Pinnacle Wealth Planning Services, Inc. (“Pinnacle”) is a SEC-registered investment adviser who began conducting business in 1998. Pinnacle is headquartered in Mansfield, Ohio with additional offices in Medina and Columbus, Ohio and St. Petersburg, Florida. Pinnacle is a family-owned company currently serving the wealth management needs of clients in 34 states. Pinnacle is currently owned in equal shares in trusts for the benefit of Keith Heichel, President & CEO, Jennifer Henderson, COO & CCO, David Heichel, VP-Marketing, Scott Heichel, CIO and Adam Heichel. Pinnacle offers several advisory services to our clients. Our firm requires that individual clients utilize our wealth management programs, which include financial planning or educational services in order to utilize our other advisory services so that we will have the information needed in order to make well informed decisions in the best interest of our clients. Pinnacle bundles financial planning with investment advisory and quarterback services to form our formal Wealth Management Services. However, each service is described and disclosed individually within this document.
• Formal Wealth Management Programs
• Informal Wealth Management Program
• Financial Planning
• Investment Advisory Services
• Independent Managers
• Quarterback Service
• Asset Tracking and Performance Reporting Service
• Pension Consulting Services AMOUNT OF MANAGED ASSETS As of 12/31/2022, Pinnacle was actively managing $1.6 billion of total client’s assets. $1.5 billion of client’s assets are managed on a discretionary basis and $10 million of clients' assets are managed on a non-discretionary basis. Pinnacle also provided investment consulting services on an additional $9.6 million to self-directed retirement plan participants. WEALTH MANAGEMENT PROGRAMS To service the various planning needs of our clients, business owners and their families, Pinnacle designed and now offers four (4) formal Wealth Management Programs and one (1) informal program. Our formal programs: Compass, Lifetime, Enhanced and Family Office, include varying levels of financial planning services, investment advisory services, independent manager selection, client portal and quarterback administration services. Our informal program offers financial planning education, planning coordination and investment advisory services. See descriptions below, and corresponding program fee schedules, including minimum annual fees, at Item 5 below. Formal Wealth Management Programs 1. Compass Wealth Management Program: A service designed for clients with a net worth under $1,500,000 with liquid investable assets of $250,000 to $750,000. Program Includes: Financial plan with one (1) annual planning meeting, investment advisory services with utilizing Pinnacle models at the account level, basic quarterback services and client portal. 2. Lifetime Wealth Management Program: A service designed for clients with a net worth $1,500,000 to $3,000,000 and income under $250,000. Program Includes: Financial plan with two (2) annual planning meetings + one annual follow-up/review meeting, investment advisory services with household allocation/rebalancing, asset location, tax loss harvesting and/or individual managers, account aggregation, Lifetime Quarterback Services and client portal. 4 | P a g e 3. Enhanced Wealth Management Program: A service designed for clients with a net worth $3,000,000 to $10,000,000 and income of $250,000 to $1,000,000. Program Includes: Financial plan with three (3) annual planning meetings, investment advisory services with household allocation/rebalancing, asset location, tax loss harvesting and/or individual managers, account aggregation, Enhanced Quarterback Services and client portal. 4. Family Office Wealth Management Program: Our top level of service designed for clients with a net worth of $25,000,000+. Program Includes: Comprehensive financial plan with four (4) annual planning meetings with client and relevant professionals, quarterly pre-meeting coordination with client’s other professionals, investment advisory services with household allocation/ rebalancing, asset location, tax loss harvesting and/or individual managers, account aggregation, Family Office Quarterback Services and client portal. Informal Wealth Management Program Our Insight Program is an informal wealth management education program designed for relatives of current formal Wealth Management clients who do not require formal financial planning program yet, but would like to meet with an advisor who will provide financial planning education as well as basic investment management. Program includes: Annual meeting; Investment Advisory Services utilizing account level models, and a client portal with tools for budgeting, account aggregation and document storage. Inclusive Planning Services Pinnacle believes that it is important for the client to address financial planning issues on an ongoing basis. To the extent that planning services are included in Pinnacle’s advisory fee, as set forth at Item 5 below, Pinnacle’s fee will remain the same regardless of whether or not the client determines to address financial planning issues with Pinnacle. TRUST WEALTH MANAGEMENT PROGRAMS To assist Trustee’s with their fiduciary responsibilities, Pinnacle offers three (3) formal Trust Wealth Management Programs: Lifetime, Enhanced and Comprehensive, include varying levels of Trust Investment Advisory Services, Trust Longevity Planning Services, Trust Asset Tracking and Performance Reporting Service and Trust Administration Compliance Services. See descriptions below, and corresponding program fee schedules, including minimum annual fees, at Item 5 below. Trust Wealth Management Programs 1. Lifetime Trust Wealth Management Program: A service designed for trusts with minimal complications. Program Includes: Trust Longevity Planning with two (2) annual meetings, trust investment advisory services with rebalancing, asset location, tax loss harvesting and/or individual managers and account aggregation, Trust Administration Compliance Service and trust portal. 2. Enhanced Trust Wealth Management Program: A service designed for trusts with various complications. Program Includes: Trust Longevity Planning with three (3) annual meetings, trust investment advisory services with rebalancing, asset location, tax loss harvesting and/or individual managers and account aggregation, Trust Administration Compliance Service and trust portal. 3. Comprehensive Trust Wealth Management Program: A service designed for a trust with a business operating inside the trust. Program Includes: Trust Longevity Planning with four (4) annual meetings, trust investment advisory services with rebalancing, asset location, tax loss harvesting and/or individual managers and account aggregation, Trust Administration Compliance Service and trust portal. 5 | P a g e FINANCIAL PLANNING We offer financial planning as a stand-alone service or as a component of our wealth management services. Financial planning is an evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan, depending upon the client’s needs and direction, can address any or all of the following areas:
• PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals.
• TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability.
• INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
• INSURANCE: We review existing policies to ensure proper coverage for life, disability and long- term care.
• RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals.
• DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income.
• ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney and asset protection plans. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. We also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent engaged by the client to do so, Pinnacle will generally provide financial planning and related consulting services regarding non-investment related matters, such as retirement planning, tax planning, estate planning, insurance, etc. Pinnacle will generally provide such consulting services as part of one of its Wealth Management programs and/or on a stand-alone separate fee basis. Please Note: Pinnacle does not serve as an attorney, accountant or insurance agent, and no portion of our services should be construed as legal, accounting or insurance services. Accordingly, Pinnacle does not prepare estate planning documents or tax returns, nor does it sell insurance products. To the extent requested by a client, we may recommend the services of other professionals for certain non-investment implementation purposes (i.e. attorneys, accountants, insurance, etc.), including Pinnacle’s affiliated entity and/or representatives in their respective separate licensed capacities as an attorney and a CPA firm - see disclosure at Item 10 below. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from Pinnacle and/or its representatives. Please Also Note: If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged professional[s], and not Pinnacle, shall be responsible for the quality and competency of the services provided. Please Note. Pinnacle believes that it is important for 6 | P a g e the client to address financial planning issues on an ongoing basis. Pinnacle’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with Pinnacle. Family Office Services. Pinnacle is affiliated with Pinnacle Family Office, LLC, a wholly owned subsidiary business that provides non-investment advisory, administrative services, to Pinnacle clients as set forth on the Wealth Management Agreement between Pinnacle and the client. Pinnacle shares a portion of its fee with Family Office for those clients that receive such administrative services. The family office service is in addition to Pinnacle’s fees for the above Wealth Management Programs. Client Obligations. In performing its services, Pinnacle shall not be required to verify any information received from the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, each client is advised that it remains his/her/its responsibility to promptly notify Pinnacle if there is ever any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising Pinnacle’s previous recommendations and/or services. INVESTMENT ADVISORY SERVICES: INDIVIDUAL PORTFOLIO MANAGEMENT As a component of our Wealth Management Programs, our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We offer management of these advisory accounts on both a discretionary and a non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities: Equity securities, corporate debt, commercial paper, certificates of deposit, municipal securities, United States government securities, interests in partnerships in real estate and oil and gas interests. Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. Client Retirement Plan Assets. If requested to do so, Pinnacle shall provide investment advisory services relative to 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s employer. In such event, Pinnacle shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the 401(k) platform. Pinnacle’s ability shall be limited to the allocation of the assets among the investment alternatives available through the plan. Pinnacle will not receive any communications from the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify Pinnacle of any changes in investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for purposes of Pinnacle calculating its advisory fee. 7 | P a g e Please Note: Non-Discretionary Service Limitations. Clients that determine to continue to engage Pinnacle on a non-discretionary investment advisory basis must be willing to accept that Pinnacle cannot affect any account transactions without obtaining prior verbal consent to any such transaction(s) from the client. Thus, in the event that Pinnacle would like to make a transaction for a client’s account (including in the event of an individual holding or general market correction), and the client is unavailable, Pinnacle will be unable to affect the account transaction(s) (as it would for its discretionary clients) without first obtaining the client’s consent. Please Note: Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one

is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Pinnacle recommends that a client roll over their retirement plan assets into an account to be managed by Pinnacle, such a recommendation creates a conflict of interest if Pinnacle will earn new (or increase its current) compensation as a result of the rollover. No client is under any obligation to roll over retirement plan assets to an account managed by Pinnacle. Pinnacle’s Chief Compliance Officer, Jennifer Henderson, remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Please Note-Use of Mutual Funds/ETFs: Most mutual funds and exchange-traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that maybe utilized by Pinnacle independent of engaging Pinnacle as an investment advisor. However, if a prospective client determines to do so, he/she will not receive Pinnacle’s initial and ongoing investment advisory services. In addition to Pinnacle’s investment management fee described above, transaction and/or custodial fees discussed below at Item 5, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). Pinnacle’s Chief Compliance Officer, Jennifer Henderson, remains available to address any questions that a client or prospective client may have regarding the above. Please Note: Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended or undertaken by Pinnacle) will be profitable or equal any specific performance level(s). Please Note: Socially Responsible Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance considerations into the investment due diligence process (“ESG”). There are potential limitations associated with allocating a portion of an investment portfolio in ESG securities (i.e., securities that have a mandate to avoid, when possible, investments in such products as alcohol, tobacco, firearms, oil drilling, gambling, etc.). The number of these securities may be limited when compared to those that do not maintain such a mandate. ESG securities could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are few when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Pinnacle Wealth Planning Services, Inc.), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Pinnacle does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed, in writing, by a client to do so. 8 | P a g e TD Ameritrade, SEI and Mid Atlantic. As discussed below at Item 12, Pinnacle generally recommends that TD Ameritrade, SEI and Mid Atlantic Trust Company (for participant-directed retirement plans) serve as the broker-dealer/custodian for client investment management assets (although Pinnacle continues to manage limited amount of client accounts at other custodians such as Schwab and National Advisors Trust). Broker-dealers such as TD Ameritrade and SEI may charge brokerage commissions and/or transaction fees for effecting securities transactions. In addition to Pinnacle’s investment management fee, brokerage commissions and/or transaction fees, clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses). The fees charged by TD Ameritrade and SEI (or any other broker-dealer/custodian), as well as the charges imposed at the mutual fund and exchange traded fund level, are in addition to Pinnacle’s advisory fee referenced in Item 5 below. Portfolio Activity. Pinnacle has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, Pinnacle will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including, but not limited to, investment performance, market conditions, fund manager tenure, style drift, account additions/withdrawals, and/or a change in the client’s investment objective. Based upon these factors, there may be extended periods of time when Pinnacle determines that changes to a client’s portfolio are neither necessary nor prudent. Pinnacle’s advisory fee remains payable during periods of account inactivity. INDEPENDENT MANAGERS Pinnacle may allocate a portion of client assets among unaffiliated independent investment managers available on various custodian investment platforms. In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets. Pinnacle shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Please Note: The investment management fee charged by the Independent Manager[s], and any applicable platform fee, is separate from, and in addition to, Pinnacle’s advisory fee as set forth in the fee schedule at Item 5 below. ANY QUESTIONS: Pinnacle’s Chief Compliance Officer, Jennifer Henderson, remains available to address any questions that a client or prospective client may have regarding the allocation of account assets to an Independent Manager(s), including the specific additional fee to be charged by such Independent Manager(s). QUARTERBACK SERVICE As a component of our Wealth Management Services, we provide basic Quarterback Service. This service provides the administration and coordination of the investment and planning services in coordination with the client's other professional advisors. This basic service also includes a Client Wealth Management portal with access to the Client’s document vault, investment portfolio and financial plan, if applicable. Enhanced and Family Office Program clients receive an additional level of Quarterback services required by the complexity of their personal, business and financial situation. ASSET TRACKING AND PERFORMANCE REPORTING SERVICE Pinnacle may also provide periodic comprehensive reporting services, which can incorporate all of the client’s investment assets including those investment assets that are not part of the assets managed by Pinnacle (the “Excluded Assets”). Pinnacle’s service relative to the Excluded Assets is limited to reporting services only, which does not include investment implementation. Because Pinnacle does not have trading authority for the Excluded Assets, to the extent applicable to the nature of the Excluded 9 | P a g e Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not Pinnacle, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The client and/or his/her/its other advisors that maintain trading authority, and not Pinnacle, shall be exclusively responsible for the investment performance of the Excluded Assets. Without limiting the above, Pinnacle shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that Pinnacle provide investment management services (whereby Pinnacle would have trading authority) with respect to the Excluded Assets, the client may engage Pinnacle to do so pursuant to the terms and conditions of the Investment Advisory Agreement between Pinnacle and the client. RETIREMENT PLAN CONSULTING SERVICES Pinnacle provides retirement plan consulting services under the alternate name, Pinnacle Fiduciary Consulting Group (herein PFCG). PFCG offers retirement plan consulting services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan consulting services can include, but are not limited to, the following services: Fiduciary Consulting Services PFCG provides the following Fiduciary Retirement Plan Consulting Services:
• Assist the Client in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Provide non-discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. Client shall have the final decision-making authority regarding the initial selection, retention, removal and addition of investment options.
• Assist the Client with the selection of a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder.
• Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options.
• Meet with Client on a periodic basis to discuss the reports and the investment recommendations.
• Provide non-discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. The Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). PFCG acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. PFCG will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause PFCG to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services of a Section 3(21) advisor, PFCG (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to 10 | P a g e manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. If contracted specifically, PFCG may also provide full investment manager services as defined in Section 3(38) of ERISA which would give PFCG the additional authority to manage, acquire or dispose of plan assets. However, PFCG is still not the “Administrator” of Client’s retirement plan as defined in ERISA. Non-Fiduciary Services PFCG provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Client understands that Adviser’s assistance in participant investment education shall be consistent with and within the scope of (d) (i.e., the definition of investment education) of Department of Labor Interpretive Bulletin 96-1. As such, the Adviser is not providing fiduciary advice (as defined in ERISA) to the participants. Adviser will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan.
• Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non- fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Consulting Agreement. All recommendations of investment options and portfolios will be submitted to the client for the client’s ultimate approval or rejection. Therefore, it is always the client’s responsibility to accept investment recommendations of PFCG and then physically make changes to the plan itself. In the event a client contracts with PFCG for one-on-one consulting services with plan participants, such services are consultative in nature and do not involve PFCG implementing recommendations in individual participant accounts. It will be the responsibility of each participant to implement changes in the participant’s individual accounts. Retirement plan consulting services are not management services, and PFCG does not serve as administrator or trustee of the plan. PFCG does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). In addition, we do not implement any transactions in a retirement plan or participant’s account. For retirement plan consulting services, the retirement plan or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. PFCG will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b- 2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator 11 | P a g e (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Consulting Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission.