PINE RIDGE ADVISERS LLC

Pine Ridge Advisers LLC 450 Lexington Avenue, 38th Floor New York, New York 10017 March 2025 Item 1 – Cover Page FORM ADV PART 2A FIRM BROCHURE This brochure provides clients with information about the qualifications and business practices of Pine Ridge Advisers LLC (“Pine Ridge” or the “Firm”). The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Registration does not imply that Pine Ridge or any individual providing investment advisory services on behalf of Pine Ridge possess a certain level of skill or training. Please contact Pine Ridge at 212-273-0463 or steve@pineridgeadvisers.com if you have any questions about the contents of this brochure. Additional information about Pine Ridge and its associated persons is available on the Internet at www.adviserinfo.sec.gov.  Item 2 – Material Changes This is an annual amendment to Pine Ridge’s Form ADV and reflects changes since the Firm’s last annual amendment filed on March 28, 2024. Since the last amendment, Pine Ridge notes there have been no material changes to the Form ADV. Investors are encouraged to review this brochure in its entirety. The information set forth in this brochure is qualified in its entirety by the applicable offering and governing documents. In the event of a conflict between the information set forth herein and the applicable offering and governing documents, the information set forth in the applicable offering and governing documents shall control. 2  Item 3 – Table of Contents Item 1 – Cover Page ...................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................ 2 Item 3 – Table of Contents ............................................................................................................................ 3 Item 4 - Advisory Business ............................................................................................................................ 4 Item 5 - Fees and Compensation .................................................................................................................. 5 Item 6 - Performance-Based Fees and Side-By-Side Management ........................................................... 7 Item 7 - Types of Clients ............................................................................................................................... 7 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 8 Item 9 - Disciplinary Information .............................................................................................................. 15 Item 10 - Other Financial Industry Activities and Affiliations ................................................................ 15 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 16 Item 12 - Brokerage Practices .................................................................................................................... 16 Item 13 - Review of Accounts ..................................................................................................................... 19 Item 14 - Client Referrals and Other Compensation ............................................................................... 20 Item 15 - Custody ........................................................................................................................................ 20 Item 16 - Investment Discretion ................................................................................................................. 20 Item 17 - Voting Client Securities .............................................................................................................. 20 Item 18 - Financial Information ................................................................................................................. 21 3  Item 4 - Advisory Business A. The Company Pine Ridge is a Delaware limited partnership that was founded in March 2018. The Firm’s principal place of business is in New York, NY. The principal owner of Pine Ridge is Baldo Fodera. B. Advisory Services Investment Management Services Pine Ridge provides discretionary investment and non-discretionary advice and management services to a pooled investment vehicle (the “Fund”) and separately managed accounts (each a “Separately Managed Account” and collectively, “Managed Accounts”). Separately Managed Account clients are referred to herein as “SMA Clients.” Pine Ridge will create a customized asset allocation strategy to meet a client’s individual investment objectives. Pine Ridge will review a client’s present financial situation, cash flow needs, tax status, existing investments, investment restrictions (if any) and time horizon before determining portfolio allocations and suitable investment managers. Pine Ridge will then set an investment policy that outlines the overall investment objectives and goals, risks, restrictions, strategic asset allocation, investments and ranges, and benchmarks for such clients. The investment policy will provide the principles under which Pine Ridge will manage the client’s investment program. Family Offices Services If requested by the client, Pine Ridge may also provide the following additional family offices services: • Bill paying; • Check writing; and • The coordination of professional and other services (i.e., accounting, legal, insurance, home repair, property management, public relations). C. Client Tailored Services and Client Imposed Restrictions As detailed above, Pine Ridge will create a customized investment strategy to meet a client’s individual investment objectives. Generally, clients are permitted to impose reasonable restrictions on investing in certain securities or types of securities in their advisory accounts, provided, however, that some restrictions may not be accommodated when utilizing Exchange Traded Funds, private funds or with respect to certain third-party investment managers. In addition, a restriction request may not be honored if it is fundamentally inconsistent with Pine Ridge’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent Pine Ridge from properly servicing client accounts. D. Wrap Fee Programs Pine Ridge does not provide portfolio management services to a wrap fee program(s). 4  E. Assets Under Management As of December 31, 2024, Pine Ridge managed $5,055,214,345 of assets on a discretionary basis and $0 on a non-discretionary basis. Item 5 - Fees and Compensation A. Advisory Fees The fees payable by an SMA Client vary based on the size of the Managed Account. Managed Account fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. SMA Clients may incur certain charges imposed by custodians, brokers, and other third parties such as fees charged by managers, custodial fees, deferred sales charges, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Such charges, fees and commissions are exclusive of and in addition to Pine Ridge’s fee, and Pine Ridge does not receive any portion of these commissions, fees, and costs. Pine Ridge does not charge any advisory fees to the Fund. Family Offices Services The fee for the family offices services will be determined on a case-by-case basis and will depend on the nature and complexity of each client's circumstances, the amount of assets under Pine Ridge management and the particular Pine Ridge professional providing the service. Pine Ridge reserves the right to waive the fee for the family offices services in its entirety. Certain family office clients have agreed that, at the sole discretion of the family office client, following each calendar quarter, in addition to an agreed fixed fee, Pine Ridge is eligible to receive a discretionary cash bonus paid by the family office client. The decision as to whether to pay a bonus, and the amount of any bonus, are entirely in the family office client’s absolute discretion. In each such agreement, Pine Ridge and the family office client have expressly agreed that the fact that Pine Ridge may have received a bonus at any time does not give rise to any expectation or entitlement to receive any bonus in the future, or as to the size of any future bonus. B. Payment Method Pine Ridge will notify the client’s qualified custodian of the amount of the fee due and payable to Pine Ridge pursuant to the firm’s fee schedule and advisory agreement. The qualified custodian will not validate or check Pine Ridge’s fees, its corresponding calculation, or the assets on which the fee is based unless the client has retained their services to do so. With the client’s pre-approval, the qualified custodian will “deduct” the fee from the client’s account or, if the client has more than one account, from the account the client has designated to pay Pine Ridge’s advisory fees. The frequency that fees are paid is typically monthly or quarterly as agreed by the client. Each month, the client will receive a statement directly from the qualified custodian showing all transactions, positions, and credits/debits into or from the client’s account. Statements sent after the quarter end will also reflect the advisory fee paid by the client to Pine Ridge. C. Additional Fee Information and Expenses Fees Negotiable Pine Ridge retains the right to modify fees, including minimum account size requirements, in its sole and absolute discretion, on a client-by-client basis. Factors considered include the complexity and nature of the advisory services provided, anticipated amount of assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, and account composition. As stated above, SMA Clients 5  and certain related accounts will pay a reduced fee or may have their investment management fee waived in its entirety. The specific fee schedule is identified in the investment management agreement or fund offering documents entered into with the client. Mutual Fund Fees and Exchange Traded Funds Managed Accounts may hold the shares of registered investment companies (e.g., mutual funds and Exchange Traded Funds). All fees paid to Pine Ridge or third-party investment managers for investment management services are separate and distinct from the fees and expenses charged by these investment companies to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay a deferred sales charge. Miscellaneous Expenses Pine Ridge’s management fee with respect to each Managed Account also does not include certain other charges and expenses, including (a) brokerage charges, which are paid on a transactional basis for the Managed Account, (b) dealer mark-ups or mark-downs on securities purchased or sold for an account through third party dealers and (c) taxes. Professional Fees Fees do not include the services of any co-fiduciaries, accountants, broker dealers or attorneys. Accordingly, the fees of any additional professionals engaged by a client will be billed directly by such professional(s). Private Fund Fees The Fund bears its own expenses, including but not limited to investment expenses (e.g., brokerage commissions, research expenses, interest on margin accounts, administration fees, custodial fees, bank service fees, interest expenses); legal expenses; insurance expenses; compliance expenses; professional fees (including, without limitation, expenses of consultants) relating to investments; accounting expenses (including the cost of accounting software packages); auditing and tax preparation expenses; applicable outside director fees, costs of printing and mailing reports and notices; entity-level taxes; corporate licensing; regulatory expenses (including filing fees); organizational expenses; expenses incurred in connection with the offering and sale of Private Fund interests and other similar expenses related to the Private Fund; and extraordinary expenses. Third-Party Investment Managers Fees and Expenses As stated above, all fees paid to Pine Ridge for its investment management services are separate and distinct from the fees and expenses charged by third-party investment managers. Each third-party investment manager used involves different custodial, administrative, and fee arrangements, and may require certain minimum initial account investments. These fees will generally include a management fee and possible other fees. The actual management fees may be higher or lower for the specific independent money manager. In certain circumstances a client may be able to invest with an independent money manager directly, without the services of Pine Ridge. In that case, the client would not receive the services provided by Pine Ridge which are designed, among other things, to assist the client in determining which third-party investment managers are most appropriate to the client's financial condition and objectives. D. Termination and Refunds A SMA Client should consult the applicable investment management agreement for termination rights. If an account is terminated during a calendar quarter, fees will be adjusted pro rata based upon the number of 6  calendar days in the calendar quarter that the investment management agreement was effective. When possible, Pine Ridge will credit a client’s account for the amount of the refund. E. Additional Compensation Neither Pine Ridge nor its supervised persons receive compensation for the sale of securities or other investment products, and mutual funds. Item 6 - Performance-Based Fees and Side-By-Side Management Pine Ridge’s investment management fees are not based on a share of the capital gains or capital appreciation (i.e., growth in value) of the funds in a client's account (a/k/a "performance-based fees"). Side-by-side management refers to an adviser simultaneously managing accounts that do pay performance- based fees and those that do not; this can create potential conflicts of interest. Pine Ridge does not engage in side-by-side management. As described in Item 5, certain family office clients have agreed that, at the sole discretion of that family office client, following each calendar quarter, in addition to an agreed fixed fee, Pine Ridge is eligible to receive a discretionary cash bonus paid by the family office client. Although a discretionary bonus is not a performance- based fee, the potential for Pine Ridge to receive discretionary bonuses creates incentives and potential conflicts of interest that are similar to the incentives and potential conflicts of interest that are created by a performance-based fee arrangement. The potential for Pine Ridge to receive a discretionary bonus is intended to provide Pine Ridge with an incentive to provide the level of service expected of Pine Ridge by the family office client. The potential to receive a discretionary bonus may create an incentive for Pine Ridge to make investments that are riskier or more speculative than would be the case in the absence of such potential. In addition, in the event that Pine Ridge manages an account as to which the client may pay a discretionary bonus and also manages an account as to which the client does not pay a discretionary bonus, or as to which the client may have paid a discretionary bonus less frequently or in lesser relative amounts, Pine Ridge may have an incentive to favor the account as to which the client pays a discretionary bonus or pays a discretionary bonus more frequently than the client account which does no pay a discretionary bonus or otherwise pays in lesser relative amounts. Item 7 - Types of Clients A. Clients Pine Ridge provides investment advice and management to members of high-net-worth families. B. Engaging the Services of Pine Ridge All clients wishing to engage Pine Ridge for investment advisory services must first sign the applicable investment management agreement, fund offering documents and sign/complete any other document or questionnaire provided by the firm. The investment management agreement will describe the services and responsibilities of Pine Ridge to the client. It also outlines Pine Ridge’s fee in detail. 7  C. Conditions for Managing Accounts As a condition for starting and maintaining a relationship, Pine Ridge imposes a minimum of $50,000,000 in assets under management. Pine Ridge may, in its sole discretion, require a larger amount or accept a smaller amount of initial assets from a potential client depending on the complexity and nature of the advisory services provided, or for any other reason deemed appropriate by Pine Ridge. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis and Investment Strategies As discussed in Item 4 – Advisory Business – Pine Ridge will designate the active discretionary management of Managed Accounts among certain institutional-quality investment managers that manage private investment funds organized as pooled investment vehicles or on a sub-advisory basis. Pine Ridge will only use investment managers for which it has completed full investment and operational due diligence. However, the investment manager(s) selected by Pine Ridge may have specific methodologies, trading processes and operational practices beyond the control of Pine Ridge. Pine Ridge will monitor each investment manager for adherence to the stated strategy, portfolio performance, turnover, team and organizational changes over time, compensation changes, growth in assets under management and product proliferation. Pine Ridge may, in its sole discretion, reallocate client assets among investment managers depending on macroeconomic, market or sector factors and/or according to changes in a client’s financial goals and needs. In evaluating and monitoring third-party investment managers, Pine Ridge will also look for specific qualities and investment principles depending on the specific investment program provided by such investment managers. For example, for a long-only equity investment program, Pine Ridge may seek institutional quality investment managers with deep fundamental research processes and high active share in broad areas such as global equities or in particular niche fields such as Asian emerging markets equities. For a global macro strategy, Pine Ridge may seek investment managers with lower directional market exposure, high alpha, strong downside protection, and lower correlation to traditional markets such as equities and fixed income. Depending on the stage of the development of an investment manager’s trading program, Pine Ridge may also take into consideration other factors, such as: the investment manager’s performance during various time periods and market cycles; the investment manager’s articulation of, and adherence to, a stated investment philosophy and style; the presence of risk management discipline; and alignment of interests. Pine Ridge will evaluate regularly each investment manager to determine whether its investment program is consistent with the client’s investment objectives and whether its investment performance is satisfactory. Subject to restrictions imposed by the investment managers, Pine Ridge may reallocate client assets among the investment managers, terminate existing investment managers and select additional investment managers. B. Risks Associated with Investment Strategies and Methods of Analysis Risk Associated with Methods of Analysis All investment analysis requires subjective assessments and decision-making by experienced investment professionals, however, there is always the risk of an error in judgment. Pine Ridge’s investment analysis methods rely on the assumption that Pine Ridge is provided accurate and unbiased data. While Pine Ridge is alert to indications that data may be incorrect, there is always the risk that the firm’s analysis may be compromised by inaccurate or misleading information. A risk of independent money manager analysis is that the past performance of the independent money manager does not guarantee future results. In addition, Pine Ridge’s subjective judgment may prove incorrect. 8  Investing in securities involves risk of loss that each client should be prepared to bear. The value of a client’s investment may be affected by one or more of the following risks, any of which could cause a client’s portfolio return, the price of the portfolio’s shares or the portfolio’s yield to fluctuate: • Market Risk. The value of portfolio assets will fluctuate as the stock or bond market fluctuates. The value of investments may decline, sometimes rapidly and unpredictably, simply because of economic changes or other events that affect large portions of the market. • Management Risk. A client’s portfolio is subject to management risk because it is actively managed by Pine Ridge’s investment professionals. Pine Ridge will apply its investment techniques and risk analysis in making investment decisions for a client’s portfolio, but there is no guarantee that these techniques and Pine Ridge’s judgment will produce the intended results. • Quantitative Tools Risk. Some of Pine Ridge’s investment techniques may incorporate, or rely upon, quantitative models. There is no guarantee that these models will generate accurate forecasts, reduce risks or otherwise produce the intended results. • Interest Rate Risk. Changes in interest rates will affect the value of a portfolio’s investments in fixed-income securities. When interest rates rise, the value of investments in fixed-income securities tend to fall and this decrease in value may not be offset by higher income from new investments. Interest rate risk is generally greater for fixed-income securities with longer maturities or durations. • Credit Risk. An issuer or guarantor of a fixed-income security, or the counterparty to a derivatives or other contract, may be unable or unwilling to make timely payments of interest or principal, or to otherwise honor its obligations. The issuer or guarantor may default causing a loss of the full principal amount of a security. The degree of risk for a particular security may be reflected in its credit rating. There is the possibility that the credit rating of a fixed-income security may be downgraded after purchase, which may adversely affect the value of the security. Investments in fixed-income securities with lower ratings tend to have a higher probability that an issuer will default or fail to meet its payment obligations. • Allocation Risk. The allocation of investments among different asset classes may have a significant effect on portfolio value when one of these asset classes is performing more poorly than the others. As investments will be periodically reallocated, there will be transaction costs which may be, over time, significant. In addition, there is a risk that certain asset allocation decisions may not achieve the desired results and, as a result, a client’s portfolio may incur significant losses. • Foreign (Non-U.S.) Risk. A portfolio’s investments in securities of non-U.S. issuers may involve more risk than those of U.S. issuers. These securities may fluctuate more widely in price and may be less liquid due to adverse market, economic, political, regulatory or other factors. • Emerging Markets Risk. Securities of companies in emerging markets may be more volatile than those of companies in developed markets. By definition, markets, economies and government institutions are generally less developed in emerging market countries. Investment in securities of companies in emerging markets may entail special risks relating to the potential for social instability and the risks of expropriation, nationalization or confiscation. Investors may also face the imposition of restrictions on foreign investment or the repatriation of capital and a lack of hedging instruments. • Currency Risk. Fluctuations in currency exchange rates may negatively affect the value of a portfolio’s investments or reduce its returns. • Derivatives Risk. Certain strategies involve the use of derivatives to create market exposure. Derivatives may be illiquid, difficult to price and leveraged so that slight changes may produce disproportionate losses for a client’s portfolio and may be subject to counterparty risk to a greater degree than more traditional investments. Because of their complex nature, some derivatives may not perform as intended. As a result, a portfolio may not realize the anticipated benefits from a derivative it holds, or it may realize losses. Derivative transactions may create investment leverage, which may increase a portfolio’s volatility and may require the portfolio to liquidate portfolio securities when it may not be advantageous to do so. 9  • Capitalization Risk. Investments in small- and mid-capitalization companies may be more volatile than investments in large-capitalization companies. Investments in small-capitalization companies may have additional risks because these companies have limited product lines, markets or financial resources. • Liquidity Risk. Liquidity risk exists when particular investments are difficult to purchase or sell, possibly preventing Pine Ridge from selling out of such illiquid securities at an advantageous price. Derivatives and securities involving substantial market and credit risk also tend to involve greater liquidity risk. • Issuer Specific Risk. The value of an equity security or debt obligation may decline in response to developments affecting the specific issuer of the security or obligation, even if the overall industry or economy is unaffected. These developments may comprise a variety of factors, including, but not limited to, management issues or other corporate disruption, political factors adversely affecting governmental issuers, a decline in revenues or profitability, an increase in costs, or an adverse effect on the issuer’s competitive position. • Concentrated Portfolios Risk. Certain investment strategies focus on particular asset classes, countries, regions, industries, sectors or types of investments. Concentrated portfolios are an aggressive and highly volatile approach to trading and investing. Concentrated portfolios hold fewer different stocks than a diversified portfolio and are much more likely to experience sudden dramatic prices swings. In addition, the rise or drop in price of any given holding is likely to have a larger impact on portfolio performance than a more broadly diversified portfolio. • Leverage. While leverage presents opportunities for increasing a client’s total return, it has the effect of potentially increasing losses as well. Accordingly, any event which adversely affects the value of an investment of a client’s account would be magnified to the extent the investment is leveraged. The cumulative effect of the use of leverage in a market that moves adversely to such a client’s investments could result in a substantial loss to such client which would be greater than if such account was not leveraged. • Legal or Legislative Risk. Legislative changes or court rulings may impact the value of investments or the securities’ claim on the issuer’s assets and finances. C. Risks Associated with Specific Securities Utilized Third-party investment managers retained by Pine Ridge may invest in all or some of the following types of securities: Common Stocks The major risks associated with investing in common stocks relate to the issuer’s capitalization, quality of the issuer’s management, quality and cost of the issuer’s services, the issuer’s ability to manage costs, efficiencies in the manufacturing or service delivery process, management of litigation risk and the issuer’s ability to create shareholder value (i.e., increase the value of the company’s stock price). Preferred Stocks Preferred stock dividends are generally fixed in advance. Unlike requirements to pay interest on certain types of debt securities, the company that issues preferred stock may not be required to pay a dividend and may stop paying the dividend at any time. Preferred stock may also be subject to mandatory redemption provisions and an issuer may repurchase these securities at prices that are below the price at which they were purchased by the investor. Under these circumstances, a client account holding such preferred securities could lose money. Convertible Stocks The value of a convertible security is a function of its “investment value” (determined by its yield in 10  comparison with the yields of other securities of comparable maturity and quality that do not have a conversion privilege) and its “conversion value.” The investment value of a convertible security is influenced by changes in interest rates, the credit standing of the issuer and other factors. The conversion value of a convertible security is determined by the market price of the underlying common stock. A convertible security generally will sell at a premium over its conversion value by the extent to which investors place value on the right to acquire the underlying common stock while holding a fixed-income security. A convertible security will generally be subject to redemption at the option of the issuer at a price established in the convertible security’s governing instrument. If a convertible is called for redemption, a client will be required to permit the issuer to redeem the security, convert it into the underlying common stock or sell it to a third party. Any of these actions could have an adverse effect on a client’s ability to achieve their investment objective. Warrants and Rights Warrants are securities, typically issued with preferred stocks or bonds, which give the holder the right to purchase a given number of shares of common stock at a specified price and time. The price of a warrant usually represents a premium over the applicable market value of the common stock at the time of the warrant’s issuance. Warrants have no voting rights with respect to the common stock, receive no dividends and have no rights with respect to the assets of the issuer. Investments in warrants and rights involve certain risks, including the possible lack of a liquid market for the resale of the warrants and rights, potential price fluctuations due to adverse market conditions or other factors and failure of the price of the common stock to risk. If the warrant is not exercised within the specified time period, it becomes worthless. Fixed-Income Securities Different forms of fixed-income instruments, such as bonds, money market funds, and certificates of deposit may be affected by various forms of risk, including: • Interest Rate Risk. The risk that the value of the fixed income holding will decrease because of an increase in interest rates. • Liquidity Risk. The inability to readily buy or sell an investment for a price close to the true underlying value of the asset due to a lack of buyers or sellers. While certain types of fixed-income securities are generally liquid (e.g., corporate bonds), there are risks which may occur such as when an issue trading in any given period does not readily support buys and sells at an efficient price. Conversely, when trading volume is high, there is also the risk of not being able to purchase a particular issue at the desired price. • Credit Risk. The potential risk that an issuer would be unable to pay scheduled interest or repay principal at maturity, sometimes referred to as “default risk.” Credit risk may also occur when an issuer’s ability to make payments of principal and interest when due is interrupted. This may result in a negative impact on all forms of debt instruments. • Reinvestment Risk. With declining interest rates, investors may have to reinvest income or principal at a lower rate. • Duration Risk. Duration is a measure of a bond’s volatility, expressed in years to be repaid by its internal cash flow (interest payments). Bonds with longer durations carry more risk and have higher price volatility than bonds with shorter durations. High-Yield Securities High-yield corporate debt securities with credit rating below investment grade (commonly referred to as “junk bonds”) may be subject to potentially higher risks of default and volatility than other debt securities, including risks that the issuer may not be able to meet its obligations to repay principal or interest. These 11  types of debt securities are more susceptible to credit risk than investment grade securities and are considered to be more speculative in nature than higher-quality fixed-income securities. In addition, issuers of high-yield securities may not be as strong financially as those issuing debt securities with higher credit ratings. Municipal Bonds In addition to the risks set forth under “Fixed-Income Securities” above, municipal bonds are susceptible to events in the municipality that issued the bond, or the security posted for the bond. These events may include economic or political policy changes, changes in law, tax base erosion, state constitutional limits on tax increases, budget deficits or other financial difficulties and changes in the credit rating assigned to municipal issues. Commercial Paper and Certificates of Deposit Commercial Paper and Certificates of Deposit are generally considered safe instruments, although they are subject to the level of general interest rates, the credit quality of the issuing bank and the length of maturity. With respect to certificates of deposit, depending on the length of maturity, there can be prepayment penalties if the client needs to convert the certificate of deposit to cash prior to maturity. Federal Agency Securities Although the issuer may be chartered or sponsored by an Act of Congress, the issuer is not funded by Congressional appropriations and its debt and equity securities are neither guaranteed nor insured by the U.S. Government. Without a more explicit commitment, there can be no assurance that the U.S. Government will provide financial support to such issuers or their securities. Exchange Traded Funds (ETFs) An ETF holds a portfolio of securities designed to track a particular market segment or index. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed- based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. ETFs are subject to risks similar to those of stocks. Investment returns will fluctuate and are subject to market volatility, so that when shares are sold they may be worth more or less than their original cost. ETF shares are bought and sold at market price (not Net Asset Value) and are not individually redeemed from the fund. There is also the risk that a manager may deviate from the stated investment mandate or strategy of the ETF which could make the holdings less suitable for a client’s portfolio. ETFs may also carry additional expenses based on their share of operating expenses and certain brokerage fees, which may result in the potential duplication of certain fees. In addition, while many ETFs are known for their potential tax efficiency and higher “qualified dividend income” (QDI) percentages, there are assets classes within these ETFs or holding periods that may not benefit. Shorter holding periods, as well as commodities and currencies that may be part of an ETF’s portfolio, may be considered “non-qualified” under certain tax code provisions. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may have no way to dispose of such shares. Mutual Funds - Equity Funds The major risks associated with investing in equity mutual funds is similar to the risks associated with investing directly in equity securities, including market risk, which is the risk that investment returns will fluctuate and are subject to market volatility, so that an investor’s shares, when redeemed or sold, may be worth more or less than their original cost. Other risks include the quality and experience of the portfolio management team and its ability to create fund value by investing in securities that have positive growth, the 12  amount of individual company diversification, the type and amount of industry diversification and the type and amount of sector diversification within specific industries. In addition, there is the risk that a manager may deviate from the stated investment mandate or strategy of the mutual fund which could make the holdings less suitable for a client’s portfolio. Also, mutual funds tend to be tax inefficient and therefore investors may pay capital gains taxes on fund investments while not having yet sold their shares in the fund. Mutual funds may also carry additional expenses based on their share of operating expenses and certain brokerage fees, which may result in the potential duplication of certain fees. Mutual Funds - Fixed-Income Funds In addition to the risks associated with investing in equity mutual funds, fixed-income mutual funds also have the same risks as set forth under “Fixed-Income Securities” listed above. Mutual Funds - Index Funds Index Funds have the potential to be affected by “tracking error risk” which means a deviation from a stated benchmark index. Since the core of a portfolio may attempt to closely replicate a benchmark, the source of the tracking error (deviation) may come from a “sample index” that may not closely align to the benchmark. In addition, while many index mutual funds are known for their potential tax efficiency and higher “qualified dividend income” (QDI) percentages, there are assets classes within these funds or holding periods that may not benefit. Shorter holding periods, as well as commodities and currencies that may be part of a fund’s portfolio, may be considered “non-qualified” under certain tax code provisions. Options There are numerous risks associated with transactions in options on securities or securities indexes. A decision as to whether, when and how to use options involves the exercise of skill and judgment, and even a well-conceived transaction may be unsuccessful to some degree because of market behavior or unexpected events. In the case of index options, the client incurs basis risk between the performance of the underlying portfolio and the performance of the underlying index. For example, the underlying portfolio may decline in value while the underlying index may increase in value, resulting in a loss on the call option while the underlying portfolio declines as well. Real Estate Related Securities Investing in real estate related securities includes, among others, the following risks: possible declines in the value of real estate; risks related to general and local economic conditions, including increases in the rate of inflation, possible lack of availability of mortgage funds, overbuilding, extending vacancies of properties, increases in competition, property taxes and operating expenses, changes in zoning laws, costs resulting from clean-up of, and liability to third-parties for damages resulting from, environmental problems, casualty and condemnation losses, uninsured damages from floods, earthquakes or other natural disasters, limitations on and variations in rents and changes in interest rates. Investing in Real Estate Investment Trusts (“REITs”) involves certain unique risks in addition to those risks associated with investing in real estate in general. REITs are dependent upon the skills of management, are not diversified and are subject to cash flow dependency, default by borrowers and self-liquidation. Structured Products A portfolio’s investments in structured finance arrangements, including Collateralized Mortgage Obligations (CMOs), Collateralized Bond Obligations (CBOs) Collateralized Debt Obligations (CDOs) and Collateralized Loan Obligations (CLOs), involve the risks associated with the underlying pool of securities or other assets, as well as risks different or greater than the risks affecting the underlying assets. In particular, these investments may be less liquid than other debt obligations, making it difficult to value an investment or sell the investment in a timely manner or at an acceptable price. 13  Master Limited Partnerships Master Limited Partnerships (MLPs) are a type of limited partnership that is publicly traded and sells like a common stock on the major stock exchanges. There are two types of partners in this type of partnership: The limited partner is the person or group that provides the capital to the MLP and receives periodic income distributions from the MLP’s cash flow, whereas the general partner is the party responsible for managing the MLP’s affairs and receives compensation that is linked to the performance of the venture. MLP investors face several kinds of risk that are inherent in these types of investments and in the market, including loss of money, volatility and interest rate risk. Alternative Investments The performance of alternative investments (e.g., commodities, futures, hedge funds; funds of hedge funds, private equity or other types of limited partnerships) can be volatile. Alternative investments generally involve various risk factors and liquidity constraints, a complete discussion of which is set forth in the offering documents of each specific alternative investment. Due to the speculative nature of alternative investments a client must satisfy certain income or net worth standards prior to investing. Private Equity Funds Private Equity Funds may be affected by various forms of risk, including: • Long-term Investment. Unlike mutual funds, which generally invest in publicly traded securities that are relatively liquid, private equity funds generally invest in large amounts of illiquid securities from private companies. Depending on the strategy used, private real estate funds will have illiquid underlying investments that may not be easily sold, and investors may have to wait for improvements or development before any redemption. Given the illiquid nature of the underlying purchases made by private equity and private real estate managers, private equity and private real estate funds are considered long-term investments. Private equity funds are generally set up as 10- to 15-year investments with little or no provision for investor redemptions. Private real estate funds are generally seven-to-ten-year investments and also have limited provisions for redemptions. With long-term investments, clients should consider their financial ability to bear large fluctuations in value and hold these investments over a number of years. • Difficult Valuation Assessment. The portfolio holdings in private equity and private real estate funds may be difficult to value, because they are not usually quoted or traded on any financial market or exchange. As such, no easily available market prices for most of a fund’s holdings are available. Additionally, it may be hard to quantify the impact a manager has had on underlying investments until those investments are sold. • Lack of Liquidity. Private equity and private real estate funds are not “liquid” (they can’t be sold or exchanged for cash quickly or easily), and the interests are typically non-transferable without the consent of a fund’s managing member. As a result, private equity and private real estate funds are generally only suitable for sophisticated investors who have carefully considered their financial capability to hold these investments for the long term. • Capital Call Default Consequences. Answering capital calls to provide managers with the pledged capital is a contractual obligation of each investor. Failure to meet this requirement in a timely manner could elicit significant adverse consequences, including, without limitation, the forfeiture of the defaulting investor’s interest in the fund. • Leverage. Private equity and private real estate funds may use leverage in connection with certain investments or participate in investments with highly leveraged capital structures. Although the use of leverage may enhance returns and increase the number of investments that can be made, leverage also involves a high degree of financial risk and may increase the exposure of such investments to factors such as rising interest rates, downturns in the economy or deterioration in the condition of the assets underlying such investments. 14  • Lack of Transparency. Private equity and private real estate funds are not required to provide investors with information about their underlying holdings or provide periodic pricing and valuation information. Therefore, investors often putting their complete trust in the managers’ abilities to meet their funds’ objectives, without the benefit of knowing their investment selections. This lack of information may make it more difficult for investors to evaluate the risks associated with the funds. • Manager Risk. Private equity and private real estate fund managers have total investment authority over their funds, and the managers’ skill is normally responsible for the investment returns. Therefore, if the founder or key person departs, the returns of the fund may be impacted. Investors have no control or influence in the management of the fund, although they will receive periodic reports from the fund manager. Also, investment in one fund that uses a generally similar investment strategy as another fund could lessen overall diversification, and consequently, increase investment risk. • Regulation. Private equity and private real estate funds are subject to fewer regulatory requirements than mutual funds and other registered investment company products and thus may offer fewer legal protections than an investor would have if they invested in more traditional investments. There may be other circumstances not described here that could adversely affect a client’s investment and prevent their portfolio from reaching its objective. Pine Ridge’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the above risks. Item 9 - Disciplinary Information Pine Ridge is required to disclose any legal or disciplinary events that are material to a client’s or a prospective client’s evaluation of the firm’s advisory business or the integrity of Pine Ridge’ management. Neither Pine Ridge nor any member of its management has been involved in a material criminal or civil action in a domestic, foreign or military jurisdiction, an administrative enforcement action, or self-regulatory organization preceding that would reflect poorly upon Pine Ridge’s advisory business or the integrity of the firm. Item 10 - Other Financial Industry Activities and Affiliations A. Broker-Dealer Registration and Registered Representatives Pine Ridge is not registered, nor does it have an application pending to register, as a broker-dealer. B. Futures and Commodity Registration Pine Ridge is not registered, nor does it have an application pending to register, as a futures commission merchant, commodity pool operator or a commodity trading advisor. No management person is registered, nor does any management person have an application pending to register, as an associated person of a futures commission merchant, commodity pool operator or a commodity trading advisor. C. Financial Industry Affiliations Pine Ridge’s primary business is as an investment advisor as described in this brochure. D. Selection of Other Advisers Pine Ridge does not receive, directly or indirectly, compensation from investment managers that it selects for its clients. 15  Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Pine Ridge has adopted a written Code of Ethics to prevent violations of federal securities laws. Pine Ridge’s Code of Ethics is predicated on the principle that the firm owes a fiduciary duty to its clients. Accordingly, Pine Ridge expects all of its associated persons to act with honesty, integrity and professionalism and to adhere to federal and state securities laws. All officers, managers, directors, members and employees of the firm and any other person who provides advice on behalf of Pine Ridge and is subject to Pine Ridge’s control and supervision are required to adhere to the Code of Ethics. At all times, the firm and its associated persons must (i) place client interests ahead of the firm’s; (ii) engage in personal investing that is in full compliance with the firm’s Code of Ethics; and (iii) avoid taking advantage of their position. A copy of Pine Ridge’s Code of Ethics is available to any client or prospective client upon request. For a copy, please contact Pine Ridge at 212-273-0463. B. Invest in Same Securities as Clients From time to time, individuals associated with Pine Ridge may buy, sell, or hold in their personal accounts the same securities that are held in client accounts. To minimize conflicts of interest, and to maintain the fiduciary responsibility Pine Ridge has to its clients, the firm has established the following personal securities transaction policy to monitor the personal securities transactions and securities holdings of each of Pine Ridge’s “access persons.” Pine Ridge’s securities transaction policy requires that an access person must provide the Chief Compliance Officer with a written report of their current securities holdings within ten (10) days after becoming an access person. Additionally, each access person must provide the Chief Compliance Officer with a written report of the access person’s current securities holdings at least once each twelve (12) month period thereafter on a date Pine Ridge selects. The Chief Compliance Officer is required to review these reports to verify that personal securities transactions are conducted in accordance with the Code of Ethics. In addition, Pine Ridge and its eligible personnel may also invest in Private Funds of its or their choosing but are not required to invest in the Private Funds. It is expected that, if such investments are made, the size and nature of these investments will change over time. Neither Pine Ridge nor its personnel are required to keep any minimum investment in any of the Private Funds. C. Engaging in Transactions at Same Time as Client From time to time, individuals associated with Pine Ridge may, at or about the same time, buy, sell, or hold in their personal accounts the same securities that the firm recommends to its clients. This practice may create a situation where such individuals are in a position to materially benefit from the sale or purchase of those securities. Therefore, this situation creates a potential conflict of interest. As indicated above in Item 11.B, Pine Ridge has a personal securities transaction policy in place to mitigate any potential conflicts of interest. D. Additional Information At times, Pine Ridge or its related persons may purchase securities that it deems appropriate only for its or their own account. Based on the experience of Pine Ridge or its related persons holding the securities and on further research and due diligence, Pine Ridge may at a later time purchase such securities for client accounts at prices which might be higher or lower than those originally paid. Item 12 - Brokerage Practices Except for the general investment guidelines set forth in the offering memorandum of a Fund, there are no limitations on the authority of Pine Ridge with respect to investment or brokerage discretion. Pine Ridge does not intend to enter into agreements with broker- dealers regarding specific amounts of brokerage, nor does Pine Ridge intend to enter into soft-dollar arrangements. Pine Ridge selects broker-dealers based on the overall benefit and quality of the services that they provide and not solely based on the amount of their fees. 16  In some cases, federal and state laws (such as the Employee Retirement Income Security Act of 1974) may limit or restrict the selection of broker-dealers. A. Brokerage Selection For those situations where Pine Ridge makes a direct securities investment (e.g., ETFs, money market funds) in a client’s account, Pine Ridge will direct transactions through broker-dealers that it reasonably believes will provide best execution. Best Execution Best execution has been defined by the SEC as the “execution of securities transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances.” The best execution responsibility applies to the circumstances of each particular transaction and an investment adviser must consider the full range and quality of a broker-dealer’s services, including, among other things, execution capability, commission rates, the value of any research, financial responsibility and responsiveness. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while Pine Ridge will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client transactions. Pine Ridge will periodically and systematically review its policies and procedures regarding recommending broker-dealers to its clients in light of its duty to obtain best execution. Broker Analysis Pine Ridge evaluates a wide range of criteria in seeking the most favorable price and market for the execution of transactions. These include the broker-dealer’s trading costs, efficiency of execution and error resolution, financial strength and stability, capability, positioning and distribution capabilities, information in regard to the availability of securities, trading patterns, statistical or factual information, opinion pertaining to trading and prior performance in serving Pine Ridge. Pine Ridge are responsible for continuously monitoring and evaluating the performance and execution capabilities of brokers that transact orders for client accounts to ensure consistent quality executions. In addition, Pine Ridge periodically reviews its transaction costs in light of current market circumstances and other relevant information. Soft Dollar Benefits Pine Ridge does not have any commitments or understandings to trade with specific brokers or to generate a specific level of brokerage commission with a particular broker to receive discounted brokerage or research services. Directed Brokerage For those Managed Accounts where Pine Ridge has discretion and except where Pine Ridge has delegated investment discretion to a sub-advisor, Pine Ridge has full discretionary authority to manage the Managed Accounts, including authority to make decisions with respect to the brokers or dealers to be used for a particular transaction, and commissions or markups and markdowns paid. Pine Ridge’s authority is limited by its own internal policies and procedures and each Managed Account’s investment management agreement and guidelines. Certain clients may direct Pine Ridge to use particular brokers-dealers for executing transactions in their accounts. With regard to client directed brokerage, Pine Ridge is required to disclose that Pine Ridge may be 17  unable to negotiate commissions, block or batch orders or otherwise achieve the benefits described above, including best execution. Directed brokerage commission rates may be higher than the rates Pine Ridge might pay for transactions in non-directed accounts. Therefore, directing brokerage may cost clients more money. Pine Ridge reserves the right to decline acceptance of any client account that directs the use of a broker- dealer if Pine Ridge believes that the broker-dealer would adversely affect Pine Ridge’s fiduciary duty to the client and/or ability to effectively service the client portfolio. As a general rule, Pine Ridge encourages each client to compare the possible costs or disadvantages of directed brokerage against the value of custodial or other services provided by the broker-dealer to the client in exchange for the directed brokerage designation. B. Trade Aggregation and Allocation There are occasions on which Managed Account portfolio transactions will be executed as part of concurrent authorizations to purchase or sell the same security for one or more clients. When it is advantageous for Pine Ridge to execute a transaction on behalf of more than one Managed Account, it is the Firm’s policy to aggregate trades whenever possible to achieve equal pricing across the Managed Accounts and to reduce transaction costs. Pine Ridge may choose not to aggregate trades in avoidance of a perceived or actual conflict of interest, provided that clients are treated fairly and equitably over time. On occasions when trades for Managed Account portfolios are not aggregated, trades generally will be processed in the order that they are placed with the broker or counterparty selected by Pine Ridge. As a result, certain trades in the same security for one client (including a client in which Pine Ridge and its personnel may have a direct or indirect interest) may receive more or less favorable prices or terms than another client, and orders placed later may not be filled entirely or at all, based upon the prevailing market prices at the time of the order or trade. The use of derivative instruments for certain Managed Accounts may also result in different effective net prices from other accounts. C. Investment Allocation Pine Ridge may give advice or take action with respect to the investments of one or more Managed Accounts that may not be given or taken with respect to other Managed Accounts with similar investment programs, objectives, and strategies. Accordingly, Managed Accounts with similar strategies may not hold the same securities or instruments or achieve the same performance. Pine Ridge also may advise Managed Accounts with conflicting programs, objectives or strategies. These activities also may adversely affect the prices and availability of other securities or instruments held by or potentially considered for one or more Managed Accounts. Finally, Pine Ridge and its personnel may have conflicts in allocating their time and services among the Managed Accounts. Pine Ridge will devote as much time to each Managed Account as Pine Ridge deems appropriate to perform its duties in accordance with its management agreements. Pine Ridge manages investments on behalf of a number of clients. Certain clients have investment programs that are similar to or overlap and may, therefore, participate with each other in investments. It is the policy of Pine Ridge to allocate investment opportunities for Managed Accounts fairly and equitably, to the extent possible, over a period of time. Pine Ridge, however, will have no obligation to purchase, sell or exchange any security or financial instrument for a Managed Account which Pine Ridge may purchase, sell or exchange for another Managed Account if Pine Ridge believes in good faith at the time the investment decision is made that such transaction or investment would be unsuitable, impractical or undesirable for a particular Managed Account. Pine Ridge generally makes investment decisions among Managed Accounts depending on the particular investment strategy pursued by each Managed Account. Allocations among Managed Accounts within a particular strategy are then made generally on a pro rata basis in proportion to the relative value of each Managed Account eligible net assets, or on a pro rata basis in proportion to the actual position size held by each Managed Account. However, Pine Ridge may take into consideration a number of additional factors, including, among others, the nature and size of the proportion of a securities issue likely to be available to Pine Ridge or the nature and size of the proposed sale; the investment objectives and investment strategy, tax 18  consequences (if applicable), risk tolerances, time horizons and restrictions and guidelines of Managed Accounts; the eligibility to invest in initial public offerings; the relative size and cash availability of the applicable strategy within the Managed Account; the ability to borrow and the cost of borrowed funds; legal restrictions, including those that may arise in foreign jurisdictions; the liquidity of the investment relative to the need of each Managed Account; the degree of specialization of a Managed Account relative to the investment offered; the relative historical participation of a Managed Account in the investment; the difficulty of liquidating an investment for more than one client; the possibility that an allocation may result in a small or odd lot; new clients with a substantial amount of investable cash; and other factors that may be considered relevant. Investment opportunities considered by Pine Ridge to be appropriate for Managed Accounts following similar investment strategies will generally, over time, be equitably allocated based on considerations such as relative capital, specific investment guidelines, composition of the portfolios at the time of purchase and tax considerations. Pine Ridge may combine purchase or sale orders on behalf of Managed Accounts and allocate the securities or other assets so purchased or sold, on an average price basis, among such accounts Pine Ridge may enter into arrangements with brokers to open such “average price” accounts wherein orders placed during a trading day are placed on behalf of Managed Accounts and are allocated among such accounts using an average price. Pine Ridge’s portfolio managers are responsible for the investment decisions made by them on behalf of clients. Item 13 - Review of Accounts A. Periodic Reviews Pine Ridge performs various daily, weekly, monthly, quarterly and periodic reviews of each client’s portfolio. B. Other Reviews More frequent reviews may be triggered by material changes in variables such as a client's individual circumstances, or the market, political or economic environment. C. Reports Pine Ridge will provide annual audited financial statements of its proprietary Private Fund to their partners/shareholders within 120 days of the applicable Private Fund’s fiscal year end. Investors in the Private Fund will generally receive periodic reports from Pine Ridge documenting the performance of the Private Fund. In addition, Pine Ridge will issue investors tax reports and audited financial statements concerning their respective Private Funds within 120 days of the end of the Private Fund’s fiscal year. Each beneficial owner and interested parties upon the client’s authorization with respect to its Managed Account typically receive a quarterly commentary letter from Pine Ridge, as well as monthly or quarterly account statements directly from their respective broker-dealer or custodian. In addition, Pine Ridge’s personnel may participate in periodic portfolio reviews with clients at Pine Ridge’s discretion, which are attended by the appropriate members of Pine Ridge’s investment staff. While all investors generally receive similar information, to the extent an investor receives additional information (that other investors have not received), which is in addition to information provided in a Private Fund’s regular reports to investors, such information may provide such investor with greater insight into the Private Fund’s activities. 19  Item 14 - Client Referrals and Other Compensation Pine Ridge does not pay any third parties for referrals and does not receive any special or added compensation from any sub-advisers or other unrelated third parties for client referrals. Item 15 - Custody Separate Managed Accounts and Private Funds Pine Ridge is deemed to have custody over certain Separately Managed Accounts because of the Firm’s ability to transfer assets between certain client accounts. In addition, Pine Ridge has custody over private fund client(s) because Pine Ridge or an affiliate is the general partner or managing member of the private fund. Accordingly, Pine Ridge has engaged an independent public accountant to perform an annual surprise audit of those accounts of which Pine Ridge has custody or is deemed to have custody. The accountant will file a Form ADV E with the SEC within 30 days after the completion of the examination. Custody of separately managed account client assets and private fund assets will be maintained with independent qualified custodians. Pine Ridge will not have physical custody of any assets in the client’s accounts except as permitted for payment of advisory fees. Clients will receive directly from the custodian at least quarterly a statement showing all transactions occurring in the client’s accounts during the period covered by the account statements, and the funds, securities and other property in the client’s accounts at the end of the period. Clients are urged to compare the account statements provided by the broker- dealer/custodian with any statements provided by Pine Ridge. Item 16 - Investment Discretion Except where Pine Ridge has delegated investment discretion to a sub-advisor or other investment manager, Pine Ridge serves as discretionary investment advisor to clients who open Managed Accounts with full power and authority to supervise and make investment decisions on behalf of Managed Accounts without prior consultation with clients. Clients may impose reasonable guidelines or restrictions upon Pine Ridge’s ability to invest on their behalf; provided, however, that a restriction request may not be honored if it is fundamentally inconsistent with Pine Ridge’s investment philosophy, runs counter to the client’s stated investment objectives, or would prevent Pine Ridge from properly servicing client accounts. Pine Ridge’s investment decisions and advice with respect to each Managed Account are subject to each client’s investment objectives and guidelines, as set forth in the client’s investment management agreement and investment policy statement, as well as any written instructions provided by the client to Pine Ridge. Item 17 - Voting Client Securities Pine Ridge has adopted and implemented policies and procedures for voting proxies with respect to portfolio securities held by Pine Ridge on behalf of its clients. The policies and procedures are reasonably designed to ensure that proxies are voted in the clients' best interest, in accordance with the Firm's fiduciary duties and Rule 206(4)-6 under the Investment Advisers Act of 1940, as amended. Pine Ridge considers the “best interests” of its clients to mean their best long-term economic interests. General Statement of Policies and Procedures Pine Ridge votes proxies for the exclusive benefit, and in the best economic interest, of its clients. Such exercise of voting rights shall be subject to the same standard of care as is generally applicable to Pine Ridge’s performance of its duties, as set forth in the advisory agreement with each client. The policies and procedures described here are designed to be guidelines. However, each vote is ultimately cast on a case-by-case basis, taking into consideration the relevant facts and circumstances at the time of the vote. Any material conflicts that may arise will be resolved in the best interests of the Firm’s clients. 20  Clients may obtain a copy of Pine Ridge’s complete proxy voting policies and procedures upon request. Clients may also request and obtain information from the Firm on any proxies voted by Pine Ridge on behalf of their account(s). Item 18 - Financial Information A. Prepayment of Fees Because Pine Ridge does not require or accept prepayment of more than $1,200 in fees six months or more in advance, Pine Ridge is not required to include a balance sheet with this firm brochure. B. Financial Condition Pine Ridge does not have any financial condition that would impair the firm’s ability to meet contractual and fiduciary commitments to its clients. C. Bankruptcy Pine Ridge has never been the subject of a bankruptcy petition. 21