PINNACLE WEST ASSET MANAGEMENT INC

Pinnacle West Asset Management, Inc. 152 North Durbin Street Suite 400 Casper, Wyoming 82601 307.235.3300 February 18, 2025 This brochure provides information about the qualifications and business practices of Pinnacle West Asset Management, Inc. (Pinnacle). Should you have any questions about the contents of this brochure, please contact us at 307.235.3300. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about Pinnacle West Asset Management, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. Pinnacle West Asset Management, Inc. is registered with the SEC as an investment advisor. Pinnacle employs a Chief Compliance Officer and strives to maintain a culture of compliance and excellence. Registration with the SEC does not, however, imply any particular level of skill or training. We encourage the reader to carefully scrutinize this document, to directly examine Pinnacle and its operation, and to discuss any potential business relationship with the reader’s own knowledgeable business advisers and legal counsel.  Table of Contents Table of Contents .................................................................................................................... 2 Material Changes .................................................................................................................... 3 Advisory Business ................................................................................................................... 4 Fees & Compensation ............................................................................................................. 5 Types of Clients ...................................................................................................................... 6 Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 7 Disciplinary Information ......................................................................................................... 8 Other Financial Industry Activities and Affiliations ............................................................... 8 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .......... 9 Brokerage Practices ............................................................................................................... 10 Review of Client Accounts ................................................................................................... 12 Client Referrals and Other Compensation ............................................................................ 12 Custody ................................................................................................................................. 13 Investment Discretion ........................................................................................................... 13 Voting Client Securities ........................................................................................................ 13 Financial Information ............................................................................................................ 13 Additional Disclosures .......................................................................................................... 14 Tom R. Creager ..................................................................................................................... 17 Lane R. Hunsicker ................................................................................................................. 20 Arin B. Wesnitzer ................................................................................................................. 22 2  Material Changes Since the last annual version of this brochure dated February 9, 2024, the following are material changes: Item 4 has been amended to report current assets under management. • Full Brochure Availability The Firm Brochure for Pinnacle West Asset Management is available by contacting our office at 307 235.3300. 3  Advisory Business Firm Description Pinnacle West Asset Management, Inc. a Wyoming Corporation is an investment management and research firm located in Casper Wyoming. The firm was founded October 1, 1991 and is a successor to a business started by Tom R. Creager in 1988. The firm was founded to fulfill the needs of long-term investors. The firm is a regulated investment advisory firm subject to the rules and regulation of the Investment Advisors Act of 1940, administered by the Securities and Exchange Commission. Principal Owners Its principal owners are Tom R. Creager, Lane R. Hunsicker, and Roger W. Wesnitzer. Types of Advisory Services Pinnacle West Asset Management, Inc’s. commitment is to provide a disciplined and systematic approach toward the investment process to achieve the highest risk adjusted return possible within defined investment objectives. The firm creates custom designed investment portfolios to meet specific client investment goals and objectives. Client portfolios are individually managed in keeping with each client’s stated investment goals, objectives, and income tax strategies within the overall parameters of our investment philosophy. The basis for which we manage each of our client’s investment portfolios begins with an asset allocation model. We believe proper asset allocation is critical to the investment process and the effective management of portfolio risk. We are available to assist with the development of an asset allocation model if requested. Many times, we are provided with a predetermined asset allocation model from the client’s financial advisor. We firmly believe once the asset allocation is determined and agreed upon it should stay constant over the short-term but evolve over the long-term. The asset allocation model should not change to respond to the market environment in the short-term, but rather evolve over the long- term as client’s needs and risk tolerance changes. Generally, the asset allocation model will broadly require that a certain percentage or range of the investment assets be allocated among cash and cash equivalents, fixed income securities, equity income securities and equity securities. Cash and cash equivalents are often readily liquid money market or bank deposit accounts. Fixed income securities often include corporate debt securities, government debt securities, and municipal debt securities. Equity income securities often include preferred stock, index securities, real estate investment trusts and publicly traded partnerships. Equity securities often include large capitalization stocks, small capitalization stock index securities, mid capitalization stock index securities, developed foreign country index securities, and foreign emerging market index securities. 4  Pinnacle West Asset Management, Inc. does not utilize leverage or margin for the management of our portfolios. However, a client may utilize margin (client directed) to borrow against their account. If so, Pinnacle will bill on managed portfolio assets without regard to the amount borrowed. Pinnacle West Asset Management, Inc. has full discretionary trading authority over each client’s account. Clients are not allowed to impose any restrictions on investing in certain securities or types of securities. Our investment philosophy is the disciplined long-term management of risk to preserve and grow investment capital. We believe superior risk adjusted returns can be achieved over the long-term with proper diversification. Our philosophy is grounded on the basis of buying and holding investment securities over the long-term. Our definition of long-term for equity securities is often measured in a lifetime. We do not believe market timing can be a successful long-term approach to the investment process. Our philosophy does not include short-term trading or thinking. The fixed income portion of the portfolio will often consist of a laddered portfolio not exceeding ten years in maturity. We do not select fixed income securities for trading purposes we tend toward holding them until they mature and collecting the interest income. At the outset of our relationship with each client in consultation with the client we develop and agree on a memorandum of understanding that outlines the assumptions and understandings governing the management of the investment portfolio. Wrap Fee Programs Pinnacle West Asset Management, Inc. does not participate in wrap fee programs of any type. Client Assets As of December 31, 2024, Client assets under management were approximately $229.5 million, all of which is managed on a discretionary basis. Fees & Compensation Description All fees charged by Pinnacle West Asset Management, Inc. are calculated on an annual basis. The fees are billed quarterly in arrears. The fee is calculated based on the end of quarter valuation. Fees are prorated for any period less than a full quarter. Minimum fee charged per household Cash and cash equivalents $100.00 .25% 5  Fixed income securities Equity securities Equity income securities Exchange traded index shares Mutual funds .25% 1.00% 1.00% .50% .50% Other Fees The fees charged for mutual funds and exchange traded index shares do not include any fees charged directly by the fund or index shares. The fees charged do not include any transaction costs, or handling fees charged by the custodial firm handling the account. The fees do not include any charges by trustees if the assets are held by a corporate trustee. Fees may be negotiable on larger accounts. Fee Billing Fees are deducted directly from client assets after the end of each quarter unless other arrangements are agreed to. A copy of the invoice showing the calculation of the fees is included with our quarterly reporting to clients. Fees Paid in Advance Fees for our services are not charged in advance. Additional Compensation Pinnacle West Asset Management, Inc. does not receive any other forms of compensation related to client assets. Performance-Based Fees & Side-by-Side Management Pinnacle West Asset Management, Inc. does not receive performance-based fees of any type. Types of Clients Description Pinnacle West Asset Management, Inc. provides investment management services to individuals, families, trusts, business entities, charitable foundations, and pension and profit-sharing plans. Account Minimums Pinnacle West Asset Management, Inc. minimum account size is $500,000. Accounts with assets less than $500,000 allocated to large capitalization equities are advised to utilize exchange traded index shares. 6  Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Our approach towards investing in equities is the long-term holding of fundamentally sound companies, that are market leaders in their respective industries and operated in our judgment by superior management teams. Additionally, we view investments in equities not as investments in stocks, but rather as ownership in respective businesses. We believe consistent risk adjusted returns can be obtained with an allocation across both the value and growth sectors of the market. Further, management of risk we believe is achieved with diversification across many industries and among various companies within an industry. We begin by developing an economic model to forecast long-term trends of the economy. Additionally, we work to identify long-term societal and demographic trends and as much as is possible effects of governmental monetary and fiscal policy. We utilize this information as the basis for our sector allocations and our industry weightings within each sector. We then select specific large capitalization equities for inclusion in each sector and industry by employing a screening process based on pre-determined financial variables and risk measurements, but not to the exclusion of certain intangible attributes. The financial variables might include but not be limited to, market capitalization, a conservative amount of leverage appropriate for a given industry, a favorable working capital position, strong and growing cash flow from operations and consistent growth in both revenues and earnings. Risk measurements include market betas and standard deviation measurements. Intangible attributes might include but not be limited to superior and stable management teams, a progressive management style, and a stated commitment to being leaders in their respective industries. Barriers to entry into a given industry by competitors are often considered as well. Our approach toward fixed income investing is to preserve capital and generate a desired level of income. It is not investing for short-term market gains. Our primary concerns are to minimize credit risk and interest rate risk while obtaining the highest possible yield on the fixed income portfolio. We attempt to mitigate credit risk or the risk of default by investing primarily in bonds with an investment grade credit rating by two debt rating agencies, Standard & Poors and Moody’s. We utilize our economic model as the basis for our projection of interest rate trends. We mitigate the effects of interest rate changes by laddering bonds maturities along what we believe to be the most favorable part of the interest rate yield curve. Further, we specifically design the bond ladder, so a certain portion of the bond portfolios matures annually enabling reinvestment at current market rates at the far end of the ladder. 7  Risk of Loss Investing in securities brings with it the risk of loss. Clients are advised that they should be prepared and able to tolerate loss of value especially in the short-term. Disciplinary Information Legal and Disciplinary None Criminal or Civil Action None Administrative Proceeding None Self-Regulatory Proceeding None Other Financial Industry Activities and Affiliations Broker-dealer or Registered Representative None Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Adviser or Associated Person None Material Relationships or Arrangements with Financial Industry Pinnacle West Asset Management, Inc. receives referrals of clients from accounting firms in Casper Wyoming. We have significant relationships with CPA Consulting Group LLP and CPA Associates LLC. Recommend or Select Other Investment Advisers We do not recommend or select other investment advisers. 8  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics We believe it is our responsibility to place our client’s interests above our own at all times. We will manage every client’s assets as though they are our own assets. Recommend Securities with Material Financial Interest We do not recommend or invest client assets in any company in which we have a material interest. Invest in Same Securities Recommended to Clients We do frequently invest in the same securities we invest client assets in. Given the nature and types of investments we utilize for client’s we do not believe there is a conflict of interest, and in fact just the opposite, we feel we should be investing our assets in the same manner as our client’s. The securities we invest client assets in are large capitalization companies and are not thinly traded. We do not invest client assets in initial public offering securities Personal Trading Practices Pinnacle West Asset Management, Inc. policy regarding trading securities for personal accounts on the same day or at the same time as clients is to place personal trades at the end of our trading session if possible. A copy of our code of ethics is available by contacting us during normal business hours. When we provide investment advice to you regarding your retirement plan account or individual retirement account (IRA), we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; 9  • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. * It should be noted that the fiduciary duties enumerated above do not differ from those we observe in all our advisory activities. Brokerage Practices Selecting Custodial Firms We select custodial firms to custody client assets and provide trading platforms. We select these firms based on many factors such as but not limited to trading costs, account fees, trade routing and order execution. We require honesty and diligence in dealing with our clients. We demand that the trading platform they provide for our use is both functional and cost effective. Research and Soft Dollars We recommend that clients establish brokerage accounts with the Schwab Institutional division of Charles Schwab & Company, Inc. (Schwab), a registered broker/dealer, member FINRA/SIPC, to act as the custodian of clients' assets and to effect trades for their accounts. We are independently owned and operated and not affiliated with Schwab. Schwab provides us with access to its institutional trading and custody services, which are typically not available to its retail investors. These services generally are available to independent investment advisors on an unsolicited basis, at no charge once the custodial relationship is established. Schwab's services include custody, brokerage, research and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Commission rates and securities transaction fees charged to affect a client's transactions are established by Schwab. For client accounts in its custody, Schwab generally does not charge separately for custody but is compensated by account holders through commissions or other transaction-related fees for securities trades that are executed through Schwab. “Soft Dollars” Charles Schwab makes available various support services that may not be available to retail customers. Some of those services help manage or administer clients’ accounts, while others help us manage and grow our business. These support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Services that Benefit Clients Charles Schwab provides clients with access to a range of investment products, execution of securities transactions, and custody of client assets. Services described in this paragraph 10  generally benefit the client and their account. The investment products available through Charles Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by clients. Services That May Not Directly Benefit Clients Charles Schwab also makes other products and services available to us that benefit us but may not directly benefit the client or their account. These products and services assist us in managing and administering client accounts. In addition to investment research, Charles Schwab also makes available software and other technology that: • Assists with back-office functions, recordkeeping, and client reporting for client accounts. • Provides access to client account data (such as duplicate trade confirmations and account statements). • Provides pricing and other market data. Services That Generally Benefit Only Us By using the services of Charles Schwab, we are offered other services intended to help us manage and further develop our business. These services include: • Educational conferences and events. • Consulting on technology, compliance, legal, and business needs. • Publications and conferences on practice management and business succession. Our Interest in Charles Schwab Services The availability of these services from Charles Schwab benefits us as we do not have to produce or purchase them independently. In addition, we do not pay Charles Schwab for these services. This presents a conflict of interest in that we have an incentive to recommend Charles Schwab based on our interest in these services. However, we observe our duty as a registered investment advisory firm to put client best interest first. We believe the selection of Charles Schwab as custodian and broker is in the best interests of clients based on the scope, quality, price, and overall value of services to clients rather than on those services that benefit us. Custodians for Client Referrals We do not receive client referrals from any custodial firms we recommend. We do not receive any compensation for recommending any custodial firms. Directed Brokerage We routinely recommend that clients use custodians we have a relationship with because we feel it is beneficial for our clients. We routinely monitor order execution and have not found any instances of unfavorable order execution. We generally do not accept clients who wish to designate a particular broker-dealer that will serve as custodian with whom we do not have a relationship with. In doing so the client should consider whether 11  commission expenses, execution, clearance and settlement capabilities, and custodial fees would be comparable to those otherwise obtainable by us. Order Aggregation We may utilize order aggregation when we have a large block of securities to trade mostly dealing with the liquidation of a security position. Given the nature of our client base and that all the accounts are individually managed there are seldom instances when we can utilize order aggregation in cost effective manner. Review of Client Accounts Periodic Reviews Each account is reviewed on a semi-annual basis at a minimum and rebalanced as necessary. Each account’s cash balance is reviewed daily to determine if a full account review is warranted. Review Triggers Accounts are reviewed on an-other than periodic basis when cash balances materially exceed targeted percentages or as new accounts are in the process of initial investment. Regular Reports Pinnacle West Asset Management, Inc. provides each client with written quarterly reports containing a Portfolio Appraisal with Income, a Year to Date Performance Report and an Account Inception to Date Performance Report. The appointed custodial firm of record that has custody of client assets provides a written or electronic trade order confirmation after each trade is executed. The custodial firm also provides a written or electronic monthly account statement and provides a written or electronic annual statement (Form 1099) for tax reporting purposes. Client Referrals and Other Compensation Third Party Solicitors Pinnacle West Asset Management, Inc. does not receive any compensation for making client referrals. Pinnacle West Asset Management. Inc. does not compensate any person or firm for client referrals. 12  Custody Account Statements Pinnacle West Asset Management, Inc. does not have custody of client assets. Clients receive monthly account(s) statements from qualified custodians such as brokerage firms and bank trust departments that have custody of client assets. Pinnacle West Asset Management, Inc. provides client account reports on a quarterly basis and clients are urged to compare the statements we provide to the statements provided from the qualified custodian. Investment Discretion Discretionary Authority for Trading We assume full power to supervise and direct the investment of client account(s), making and implementing investment decisions, all without prior notification with the client, in accordance with the investment management agreement between the client and Pinnacle West Asset Management, Inc. Prior to assuming authority, we will develop in concert with the client an engagement memorandum which sets forth our assumptions and understandings under which we are to manage the client’s assets. Voting Client Securities Proxy Voting Pinnacle West Asset Management, Inc. does not have and will not accept authority to vote client securities. Financial Information Prepayment of fees Pinnacle West Asset Management, Inc. does not solicit prepayment of fees. 13  Additional Disclosures Privacy Policy Pinnacle West Asset Management, Inc. is committed to protecting the information you have entrusted to us. You can rely on us to protect your privacy and ensure the security of your information. • We do not sell client information to other companies for marketing purposes. • We employ strict security standards and safeguards to protect your personal information. • We will continue to protect your privacy even if you are no longer a client. You can help safeguard your personal information by taking a few simple precautions. • Do not disclose your account information, personal identification numbers, passwords, or code words to others. • Never provide confidential information to unknown callers. • When using the Internet, be sure to use a secure browser and exit online applications as soon as you finish using them. • Make sure your personal computer has current virus-protection software. • Never open e-mail from unknown sources. In order to serve your investment needs, it is important for us to obtain specific information about you. The information we gather comes from a variety of sources, including: • • • Information you provide directly to us on applications or otherwise (such as Social Security Numbers, assets and income). Information related to your transactions with us (such as account balances, securities positions, and securities trade information). Information we obtain from others at your request (such as information about assets held at another institution for inclusion in an investment portfolio). With the limited exceptions described below, we do not provide client information to companies outside of Pinnacle West Asset Management, Inc. You do not need to request this confidentiality; it is our standard practice. To serve your needs, we may provide your information to: • Specialists that perform business operations for you (such as your accountant, lawyer, or financial advisor). 14  • Companies that act on our behalf to provide you with services that we may not offer ourselves (such as broker dealers). • Others only as permitted or required by law (such as in response to a subpoena). We select very carefully the outside companies that provide services on our behalf and we provide them only with the information necessary to fulfill their responsibilities to offer a service to you. These companies are prevented by legal agreement from using client information for their own purposes or selling this information to others. If you have questions or concerns, contact us. We welcome the opportunity to answer additional questions you may have about this policy statement or the safeguarding and confidentiality of your information. 15  Business Continuity Plan Statement Pinnacle West Asset Management, Inc is committed to providing our clients with secure and reliable access to their accounts. This commitment includes providing information regarding plans to address disruption in our business operations due to natural disasters, or other significant events. As a part of our plan we utilize third party custodians to custody your assets. Those custodians maintain business interruption plans as fully described in their documents regarding specific plans they have in place to maintain business operations. Due to the way we manage your investment assets, we feel a disruption in our office facilities would have a minimal impact on your specific investment plans in the short run. We feel we would be able to continue the management of your assets from another location if needed. We maintain duplicate asset allocation documents, account review documents and security research at an off-site location. We periodically assess and update this plan as needed. You may obtain a current version of the Statement by contacting us during normal business hours. 16  Tom R. Creager Pinnacle West Asset Management, Inc. 152 North Durbin Street Suite 400 Casper, Wyoming 82601 307.235.3300 February 18, 2025 This brochure supplement provides information about Tom R. Creager that supplements Pinnacle West Asset Management, Inc brochure. You should have received a copy of that brochure. Please contact Pinnacle West Asset Management, Inc. if you did not receive Pinnacle West Asset Management, Inc. brochure or if you have any questions about the contents of this supplement. Educational Background & Business Experience Tom R. Creager Year of Birth: 1958 Formal Education Tom R. Creager received a Bachelor of Science Degree in Accounting from the University of Wyoming in 1983. His course work also included additional studies in finance and economics. Business Background Tom R. Creager has been actively working in the field of investment management and research since 1988. He also worked in the field of public accounting from 1984 through 2010 concentrating on business and financial consulting, financial statement preparation and analysis, and income tax planning and preparation. He has served on the board of directors of a publicly traded oil and gas exploration company. 17  Disciplinary Information Legal or Disciplinary Events None Criminal or Civil Action None Administrative Proceeding None Self-Regulatory Organization Proceeding None Other Proceeding None Other Business Activity Other Business or Occupation for Compensation Tom R. Creager provides contract services requiring less than 20 hours per year to CPA Associates, LLC for which he receives compensation. Tom R. Creager has an ownership interest in and serves as Managing Partner of Energy Properties Limited, LP a privately held company engaged in the acquisition and holding of oil and gas royalty interests and the active management of a diversified investment portfolio. He spends approximately 150 hours per year on this activity and isn’t compensated. Tom R. Creager has an ownership interest in and serves as President of Wind River Resources, Inc. a privately held company involved in oil and gas exploration and production. He spends less than 50 hours per year on this activity and is compensated for his services. Tom R. Creager has an ownership interest in and is a director of Coastal Sands Indemnity Ltd. a privately held company whose primary purpose is to provide access to nontraditional insurance coverage of risks that businesses are commonly faced with, but for which limited, or no coverage is currently available. The Company retains the services of Pinnacle West 18  Asset Management, Inc. for the management of its investments for which it pays fees to Pinnacle West Asset Management, Inc. He spends less than 10 hours per year on this activity and isn’t compensated. Supervision Describe Supervision Tom R. Creager is the Chief Investment Officer for Pinnacle West Asset Management, Inc. He supervises the firm’s investment research and portfolio management activities. 19  Lane R. Hunsicker Pinnacle West Asset Management, Inc. 152 North Durbin Street Suite 400 Casper, Wyoming 82601 307.235.3300 February 18, 2025 This brochure supplement provides information about Lane R. Hunsicker that supplements Pinnacle West Asset Management, Inc brochure. You should have received a copy of that brochure. Please contact Pinnacle West Asset Management, Inc. if you did not receive Pinnacle West Asset Management, Inc. brochure or if you have any questions about the contents of this supplement. Educational Background & Business Experience Lane R. Hunsicker Year of Birth: 1995 Formal Education Lane R. Hunsicker received a Bachelor of Science Degree in Finance with a minor in Banking and Financial Services from the University of Wyoming in 2018. He graduated Magna Cum Laude. Business Background Lane R. Hunsicker has been actively working in the field of investment management and research since his graduation in 2018. He has passed the Series 65 Examination. 20  Disciplinary Information Legal or Disciplinary Events None Criminal or Civil Action None Administrative Proceeding None Self-Regulatory Organization Proceeding None Other Proceeding None Other Business Activity None. Supervision Describe Supervision Tom R. Creager, Chief Investment Officer, 307 235-3300, supervises Lane R. Hunsicker in the performance of his duties for Pinnacle West Asset Management, Inc. 21  Arin B. Wesnitzer Pinnacle West Asset Management, Inc. 152 North Durbin Street Suite 400 Casper, Wyoming 82601 307.235.3300 February 18, 2025 This brochure supplement provides information about Arin B. Wesnitzer that supplements Pinnacle West Asset Management, Inc brochure. You should have received a copy of that brochure. Please contact Pinnacle West Asset Management, Inc. if you did not receive Pinnacle West Asset Management, Inc. brochure or if you have any questions about the contents of this supplement. Educational Background & Business Experience Arin B. Wesnitzer Year of Birth: 1975 Formal Education Arin B. Wesnitzer received a Bachelor of Science Degree in Accounting from the University of Wyoming in 1997. He passed the CPA Exam in 1999 and holds an inactive license to practice in the state of Wyoming. Business Background Arin B. Wesnitzer has been actively working in the field of accounting in various roles, including public accounting, government, higher education and private enterprise since his graduation in 1997. He has passed the Series 65 Examination. 22  Disciplinary Information Legal or Disciplinary Events None Criminal or Civil Action None Administrative Proceeding None Self-Regulatory Organization Proceeding None Other Proceeding None Other Business Activity None. Supervision Describe Supervision Tom R. Creager, Chief Investment Officer, 307 235-3300, supervises Arin B. Wesnitzer in the performance of his duties for Pinnacle West Asset Management, Inc. Arin B. Wesnitzer is the Chief Compliance Officer for Pinnacle West Asset Management, Inc., and supervises the firm’s compliance with all applicable securities regulations, including his own, and will adhere to the firm’s policies and procedures. 23