Pinnacle Wealth Advisors LLC

ITEM 5 – FEES AND COMPENSATION
A description of the fees we charge for advisory services is set forth in this Item 5. We generally strive to
ensure the equal treatment of all clients with respect to fees. Therefore, the standard fees discussed in
this brochure are generally not negotiable, although we reserve the right to negotiate asset-based fees
for accounts with market value in excess of $7,000,000 and to make certain exceptions to our general fee
policies for family members, friends or individuals personally known to us, and/or those who are
employed by non-profit organizations. As an additional matter, individual clients may pay fees that are
higher or lower (or otherwise materially different) than those described in this brochure based on our
honoring of certain legacy fee arrangements with the client’s previous financial professional.

Fees for Investment Supervisory Services. For “full service” advisory engagements and “new client”
program accounts, we typically charge annual asset-based fees in line with the fee schedules shown
below. Fees are calculated as a percentage of the market value of the client’s investment account(s), as
determined by the custodian. They are charged quarterly, in advance, based on the market value on the
day assets are received into the client’s account, and prorated through the end of the quarter. The value
of annuities and outside 401k holdings are generally included for purposes of our fee calculations, unless
otherwise agreed.

PINNACLE WEALTH ADVISORS                                                                    FORM ADV PART 2A

     Full Service Program Fee Schedule (Portfolio Management, Financial Planning, and Financial
                                             Consulting)

 Household Assets*                                         Annual Asset-Based Fee (Retroactive to $1.00)
 $0 - $ 99,999                                             1.60%
 $100,000 - $249,999                                       1.35%
 $250,000 - $499,999                                       1.20%
 $500,000 - $999,999                                       1.15%
 $1,000,000 -$2,499,999                                    1.00%
 $2,500,000 - $3,999,999                                   0.95%
 $4,000,000 - $6,999,999                                   0.90%
 $7,000,000 and above                                      0.85%

                   New Investor Program Fee Schedule (Portfolio Management Only)

 Household Assets*                                         Annual Asset-Based Fee (Retroactive to $1.00)
 $0 – $10,000                                              0.00%
 $10,000 - $99,999                                         0.85%

* In the case of multiple accounts within a family, our billing is based on the collective value of all accounts
held by the family members.

* On October 1, 2025, PWA acquired IMS, an investment advisor registered with the Securities and
Exchange Commission also located in Portland, Oregon. In connection with the IMS acquisition, PWA also
acquired two mutual funds managed by IMS; the IMS Capital Value Fund trading as IMSCX and the IMS
Strategic Income Fund trading as IMSIX. Both mutual funds are registered with the Securities and
Exchange Commission. Client investments in IMSCX and IMSIX are subject only to mutual fund level fees.
The above fee schedules do not apply to these holdings.

Under our new investor program, we do not provide the client with a comprehensive written financial
plan, ongoing financial consulting services (beyond those related to management of the client’s
investment accounts), or access to alternative investments. New investor clients are also required to set
up an automatic monthly deposit to the investment account to be managed by our firm under the
program. Certain clients who have rollover retirement accounts may not be eligible to enroll in our new
investor program and may be subject to fees of up to 1.00% of the market value of their rollover assets.

Our advisory fees for these services are directly deducted from the client’s account held at the custodian.
You will be required to authorize our direct deduction of fees in our written advisory agreement and/or
in the account opening documentation of your custodian. We will first look to cash balances in your
account or to liquidate money market shares to pay our advisory fees. In the event that cash balances or
money market shares are not available, other investments may be liquidated to pay our advisory fees
then due. We will only liquidate investments held in your account for these purposes in line with our
fiduciary duty to the client.

We will submit a request to the custodian each time a fee is to be deducted from your account. You will

PINNACLE WEALTH ADVISORS                                                                 FORM ADV PART 2A

receive an account statement at least quarterly from the custodian showing all holdings and transactions
in your account during the period, including any deductions for advisory fees paid to our firm. The
custodian is not responsible for verifying the accuracy of our advisory fees. Therefore, clients are strongly
encouraged to carefully and promptly review their custodial account statements upon receipt. If you have
any questions or concerns about our advisory fees or any transactions or holdings in your account, you
should contact us at the telephone number listed on the cover page of this brochure.

For illustration purposes only, a full service client account with a value of $734,500 on September 30th
subject to the above fee policies would pay a quarterly management fee calculated as follows:

$734,500 X 1.15% = $8,446.75 / 4 = $2,111.69.

                     Independent Manager Fees and Third Party Professional Fees

Where Independent Managers are engaged to manage a portion of your assets, the amount of their
...

ITEM 7 – TYPES OF CLIENTS
We typically provide advisory services to individuals, high net worth individuals, pensions, 401(k) and
profit sharing plans, trusts, estates, partnerships, corporations, and other business entities.

We do not impose any minimum account size or fee minimums of any kind to open or maintain an advisory
relationship with our firm.