PKSA’s philosophy centers on a belief that each client has specific investment needs, and that these needs can only be met by a careful study of their particular profile. Founded in October 2001, PKSA provides financial planning, consulting, and investment management services to its clients. PKS Holdings, LLC is the principal owner of PKSA. Pamela S. Young is the President of the firm. Prior to engaging PKSA to provide any of the foregoing investment advisory services, the client is required to enter into one or more written agreements with PKSA setting forth the terms and conditions under which PKSA renders its services (collectively the “Agreement”). PKSA has $697,742,374 of assets under management as of January 2, 2024, $666,213,057 of these assets are managed on a discretionary basis, and $31,529,317 are managed on a non-discretionary basis. This Disclosure Brochure describes the business of PKSA. Certain sections will also describe the activities of Supervised Persons. Supervised Persons are any of PKSA’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), or employees, or any other person who provides investment advice on PKSA’s behalf and is subject to PKSA’s supervision or control. Financial Planning and Consulting Services PKSA provides its clients with a broad range of comprehensive financial planning and consulting services. These services include education, retirement, disability, long term care, estate analysis, investments, and tax and cash flow needs of the client. These services may be included as part of PKSA’s investment management services, described below. In performing its services, PKSA is not required to verify any information received from the client or from the client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized to rely on such information. PKSA recommends the services of itself, its Supervised Persons in their individual capacities as registered representatives of a broker-dealer, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if PKSA recommends its own services. The client is under no obligation to act upon any of the recommendations made by PKSA under a financial planning or consulting engagement or to engage the services of any such recommended professional, including PKSA itself. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any of PKSA’s recommendations. Clients are advised that it remains their responsibility to promptly notify PKSA if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising PKSA’s previous recommendations and/or services. Page 5 © MarketCounsel 2024 Investment Management Services Clients can engage PKSA to manage all or a portion of their assets on a discretionary or non- discretionary basis. As detailed in Item 8, PKSA primarily allocates clients’ investment management assets among mutual funds, independent investment managers (“Independent Managers”), exchange- traded funds (“ETFs”), and individual debt and equity securities in accordance with the investment objectives of the client. However, PKSA may provide advice about any type of investment held in clients' portfolios. Where appropriate, PKSA recommends products to its clients for which its affiliated broker- dealer, Purshe Kaplan Sterling Investments (“PKS”) earns compensation in connection with purchases. As a result, a conflict of interest exists because PKSA has an incentive to recommend products to clients for which PKS earns compensation in connection with such recommendations. Nonetheless, PKSA has policies and procedures in place to ensure that such recommendations are made only when they are in the best interest of clients. PKSA also renders non-discretionary investment management services to clients relative to variable life/annuity products that they own, their individual employer-sponsored retirement plans, and/or 529 plans or other products that are not held by the client’s primary custodian. In so doing, PKSA either directs or recommends the allocation of client assets among the various investment options that are available with the product. Client assets are maintained at the specific insurance company or custodian designated by the product. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios, but clients should not assume that these assets are being continuously monitored or otherwise advised on by the Firm unless specifically agreed upon. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage PKSA for additional services for compensation, including rolling over retirement accounts or moving other assets to the Firm’s management. Clients retain absolute discretion over all decisions regarding engaging the Firm and are under no obligation to act upon any of the recommendations. PKSA tailors its advisory services to the individual needs of clients. PKSA consults with clients initially and on an ongoing basis to determine

risk tolerance, time horizon and other factors that may impact the clients’ investment needs. PKSA ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. Clients are advised to promptly notify PKSA if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon PKSA’s management services. Clients may impose reasonable restrictions or mandates on the management of their account (e.g., require that a portion of their assets be invested in socially responsible funds) if, in PKSA’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Page 6 © MarketCounsel 2024 Use of Independent Managers As mentioned above, PKSA recommends that certain clients authorize the active discretionary management of a portion of their assets by and/or among certain Independent Managers, based upon the stated investment objectives of the client. The terms and conditions under which the client engages the Independent Managers are set forth in a separate written agreement between PKSA or the client and the designated Independent Managers. PKSA renders services to the client relative to the discretionary and/or non-discretionary selection or recommendation of Independent Managers. PKSA also monitors and reviews the account performance and the client’s investment objectives. PKSA receives an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the designated Independent Managers. When recommending or selecting an Independent Manager for a client, PKSA reviews information about the Independent Manager such as its disclosure brochure and/or material supplied by the Independent Manager or independent third parties for a description of the Independent Manager’s investment strategies, past performance and risk results to the extent available. Factors that PKSA considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, may be exclusive of, and in addition to, PKSA’s investment advisory fee set forth above. As discussed above, the client incurs additional fees than those charged by PKSA, the designated Independent Managers, and corresponding broker-dealer and custodian. In addition to PKSA’s written disclosure brochure, the client also receives the written disclosure brochure of the designated Independent Managers. Certain Independent Managers may impose more restrictive account requirements and varying billing practices than PKSA. In such instances, PKSA may alter its corresponding account requirements and/or billing practices to accommodate those of the Independent Managers. If PKSA refers a client to an Independent Manager where PKSA’s compensation is included in the advisory fee charged by such Independent Manager and the client engages the Independent Manager, PKSA may be compensated for its services by receipt of a fee to be paid directly by the Independent Manager to PKSA in accordance with the requirements of Rule 206(4)-3 of the Investment Advisers Act of 1940, as amended, and any corresponding state securities laws, rules, regulations, or requirements. Any such fee is paid solely from the Independent Manager’s investment management fee, and does not result in any additional charge to the client. Page 7 © MarketCounsel 2024 Fiduciary Acknowledgment in IRA Accounts This acknowledgment applies to any client account that is an Individual Retirement (IRA) Account governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”), and/or and the Internal Revenue Code of 1986, as amended. When PKSA or one of its Supervised Persons provides investment advice to a client regarding their retirement plan account or individual retirement account, PKSA and/or its Supervised Persons are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way PKSA makes money creates some conflicts with client interests, so PKSA operates under a special rule that requires the Firm to act in the client’s best interest and not put the Firm’s interest ahead of the client’s. Under this special rule’s provisions, PKSA must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put the Firm’s financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that PKSA give advice that is in the client’s best interest;
• Charge no more than is reasonable for PKSA's services; and
• Give clients basic information about conflicts of interest.