Pioneer Advisory LLC

ITEM 5. FEES AND COMPENSATION
Users may access PiTrade’s core functionality without charge. Pioneer Advisory receives
compensation for the use of PiTrade through subscription fees.
A. Platform Subscription Fees

The Firm offers a tiered subscription model that grants Users access to various Platform
functionalities, including the ability to view and replicate Portfolios. In order to access the core
features of the Platform—specifically, the ability to copy investment strategies developed by
Traders or by the Firm—Clients are required to pay a subscription fee. Such fees may be billed
on a monthly or annual basis, as selected by the Client.
Pioneer Advisory understands that Clients have different financial circumstances, investment
objectives, and risk tolerances. Taking into account its fiduciary duty to Clients, Pioneer Advisory
has developed a two-tier membership structure designed to align with the varying needs and
abilities of Clients. Each tier provides Clients with different levels of access to curated trading
Portfolios and Strategies:
Tier 1: Permits the copying of up to two (2) stock and ETFs Portfolios and Strategies per month.
Tier 2: Permits the copying of an unlimited number of Portfolios and Strategies.

The applicable fees and billing terms are set forth in the Platform’s current Pricing Schedule,
available at https://www.pitrade.com/pricing.
Plus subscription - USD $9.99. This subscription is for Tier 1.
Pro subscription - USD $29.99. This subscription is for Tier 2.
Subscription fees are fixed and automatically charged to the User’s selected payment method.
Monthly fees are non-refundable. If a Client cancels an annual subscription prior to the expiration
of the subscription term, the Firm will issue a pro-rata refund based on the unused portion of the
term. Any discounts applied at the time of purchase will be forfeited and deducted from the
refund amount. No penalties are imposed for early cancellation.
B. Other Fees and Expenses

Trades executed through PiTrade are routed through a third-party broker-dealer, Interactive
Brokers LLC. Users are solely responsible for any commissions or transaction fees charged by
Interactive Brokers LLC. Pioneer Advisory does not charge or receive any additional
compensation in connection with such brokerage fees.
If a User invests in mutual funds through the Platform, these funds may incur fund-level expenses,
such as management fees and expense ratios imposed by the fund issuer. Pioneer Advisory
does not receive any portion of these expenses and does not impose additional charges in
connection with mutual fund investments.
Pioneer Advisory does not charge custodial fees. Custodial services are provided directly by the
executing broker-dealer without additional charges from the Platform.

ITEM 7. TYPES OF CLIENTS
Pioneer Advisory offers access to its online investment platform, PiTrade, to a broad range of
Users, including individuals interested in engaging in trading and copy trading functionalities.
Only Users who engage Pioneer Advisory to receive advisory services by creating a risk profile,
authorizing trade execution, and copying Portfolios are considered Clients of the Firm. Users who
solely publish Portfolios (“Traders”) are not considered Clients unless they also participate in copy
trading or otherwise engage the Firm’s advisory services.
Before accessing trading features on the Platform, Users must (i) complete a user profile with
Pioneer Advisory and (ii) pass identity verification conducted by the Firm’s designated broker-
dealer, Interactive Brokers LLC as disclosed in Item 13 hereto. Only upon successful completion
both steps will a User be eligible for trading and copytrading.
Opening a User profile on the Platform is not subject to any minimum asset requirement.
However, the ability to copy or invest in specific Portfolios may be subject to minimum investment
thresholds, as determined by the respective Portfolio parameters. Where applicable, these
minimum thresholds will be clearly disclosed on the Platform in connection with each Portfolio.

Pioneer Advisory does not impose restrictions based on User type, account size, or prior
investment experience. However, all Users are required to complete the Platform’s standard
onboarding and verification procedures in accordance with applicable laws and regulations.