Pinvest LLC

>   Item 5
    ACCOUNT REQUIREMENTS AND TYPE OF CLIENTS

    Pinvest’s clients are institutional clients that provide advisory services to wealthy individuals
    and families. The Firm also has clients that are high net worth individuals and families and
    retail clients.

    Pinvest’s minimum accounts for the wrap fee program is $5,000. However, based on facts
    and circumstances Pinvest, at its sole discretion, accepts accounts with a lower value.

>   Item 7
    CLIENT INFORMATION PROVIDED TO PORTFOLIO
    MANAGERS
    In order to provide the Wrap Program services, PINVEST will share your private information
    with your account custodian. PINVEST may also provide your private information to mutual
    fund companies and/or third-party managers, or other service providers, as needed.
    PINVEST will only share the information necessary in order to carry out our obligations to
    you in servicing your account. PINVEST shares your personal account data in accordance
    with our privacy policy as described below.

    Privacy Notice

    PINVEST views protecting your private information as a top priority. Pursuant to applicable
    privacy requirements, we have instituted policies and procedures to ensure that we keep
    your personal information private and secure.

    PINVEST may disclose your non-public personal information to non-affiliated third parties.
    In the course of servicing your account, we may share some information with our service
    providers, such as transfer agents, custodians, broker-dealers, accountants, consultants,
    and attorneys.

    PINVEST restricts internal access to non-public personal information about you to
    employees, who need that information in order to provide products or services to you. We
    maintain physical and procedural safeguards that comply with regulatory standards to
    guard your non-public personal information and to ensure our integrity and confidentiality.
    We will not sell information about you or your accounts to anyone. We do not share your
    information unless it is required to process a transaction, at your request, or required by
    law.

    You will receive a copy of our privacy notice prior to or at the time you sign an advisory
    agreement with our firm.

    If you decide to close your account(s) we will adhere to our privacy policies, which may be
    amended from time to time.

    If we make any substantive changes in our privacy policy that would further permit or
    require disclosures of your private information, we will provide written notice to you. Where
    the change is based on permitted disclosures, you will be given an opportunity to direct us
    as to whether such disclosure is acceptable. Where the change is based on required
    disclosures, you will only receive written notice of the change. You may not opt out of the
    required disclosures.

    If you have questions about our privacy policies, contact our main office at the telephone
    number on the cover page of this Brochure.