Pacific Heights Asset Management LLC

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Pacific Heights Asset Management LLC
CRD #124365
SEC #801-61673
CIK #0001323414
AUM 7,273.9 M (2026-02-17)
Employees 10 (20% Investors, 20% Brokers)
Fees
Minimum
Phone415-398-8000
Address600 Montgomery Street
San Francisco, CA 94111-2816
Source [IAPD] [EDGAR]
Total AUM ($B)
2016128402003201120192027
Fees and Compensation — Form ADV Part 2A (2/17/2026) [Brochure]
Item 5 – Fees and Compensation

Pacific Heights receives a portion of the asset-based fee charged to Financial Intermediary Clients
by their Financial Intermediary in the form of a Model Portfolio provider fee from the Financial
Intermediary. Pacific Heights negotiates such a Model Portfolio provider fee for its services with
a Financial Intermediary on a case-by-case basis. Pacific Heights does not maintain a standard
Model Portfolio provider fee schedule for such Model Portfolio provider services but expects that
such fees will be negotiated with a Financial Intermediary based on the particular services to be
provided in the circumstances. Pacific Heights expects that a Model Portfolio provider fee of .40%
(forty basis points) of assets under management will be payable to Pacific Heights under its Model
Portfolio program with Envestnet.

All fees paid to Pacific Heights for its Model Portfolio services, and fees paid to Financial
Intermediaries for the Model Portfolios, are separate and distinct from the fees and expenses
charged by mutual funds or exchange-traded funds (“ETFs”) that are included in a Model Portfolio.
These fees and expenses are described in each investment product’s individual Prospectus,
Statement of Additional Information, or other disclosure document. These fees will generally
include a management fee, other fund operating expenses, and a possible distribution fee. A
Financial Intermediary Client could invest in a mutual fund or ETF directly, without participating
in a Model Portfolio, which would be less expensive. However, in that case, the Financial
Intermediary Client would not receive the Model Portfolio services provided by the Financial
Intermediary which are designed, among other things, to provide an ongoing portfolio investment
program. Accordingly, the Financial Intermediary Client should review both the fees charged by
the investment products and the fees charged by the Financial Intermediary to fully understand the
total amount of fees to be paid and thereby evaluate the Model Portfolio services being provided.
The fee charged by a Financial Intermediary to its Financial Intermediary Clients may only cover
the portfolio management and advisory services provided by the Financial Intermediary and may
not include brokerage commissions, mark-up and mark-downs, dealer spreads or other costs
associated with the purchase and sale of securities, custodial fees, interest, taxes, or other account
expenses. A Financial Intermediary Client will be solely responsible, directly, or indirectly, for
these additional expenses. Please see Item 12 for additional information about brokerage costs.

Pacific Heights does not receive any asset-based sales charges, any service fees, or other monetary
compensation from any third-party mutual fund or ETF providers for use of their respective mutual
funds or ETFs in its Model Portfolios. Pacific Heights does not include the Trust’s Portfolios
within its Model Portfolio recommendations.

Financial Intermediary Clients should refer to the materials provided by their Financial
Intermediary regarding the fees and expenses that they will be charged for various services
provided, and the methodology for charging such fees and expenses, including whether the fees
and expenses will be billed to the Financial Intermediary Client or deducted from the Financial

Intermediary Client’s assets under management, and whether any fees or expenses may be required
to be prepaid, and any applicable refund policies for prepaid fees and expenses. Minimum balance,
initial deposit, termination, and withdrawal provisions will vary by Financial Intermediary.
Account Minimums and Types of Clients — Form ADV Part 2A (2/17/2026) [Brochure]
Item 7 – Types of Clients

Pacific Heights provides Model Portfolio services to Financial Intermediaries who utilize the
Model Portfolios with their Financial Intermediary Clients. Because Pacific Heights provides non-
discretionary investment recommendations to Financial Intermediaries with respect to the Model
Portfolios, it does not dictate the investment minimums that Financial Intermediaries may apply
to their Financial Intermediary Clients. Besides the Model Portfolio services offered through this
Brochure, Pacific Heights also serves as the investment adviser to the Trust.
Sector Form 13F Holdings Value ($B)
Texas Pacific Land Corp 0.3
Palantir Technologies Inc 0.2
Freeport McMoran Copper & Gold Inc 0.2
Nvidia Corp 0.2
Facebook Inc 0.1
Broadcom Inc 0.1
Costco Wholesale Corp /NEW 0.1
Applovin Corp 0.1
Lockheed Martin Corp 0.1
Parker Hannifin Corp 0.1
View All
Holdings by Sector ($B)
5.04.03.02.01.00.02011201620212027
AUM Breakdown Accounts AUM ($B)
By Client Type
(a) Individuals (other than high net worth individuals) 0 0.0
(b) Individuals (high net worth individuals) 0 0.0
(c) Banking or thrift institutions 0 0.0
(d) Investment companies 4 7.3
(e) Business development companies 0 0.0
(f) Pooled investment vehicles 0 0.0
(g) Pension and profit sharing plans 0 0.0
(h) Charitable organizations 0 0.0
(i) State or municipal government entities 0 0.0
(j) Other investment advisers 1 0.0
(k) Insurance companies 0 0.0
(l) Sovereign wealth funds and foreign official institutions 0 0.0
(m) Corporations or other businesses not listed above 0 0.0
(n) Other 0 0.0
Total 4 7.3
By Discretionary
Discretionary 4 7.3
Non-Discretionary 0 0.0
Total 4 7.3
By Non-United States Persons
Non-United States Persons 0.0
United States Persons 7.3
Total 4 7.3
EDGAR Form CIK 2011 - 2026
13F-HR [0001323414]
Firm Profile (Form ADV)
Discretionary AUM$9.7B
Clients1
ServesInstitutional
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