Pier Capital LLC

TYPES OF CLIENTS

          We provide investment advisory services for a variety of clients including High Net Worth Individuals, investment
          companies, pooled investment vehicles, pension and profit-sharing plans, charitable organizations, state and/or
          municipal government entities, and other institutional clients.

          MINIMUM ACCOUNT SIZE

          We require a minimum account size of $3,000,000 for separately managed accounts invested in the firm’s Small
          Cap Growth and Smid Cap Growth strategies and $1,000,000 for separately managed accounts invested in the
          firm’s Small Cap Growth Concentrated and Mid Cap Growth Concentrated strategies.

          Minimum account size for investment in Pier Capital Commingled Small Cap Growth Fund Investment Trust is
          $500,000 and subsequent contributions require a minimum of $300,000. Prospective investors in the Commingled
          Fund should refer to the Offering Memorandum and other Fund documents for complete information.

          Occasionally, we can make an exception to minimum account sizes or subsequent investments because of existing
          client relationships.

          We reserve the right to refuse to accept a proposed investment management mandate or to resign from the
          management of any account, subject to termination provisions agreed to with existing clients in advisory
          agreements.

          Clients in the wrap-fee programs for which Pier acts as Portfolio Manager are subject to that program’s minimum
          account requirements. Potential investors in such wrap programs are requested to refer to the applicable program
          brochure for complete information.

          As disclosed under Item 4, Pier is a sub-adviser to the following U.S. mutual funds: Dunham Small Cap Growth
          Funds (Class A, C, and N) and Adara Smaller Companies Fund (formerly Altair Smaller Companies Fund), a series of
          The RBB Fund, Inc. These mutual funds have minimum initial and subsequent investment requirements. Investors
          should refer to the applicable fund prospectus and Statement of Additional Information for complete information
          on these registered investment companies.

ITEM 8.                    METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS                                           Link to TOC

          METHODS OF ANALYSIS AND INVESTMENT STRATEGIES

          As mentioned in Item 4, we offer the following investment strategies:

              -    Small Cap Growth
              -    Small/Mid (SMID) Cap Growth
              -    Small Cap Growth Concentrated
              -    Mid Cap Growth Concentrated

          In doing so, we invest, within the limitations of clients’ investment objectives, goals, needs, risk and guidelines, in a
          wide range of securities and other financial instruments, including, but not limited to the following investment
          vehicles:

              -    Exchange-listed equity securities
              -    Equity securities traded over-the-counter
              -    Foreign issuers equity securities
              -    American depositary receipt (ADR)
              -    Mutual Fund Shares
              -    Exchange Traded Funds

          As financial markets and products evolve, we may invest in other types of instruments or securities depending on
          risk and our fundamental analysis.

          We apply a fundamental method of analysis to all investments and strategies. As part of our fundamental analysis
          process, we attempt to measure the intrinsic value (or value based on simplified assumptions that ignores the
          possibility of future fluctuations and the time value of money) of a security by looking at economic and financial
          factors (including the overall economy, industry conditions and the financial condition and management of the
          company itself) to determine if the company is underpriced (indication it may be a good time to buy) or overpriced
          (indicating it may be time to sell).

          In conducting our security analysis, we utilize a broad spectrum of information including financial publications, third-
          party research materials, annual reports, prospectuses, regulatory filings, company press releases, corporate rating
          services, inspections of corporate activities and meetings with management of various companies.

          Environmental, Social and Governance Overlay in the Investment Process
          At the end of our investment analysis process, we apply Environmental, Social and Governance (ESG) risk review. As
          part of this ESG review process, we utilize both inclusionary and exclusionary investment screening. We consider
          ESG risks factors when making investment decisions; however, our stock selection process excludes ESG risk factor
          considerations and focuses (and begins with) on the evaluation of company’s fundamentals. The impact of ESG risk
          aspects is the last step in our investment process, when the Portfolio Manager can discretionarily overweight a
          security with a Low or a Negligible ESG risk score, as provided by Sustainalytics (an independent third-party ratings
          vendor we use to obtain the overall ESG risk ranking). The ESG risk analysis provided by Sustainalytics serves as a
          valuable additional risk metric in the overall investment process but is only complimentary to the fundamental
          research process and does not alter the way we conduct initial screening for growth companies that meet our
          investment criteria. The integration of Sustainalytics’ ESG risk ranking metrics into Pier’s investment process has no
          impact on Pier’s individual stock selection decisions.
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