Pachira Investments Inc

ITEM 5: FEES AND COMPENSATION
A. Advisory Fees

CGAM charges fees based on a percentage of assets under management. The fee charged by
CGAM for its advisory services will be set forth in each client’s written agreement with CGAM.
Although CGAM believes its advisory fees are competitive, clients should be aware that lower
fees for comparable services can be available from other sources.

Asset Management Fees

CGAM generally charges an annual asset management fee, which is a flat percentage rate
determined upon engagement and based on the amount of a client’s assets managed by the Firm.
The percentage rate is negotiable and based on the following ranges:

                Assets Under Management                  Annual Advisory Fee
               0 to $999,999                             Up to 2%
               $1,000,000 to $2,999,999                  Up to 1.50%
               $3,000,000 to $9,999,999                  Up to 1.25%
               Over $10,000,000                          Up to 1.00%
When determining the amount of a client’s assets under management, CGAM will consider all
investment management accounts which constitute the "household" of the client’s assets.
Typically, a client's household consists of any spouse, parent, child, partner, or sibling.

The asset management fee is calculated and billed quarterly in advance based on the market
value (including cash, cash equivalents, accrued interests and dividends, and any margin
balance) of a client’s assets under management ("AUM") as of the close of business on the last
business day of the preceding calendar quarter.

Unless otherwise waived in CGAM’s sole discretion, the Firm requires a minimum account size
of $1,000,000 to open an account. CGAM reserves the right to waive or reduce any account
minimums, management fees and/or performance fees (as further described below) with respect
to any client and for any of the Firm’s employees and/or family members. Please note that the
Firm has clients with similar portfolios which are assessed different fees based on a variety of
factors, including account size, longevity of time as a CGAM client, investment strategy
employed, potential for providing additional assets to CGAM to manage and amount of
personalized servicing requested. All fees are subject to negotiation subject to CGAM’s sole
discretion. Furthermore, the Firm can negotiate fees with future advisory clients that are
different than the fees discussed herein.

The Clark Group Asset Management                                               March 4, 2026
Form ADV Part 2A
Should a client open an account during the quarter, management fees will be prorated for assets
held for a partial quarter based on the number of days that the account was open during the
quarter. In the event that CGAM's services are terminated mid-quarter, the annual fee shall be
prorated through the date of termination as defined in the Agreement and any earned, unpaid
balance will be immediately due and payable by client, and any pre-paid unearned fees will be
promptly refunded to the client. CGAM does not prorate fees for any partial additions and
withdrawals made during each billing quarter.

If a client has a margin account, our asset management fee will be based on the full value of the
account, including any margin balance. Clients need to be aware that having a margin balance
increases the amount of fees paid to us. This creates a conflict of interest as we have an
incentive to encourage use of margin. In addition, a client with a margin account is charged
margin interest by the custodian on the margin balance in the client’s account.

As authorized in the written client agreement, asset management fees are deducted from a
client’s managed account(s). At the beginning of each calendar quarter, CGAM sends a billing
statement to each client’s custodian for payment. Clients will receive a periodic (at least
quarterly) account statement from the custodian, reflecting among other things, any advisory
fees withdrawn by the custodian and paid to CGAM. Clients are urged to compare statements
received by third parties, such as the client’s custodian, with any statements sent by CGAM. For
more information on the reports CGAM provides to clients, please refer to Item 13, below.

Financial Planning Services Fees

For Financial Planning services, the Firm generally charges a fixed fee. The Firm’s fixed fees
can be assessed as a one-time fee, or an ongoing fee dependent upon the services received.
Generally, rates range from $2,000 to $10,000 on a fixed fee basis, based on the scope and
complexity of the requested services, as stipulated in the Agreement. These rates can be
negotiated based on the sole discretion of the Firm.

Clients are generally requested to pay 50% of the estimated fee upon execution of the
Agreement. An invoice for services is issued on completion of the written analysis, which is
payable upon receipt. Clients can terminate the Agreement, without penalty, at any time upon
written notice. At the time of termination, any prepaid fees will be prorated based on the amount
of work completed by the Firm as of the date, the notice of termination is received, and any
unearned fees will be returned to the client.
B. Other Fees and Expenses

Clients should understand that the advisory fees described in the sections above do not include
certain charges imposed by third parties such as custodial fees, mutual fund fees and expenses.
Client assets also can or will be subject to transaction costs, deferred sales charges on mutual
funds initially deposited in the account, 12b-1 fees, odd-lot differentials, transfer taxes, wire
transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions.

Client assets invested in mutual funds will be subject to certain fees and expenses imposed
directly by mutual funds to their shareholders, which shall be described in each fund's
...

ITEM 7: TYPES OF CLIENTS
A. Description

CGAM provides investment management and financial planning services to individuals,
pension and profit-sharing plans, trusts, estates, corporations and business entities.

B. Conditions for Managing Accounts

CGAM imposes a minimum account size of $1,000,000 but reserves the right to waive the
minimum or decline a potential client for any reason in its sole discretion. A Client can make
cash additions to and/or withdrawals from Client’s account(s) at any time. Client acknowledges
that cash will be made available for withdrawal only when transactions effected to raise cash are
settled. This could take several days dependent upon the type of investment and/or market
conditions.

Prior to engaging CGAM to provide any of the investment advisory services described in this
Brochure, the client will be required to enter into one or more written agreements with CGAM
setting forth the terms and conditions under which CGAM shall render its services.

When CGAM provides investment advice to a client, we are deemed a fiduciary under certain
federal regulations, and 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 the firm makes money creates conflicts of interest; however, as a
fiduciary, CGAM and our supervised persons are required to always act in our clients’ best
interests, which means we must, at a minimum take the following steps:

  •   Meet a professional standard of loyalty and care when making investment
      recommendations.
  •   Always put our clients’ interests ahead of our own when making recommendations and
      providing services.
  •   Disclose conflicts of interest and how the Firm addresses such conflicts. Adopt and follow
      policies and procedures designed to help ensure that we give advice and provide services
      that remain in each client’s best interest.
  •   Charge an advisory fee that is reasonable for our services.
  •   Not provide, or withhold, any information that could render our advice and/or services
      misleading.

If a Client’s account is a pension or other employee benefit plan governed by the Employee
Retirement Income Security Act of 1974, as amended ("ERISA"), CGAM can be a fiduciary to

the plan. In providing our investment management services, the sole standard of care imposed
upon us is to act with the care, skill, prudence and diligence under the circumstances then
prevailing that a prudent man acting in a like capacity and familiar with such matters would
use in the conduct of an enterprise of a like character and with like aims. CGAM will provide
certain required disclosures to the "responsible plan fiduciary" (as such term is defined in
ERISA) in accordance with Section 408(b)(2), regarding the services we provide and the
direct and indirect compensation we receive by such clients. Generally, these disclosures are

The Clark Group Asset Management                                                 March 4, 2026
Form ADV Part 2A
contained in this Form ADV Part 2A, the client agreement and/or in separate ERISA
disclosure documents and are designed to enable the ERISA plan’s fiduciary to: (1) determine
the reasonableness of all compensation received by CGAM; (2) identify any conflicts of
interests; and (3) satisfy reporting and disclosure requirements to plan participants.