environments. Our main sources of information include financial newspapers and magazines, inspections of corporate activities, research materials provided by others, corporate rating services, and companies’ press releases, annual reports, prospectuses, and filings with the Securities and Exchange Commission. We also utilize local and global general news sources, internet-based services, academic, governmental, and international organizations’ research and reports. The types of investments and investment strategies utilized by PGAM vary depending on the particular investment objectives and restrictions selected by our Clients. We provide US, International and Global investment strategies that are customized to our Clients’ investment objectives through diversified equity, fixed income and balanced separately managed accounts. We consider a US investment strategy to invest primarily in US domiciled entities. We consider an International investment strategy to invest primarily in non-US domiciled entities, and a Global investment strategy to invest in a mix of both US and non-US domiciled entities. To execute these strategies, we may purchase exchange-listed securities, including American Depository Receipts (“ADRs”) and Exchange Traded Funds (“ETFs”), securities traded over-the- counter, securities issued by foreign issuers, warrants, corporate debt securities, certificates of deposits, Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 8 municipal securities, mutual fund shares, United States government securities, and foreign bonds issued or guaranteed by foreign governments and international organizations. International and Global investment strategies contain special risks and circumstances involved in investing in foreign securities, including but not limited to currency fluctuations, political and economic instability, and expropriation, confiscatory or withholding taxation practices of foreign governments. There may also be reduced availability of public information about issuers, including but not limited to less accounting and financial reporting. Foreign financial markets may be less liquid and more volatile and may be subject to less regulation than US markets. Investing in foreign markets may also involve settlement delays and higher commission and transaction costs. An International Equity or Balanced Investment Strategy, and the non-US securities component of a Global Equity or Balanced Investment Strategy, are invested primarily in ADRs. The number of ADRs available with respect to a given country or region may not be representative of that country or region’s proportionate share of the world securities market. Direct investments in some non-US securities may be prevented or made impractical by factors including federal, state or local country law or regulation. In addition, these strategies may not be diversified across industry sectors. Trading in Client accounts may be long-term or short-term. Depending on the investment objective selected, and the level of customization involved, annual account turnover of an account may be minimal or substantial. PGAM does not guarantee the future performance of any investment strategy or any specific level of performance, the success of any investment recommendation or strategy, or the success of PGAM’s overall management of a strategy. PGAM’s investment recommendations are subject to various markets, currency, economic, political and business risks. Past performance is not a guarantee of future results and our investment decisions and strategies will not always be profitable. Item 9: Disciplinary Information There are no disclosable legal or disciplinary events associated with PGAM or its supervised personnel. Item 10: Other Financial Industry Activities and Affiliations Receipt of Insurance Commission Certain of PGAM’s Supervised Persons, in their individual capacities, are also licensed insurance agents with various insurance companies, and in such capacity, may recommend, on a fully- disclosed commission basis, the purchase of certain insurance products. While PGAM does not sell such insurance products to its investment advisory clients, PGAM does permit its Supervised Persons, in their individual capacities as licensed insurance agents, to sell insurance products to its investment advisory clients. A conflict of interest exists when PGAM’s Supervised Persons recommends insurance products and receives compensation. Any such contemplated transaction is fully disclosed to the client, including all compensation terms. Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 9 Pontera Platform PGAM is not affiliated with Pontera in any way and receives no compensation from Pontera in connection with our use of the Pontera Platform. Clients are advised that our management of accounts via the Pontera Platform is subject to the limitations and restrictions imposed by the underlying sponsor, issuer, and/or custodian of the client’s held-away assets. For example, our instructions to rebalance holdings within your held-away account through the Pontera Platform may not be implemented by the account sponsor, issuer, or custodian for up to one (1) business day or more following entry. We may also not be able to view real-time account value and holdings data over the Pontera Platform. Clients understand that our investment of the assets held within such accounts is limited to allocation of the client’s assets among the various investment options made available by the account sponsor, issuer, or custodian. Upon entering into an agreement for advisory services with us, clients authorize us to use unrelated third-party service providers (including Pontera) to service their account(s). We require unrelated third-party service providers to execute a confidentiality agreement and not share client information with any unauthorized person or entity. The use of unrelated third-party service providers will not cause the client to incur any additional fees. We pay unrelated third-party service providers (including Pontera) for services out of the total advisory fee charged to the client. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading PGAM enforces Compliance Policies and Procedures which include Insider Trading and Personal Trading Policies. These policies require pre-clearance procedures, and transaction, holdings and account monitoring that are designed to prevent potential conflicts of interest and the infringement of statutory and other rules relating to trading and similar activities. Each employee who makes investment recommendations or decisions for Clients, who participates in the determination of such recommendations or decisions, or who, in connection with their duties, obtains information concerning which securities are being purchased or sold or recommended for such action, must comply with the applicable requirements and restrictions of our Compliance Manual of Policies and Procedures. Among other restrictions, our employees' personal trading may not be executed on the basis of information that is not generally available to the investing public. In addition, our employees are prohibited from trading securities which are under consideration for purchase or sale by PGAM’s Investment Committee before the Committee’s decision to purchase or sell the securities is made. These and other restrictions are designed and enforced in order to established and maintain the primacy of our Clients’ interests above all else. PGAM’s Code of Ethics is intended to reflect fiduciary principals that govern the conduct of PGAM Employees in general and in those situations where PGAM provides investment advice to Clients in particular. Our Compliance Manual consists of policies and procedures regarding several key areas: standards of conduct and compliance with laws, rules and regulations, safeguarding Client and PGAM information and privacy, insider trading, personal securities trading, and our Code of Ethics. Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 10 PGAM maintains and enforces a Privacy Policy. PGAM respects our Clients’ right to keep their personal information confidential and understands their desire to avoid unwanted solicitations. Unless compelled by a validly issued and enforceable subpoena or summons, PGAM will not disclose personal information about our Clients or former Clients to anyone without their authorization. We also restrict access to non-public personal information about our Clients to employees of our firm and other parties who must use that information to provide services to our Clients. Item 12: Brokerage Practices PGAM may select brokers which provide us with research or other transaction-related services. However, PGAM does not participate in “soft-dollar” arrangements with any broker. That is, PGAM does not accumulate soft dollar credits with any broker, and any benefits PGAM may receive from any broker, such as obtaining research or any other goods or services, is not contingent upon any level of commission generation or trading activity. PGAM recommends custodians and/or brokers that we reasonably believe will provide the best execution of services, including trading. PGAM generally will seek competitive commission rates but will not necessarily attempt to obtain the lowest possible commission for transactions. In selecting brokers for a particular transaction, PGAM may consider all relevant factors, including the execution capabilities required by the transaction, the importance of speed, efficiency or confidentiality, familiarity with sources from whom or to whom particular securities might be purchased or sold, as well as any other relevant matter. Consistent with obtaining best execution, transactions for a Client’s account are directed to brokers that furnish PGAM with research or other services regardless of the amount of commissions and trade activity generated by the relationship between PGAM and the broker. Such research or other services benefit all of PGAM’s Clients and brokerage commissions paid by a particular Client for a particular transaction do not benefit that particular Client but all of PGAM’s Clients. PGAM may, in its discretion, cause a Client to pay brokers a commission greater than another qualified broker might charge to effect the same transaction where PGAM determines in good faith that the commission is reasonable in relation to the value of the brokerage services received. It is also usual for custodians to provide certain products and services to investment advisers in order to facilitate business between them. For example, custodians may provide PGAM with software for downloading information into our account management and accounting systems and submitting client trades. They may also provide us with services such as practice management and compliance assistance depending on the total value of Client assets held with the custodian. PGAM may also utilize any custodian's research products and services. PGAM does not accept Client referrals from brokers or custodians in consideration for selecting brokers or custodians for services. PGAM may recommend custodians and/or brokers to Clients and Clients may designate their own if PGAM agrees. It is usually anticipated that all or a significant amount of brokerage transactions for a Client’s account will be placed through the custodian of the Client’s account if the custodian is also the broker and the account is a retail brokerage account. In the event a Client directs PGAM to use a particular custodian Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 11 and/or broker, it is made clear to the Client in writing that PGAM may not have the authority to negotiate commissions, obtain volume discounts, aggregate that Client’s orders or ensure best execution, and that there may be a disparity in commission charges with other Clients. Transactions for each Client generally will be effected independently on a rotational allocation basis. To the extent permitted by law, PGAM shall also be permitted to, but is not obligated to, combine trade orders to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among PGAM’s Clients. Clients may experience differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transaction prices and costs are shared equally on a pro-rata basis between all accounts in any such combined trade order. Item 13: Review of Accounts Under the direction of the Chief Investment Officer, members of the PGAM Investment Committee review select accounts on a daily basis for cash flows, security additions or withdrawals, trade settlement, corporate action processes, trading to model, and other account-appropriate operational processes. Selection of accounts is based on several factors such as its status of bringing the account to model or restrictions, account specific circumstances such as expected inflows or outflows of securities and/or cash, or any other circumstances unique to the account. All accounts are reviewed on a monthly basis for cash flows, security additions or withdrawals, trade settlement, corporate action processes, and trading to model. They are reviewed on a quarterly basis for adherence to investment objective, asset allocation, stage of implementation of investment strategy, and other account-appropriate management requirements. The Chief Operating Officer is also responsible for monitoring accounts for cash flows, security additions or withdrawals, trade settlement, corporate action processes, and other account-appropriate operational processes. Unscheduled reviews are triggered by changes to a holding's fundamentals, or a Client's circumstances such health, employment, family, etc. At a minimum, each PGAM Client receives on a quarterly basis a written report of account holdings, market value and advisory fees. Clients may also receive interpretive comments on investment positions and the general investment environment. Such reports and commentaries are always provided to Clients upon request. Clients may also receive transaction confirmations and monthly, or on another frequency, statements from brokers and their custodians. Item 14: Client Referrals and Other Compensation PGAM is required to disclose any relationship or arrangement where it receives an economic benefit from a third party (non-client) for providing advisory services. PGAM may receive economic benefits from non-clients for providing advice or other advisory services to clients. This type of relationship poses a conflict of interest and any such relationship is disclosed in response to Item 12, Brokerage Practice, see above. Princeton Global Asset Management LLC (IARD#146644) May 2025 Page 12 Item 15: Custody PGAM primarily does not maintain physical custody of client assets. All client assets are custodied with nationally recognized, SEC registered and FINRA member broker-dealer/custodians. Clients are provided with transaction confirmation notices and regular summary account statements directly from the broker-dealer/custodian of the client accounts. PGAM provides a report summarizing account activity, positions and performance. Clients are advised that the custodian statement is the official record of their account(s) and PGAM’s reporting is for informational purposes only. PGAM is deemed to have custody of client funds solely because it has the ability to authorize the custodians to debit its Advisory Fee but otherwise PGAM has no ability to access client funds. Item 16: Investment Discretion Clients usually grant PGAM discretionary trading authorization and appoint PGAM as agent and limited attorney-in-fact with respect to their accounts. However, Clients may impose investment restrictions or other special instructions as described in Item 4: Advisory Business. When necessary and appropriate, Clients agree to sign a “Limited Powers of Attorney” or “Trading Authorization” as may be required by their custodian and/or broker. Pursuant to such agreement(s), PGAM is authorized to purchase, sell, exchange and otherwise trade in the securities and other investments in the Client’s account(s) and act on behalf of the Client in all other matters necessary or incidental to the handling of the Client’s account. Item 17: Voting Client Securities Generally, PGAM will not vote proxies of securities in Client accounts. If PGAM agrees to a Client’s request for PGAM to vote proxies, PGAM will vote proxies in accordance with our Proxy Policy and Procedures. In general, PGAM will act prudently, taking into consideration those factors that may affect the value of the security, and will vote such proxies in a manner that, in our opinion, is in the best interest of the Client. Information about how PGAM voted proxies will be available to the Client upon request. PGAM will provide a copy of our Proxy Policy and Procedures upon request. Item 18: Financial Information PGAM is not required to provide a balance sheet for our most recent fiscal year as we do not require or solicit prepayment of more than $1,200 in fees per Client six months or more in advance.