Benjamin Tyler West

The amount of fees you pay us will depend on the services we provide you. Our advisory fees are negotiable, though retirement plan managed account fees may be negotiated at the plan sponsor level, not at the individual plan participant level. PCIA’s fees vary among clients for the services provided due to such differing client needs, circumstances, objectives, services, and other factors that are deemed at the time to be relevant. We utilize wrap fee and non-wrap fee programs to provide asset management. Under a wrap fee program, the fee you pay us covers both our advisory services and the transaction fees imposed by the broker-dealer. Under a non-wrap fee program, you will be charged transaction costs separately. Since a wrap fee covers transaction expenses it tends to be higher than non-wrap fee programs. Our asset-based advisory fees for services to retail investors and retirement plan participants are charged on a monthly or quarterly (most often) basis, in arrears (most often) or in advance. Performance-based fees are most often charged in arrears on a quarterly and semi-annual basis. Your exact fee amount and terms will be specified in your agreement with PCIA.

• Fees for PCIA’s Wrap Fee Management Program (for Asset Management Services): PCIA’s annual advisory fee for asset management services under this Program, excluding (1) PCIA’s Covered Calls Strategy (CCS) and (2) such services pursuant to a Performance-Based Advisory Services Agreement, most often ranges between 1.00% and 1.50%, but will not be below 0.25% or above 2.50%. The annual advisory fee for CCS ranges between 1.50% and 2.20%. The annual advisory fee for “performance-based” asset management services is 0.70% for the Opportunistic Growth Strategy and 1.50% for the Absolute Return Strategy, plus 20% of capital appreciation subject to high-water mark provision.

• Fees for PCIA’s Wrap Fee Management Program (for Limited/Limited Scope Advisory Services): The annual PCIA Wrap Fee rate (%) under this Program is .06% (6 Bps) or $24, whichever is greater.

• Fees for PCIA’s Managed Account Allocations for individuals and certain Retirement Plan Participants: PCIA’s standard annual fee for retirement plan participant managed account allocations generally ranges from 0.10% to 1.00%, and from 0.50% to 1.50% for individuals.

• Fees for PCIA’s Financial Planning Services: PCIA’s annual fees for financial planning services most often range between $500 and $5,000 (or as an equivalent percentage), but will not exceed $25,000, and can be on an annual recurring or a monthly subscription basis depending on your arrangement with PCIA.

• Fees for PCIA’s Recommendation and Selection of Third-party Money Managers and Subadvisors: The portion retained by PCIA in the form of advisory fees will not exceed 1.50%; however, the overall management fee charged by the third-party money manager, which includes the advisory fee retained by PCIA, can and often exceeds 1.50%. PCIA’s annual fee for advisory services provided in connection with a sub-advisory arrangement most often ranges between 0.50% and 1.50%, but will not be below 0.25% or above 1.85%. Such fees are generally charged quarterly, in arears.

• Fees for PCIA Seminars: PCIA will not charge an attendee a seminar fee greater than $499. Such fees are charged on a one-time basis.

• Other Fees and Costs: PCIA’s advisory fees do not include fees and expenses charged by investment company securities that may be recommended to you. A description of these fees and expenses is available in each investment company security’s prospectus. Our advisory fees do not include fees charged by third-party money managers and subadvisors. Please refer to these firm’s disclosure brochures for more information about their fees. Our advisory fees also do not include other fees and expenses charged by third parties (including your custodian). Please review your custodian’s agreement.

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

Please see Item 5 of PCIA’s Form ADV Part 2A, Item 4 of PCIA’s Part 2A Appendix 1 - Wrap Fee Program Brochure for Asset Management Services, or Item 4 of PCIA’s Part 2A Appendix 1 - Wrap Fee Program Brochure for Limited Advisory Services, for more information about our standard advisory fees and expenses.

Standard of Conduct: When we act as your investment adviser, we have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means. When we charge “asset-based fees” (most common), we have an incentive to encourage the retail investor to increase the assets in his or her account. This is a conflict of interest. Such arrangements also create an incentive to charge an ongoing investment fee without providing any substantive ongoing investment services. “Performance-based Fee” arrangements create additional conflicts of interest, such as taking unnecessary speculation with client assets in order to earn or increase the amount of the fee. We have a conflict of interest by only offering those third-party money managers that have agreed to pay a portion of their advisory fee to us. A conflict of interest arises when we, including your financial professional, receive expense reimbursement for travel and/or marketing expenses from product distributors and third-party providers. A conflict of interest also arises when PCIA makes recommendations about plan distributions and rollovers (“rollover recommendations”), if it results in PCIA receiving compensation that it would not have received absent the recommendation. PCIA has an affiliate named PCRM, LLC that is an insurance agency. PCRM, LLC will often times receive override commissions on the sale of insurance products which is a conflict of interest. Please see Items 5, 6, and 14 of PCIA’s Form ADV Part 2A, Items 4 and 9 of PCIA’s Part 2A Appendix 1 - Wrap Fee Program Brochure for Asset Management Services, or Items 4 and 9 of PCIA’s Part 2A Appendix 1 - Wrap Fee Program Brochure for Limited Advisory Services, for more information about the conflicts of interest associated with our services and how we control or mitigate them.

We compensate our investment adviser representatives based on the level of assets that the representative brings in to us. This creates a conflict of interest as it gives your representative an incentive to recommend you invest more in your account with us due to the potential for increased payments. Your financial professional will also be faced with the same conflicts of interest referenced above in Item 3 of this Form CRS. Some of PCIA’s investment adviser representatives also earn commissions by selling securities, insurance products, or both, in a separate and independent capacity. This receipt of commissions creates a conflict of interest. Please see Item 14 of PCIA’s Form ADV Part 2A, Items 4 and 9 of PCIA’s Part 2A Appendix 1 - Wrap Fee Program Brochure for Asset Management Services, or Items 4 and 9 of PCIA’s Part 2A Appendix 1 - Wrap Fee Program Brochure for Limited Advisory Services, for more information about the conflicts of interest associated with our financial professionals’ receipt of additional compensation and economic and non‐economic benefits, how they make money, and how we control or mitigate these conflicts.