Firm Description
Park Avenue Securities LLC (“PAS”) is a dually registered broker-dealer and investment adviser that provides
investment advisory services through investment adviser representatives (each, an “IAR”). PAS has been
registered with the SEC as an investment adviser since November 13, 2000. Additional information about PAS is
available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about
persons who are registered as IARs of PAS.
Principal Owners
PAS is a wholly owned subsidiary of The Guardian Life Insurance Company of America (“GLIC”), a New York
mutual life insurance company. GLIC and its affiliates sell their products through a system of insurance agents,
most of whom are also registered representatives and IARs of PAS.
Types of Advisory Services Offered
PAS offers proprietary investment advisory programs (each, a “PAS Proprietary Program”) and select third- party
investment advisory programs (each, a “Third-Party Investment Advisory Program”), together the “Programs.” In
addition, certain IARs offer financial planning, consulting, business planning and education services to clients.
Understanding your Relationship with PAS
PAS is subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and as a registered
investment adviser, PAS, along with its IARs, have a fiduciary duty to you. This generally means that PAS and
its IARs will act in your best interest when providing investment advice under the Advisers Act and will disclose
or avoid all material conflicts of interest. Throughout the various sections of this Brochure PAS has identified
material conflicts of interest where you see such language bolded or within specific sections identified
as discussing material conflict of interest. Within the advisory programs described in this Brochure, PAS
provides services as an investment adviser under the Advisers Act.
In providing investment advice, your PAS Investment Adviser Representative (IAR”) can select from different
products and programs. This includes advisory programs described in this brochure and other advisory programs
described in PAS Wrap Fee Brochures. Your IAR can also act in his or her capacity as a registered representative
of PAS providing securities recommendations in a PAS brokerage account. This includes the recommendations
and sales of products such as mutual funds, variable annuities, variable life, or individual stocks and bonds, if
appropriately licensed. In each of these scenarios, your IAR provides different services and will be paid differently
depending on the account type, product or program selected. There are important differences within these types
of accounts/products in terms of ongoing services provided, costs and the obligations of your IAR and PAS.
You should discuss with your IAR the benefits and costs associated with the different advisory programs
available at PAS as well as what relationship may be best for you. This should include a discussion about the
benefits and costs associated with a brokerage versus an advisory relationship, the products offered within each
relationship and the IAR’s ongoing obligations when acting as an IAR versus a registered representative.
An advisory account may not be appropriate for low volume trading activity, if you have a long term buy-and- hold
investment strategy or if you direct PAS to execute a significant amount of trades on your behalf. In these
instances, a transaction-based brokerage account may be more appropriate. Trading activity and the costs and
expenses associated with an investment product, among other things, should be considered when deciding
whether an advisory account is appropriate for you.
Based on the following scenarios, a brokerage relationship may be right for you, if:
You want an adviser to provide occasional advice and recommendations on certain investments and
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execute on your investment decisions;
You plan to buy only a few securities and follow a buy-and-hold strategy over a long time period without
the need for ongoing advice from an adviser; and/or
You wish to pay fees based on each transaction that you place and not for ongoing advice.
As a broker-dealer, PAS offers a variety of financial products and services and can render advice as to the value
and/or advisability of purchasing or selling securities without receiving special compensation where such advice
is solely incidental to the conduct of its business as a broker-dealer. In certain situations, PAS may offer general,
impersonal investment advice in the form of publications and other services. PAS will not be deemed to be
providing investment advisory services unless it has entered into a contract with the client for that purpose.
If you are seeking one or more of the following scenarios, an investment advisory relationship may be right for
you:
Discretionary management of your investment portfolio;
Ongoing advice and investment services;
Trading and rebalancing of your portfolio on a periodic basis; and
An annual fee that is based on the amount of assets managed and is not tied to the number or type of
transactions in the account.
In some cases, an investment advisory relationship may cost you more than a brokerage relationship and vice
versa. You should periodically discuss the various options with your IAR. PAS IARs are compensated for
servicing and providing investment advice for the Programs. The compensation paid to IARs for each of the
Programs is generally comparable, except for VestWiseTM, the digital advisory program offered by PAS, which
has a lower fee structure. This compensation may be more than what the IAR would receive if you pay separately
for investment advice, brokerage, and other services.
Under PAS Proprietary Programs, clients must establish an account through PAS with Pershing LLC
(“Pershing”). Pershing acts as the clearing firm and custodian for client assets within PAS Proprietary Programs.
Accordingly, all trading activity under PAS Proprietary Programs will be processed through client accounts with
Pershing. In its capacity as a clearing and custodial firm Pershing performs centralized custody, bookkeeping
and execution functions.
Pershing handles the delivery and receipt of securities purchased or sold on behalf of PAS clients, receives, and
distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender
offers, and redemptions. Pershing sends statements of account activity no less often than quarterly.
Rollovers and Fiduciary Acknowledgement
When PAS and its IARs recommend to a) participants in ERISA-covered retirement plans to roll over assets into
an IRA or b) owners of IRAs to roll over or transfer assets to another IRA, PAS and its IARs are fiduciaries within
the meaning of Title I of the Employee Retirement Income Security Act of 1974 and/or the Internal Revenue
Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not
necessarily mean PAS and its IARs are acting as fiduciaries for purposes of other applicable laws. This
acknowledgement of fiduciary status does not confer contractual rights or obligations on you, PAS, or the IARs.
With respect to rollover transactions, certain portions of this Firm Brochure disclosure are intended to comply
with requirements under the U.S. Department of Labor’s Prohibited Transaction Exemption 2020-02, specifically;
(i) information regarding the scope of services provided by PAS and its IARs, (ii) the fiduciary acknowledgement
above, and (iii) the description of the material conflicts of interest under which PAS and your IARs are operating.
Rollovers
PAS and your IAR get paid when you engage in a rollover transaction. PAS can recommend that you
rollover assets from your workplace retirement plan or from an existing IRA into an IRA account with
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PAS. When you engage in a rollover to an IRA, PAS and your IAR will receive compensation in
connection with the investments you will acquire for your IRA account and hold in the account. This
compensation incentivizes PAS and your IAR to make a rollover recommendation.
Transferring an Existing Account to PAS Programs
There may be instances in which you have chosen to open a Program account that requires you to liquidate
existing investment assets or accounts and transfer the proceeds to the Program in which you wish to participate.
In making the request to liquidate assets and transfer your proceeds, you may experience costs due to the
requested liquidation. These costs can include, but are not limited to, account termination charges, contingent
deferred sales charges, surrender charges, and commissions on the sale of stocks, bonds, exchange traded
funds, closed end mutual funds, limited partnership shares or any other securities you hold in these accounts. If
you redeem, surrender, or sell existing assets to fund an account you should carefully consider the costs and
benefits of the transaction including any tax liability.
You should also ask your IAR if the sale of the assets used to fund your Program account will benefit your
IAR in the form of a commission or fee payable to them and take that into consideration before you
initiate the liquidation of any assets to fund your Program account. The liquidation of any investment may
trigger taxable gains or losses, could trigger the Alternative Minimum Tax (AMT) and may require additional
quarterly estimated tax payments. Neither PAS nor your IAR provide tax advice or tax management services.
You are responsible for any taxable events. You should always consult with your tax advisor for specific tax
advice.
Tailored Client Relationships
For programs other than VestWiseTM, the digital advisory program offered by PAS, your IAR will request
information from you regarding your financial background, investment experience, investment objectives, risk
tolerance, and any reasonable restrictions that you wish to impose on investing in certain specific securities and
types of securities and will provide important disclosures to you. Your IAR will work with you to help you
determine your investment goals and will assist you in selecting one of the PAS Proprietary Programs or a Third-
Party Investment Advisory Program. As your goals and objectives change over time, your IAR will update your
records and client file and may provide new recommendations and advice that fit your needs. You should notify
your IAR promptly if there are any changes in your financial situation, risk tolerance, investment objectives or
account restrictions. Your IAR will periodically review performance and other periodic reports provided to you
and will offer to meet with you at least annually to review your financial situation and investment objectives.
Client Advisory Agreement
If you select a PAS Proprietary Program, you will sign a client agreement which consists of a Statement of
Investment Selection and Terms and Conditions (the “Client Agreement”). The Client Agreement will detail all of
the important information pertaining to your account, including the management fee and the termination
provisions. You are encouraged to read all of the terms of the Client Agreement.
In a Third-Party Investment Advisory Program, you will sign an investment advisory agreement directly with the
third-party investment adviser or, in certain circumstances, a tri-party agreement with PAS and the third- party
investment adviser, as described below under “Third-Party Investment Advisory Programs.”
Financial Planning and Consulting
Certain IARs are authorized by PAS to offer financial planning and consulting services. For these services, the
IAR may negotiate a fee based upon the overall experience of the IAR, a client’s financial needs and investment
objectives, the time necessary to develop a plan and the complexity of a plan. If you engage an IAR for financial
planning or consulting services, at the beginning of the relationship your IAR will provide you with a Financial
Planning or Consulting Agreement, which will detail all the important terms and conditions pertaining to the
financial plan or consultation, including the fee.
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Fee-based financial planning is a service that considers many different aspects of your financial circumstances,
typically by utilizing a financial planning software program to create an overall plan that is designed to meet your
goals and objectives.
Financial consulting is an open architecture process that requires your IAR to collect information from you and
develop customized recommendations that are delivered to you within the parameters of an agreed upon scope
of consulting services.
The financial planning and consulting services provide for ongoing consultation with your IAR, typically through a
series of personal meetings and telephone calls. The services provided may include follow-up meetings with you
and your other advisors (e.g., attorneys, accountants, etc.).
Depending on your needs and pursuant to the agreement with your IAR, your formal written financial plan or
consultation recommendations may cover:
General Financial Planning
Goal Planning (e.g., Education Planning)
Retirement Planning
Risk Management
Cash Flow Planning
Wealth Transfer Planning
Business Succession and Exit Planning
Investment Analysis
Your written financial plan or consultation will consist of observations, assumptions, strategies, and
recommendations. You will have the opportunity to renew the agreement and update your plan at least annually,
or as your circumstances change. You may choose to implement all or any part of the financial plan or
consultation recommendations through PAS, or through any other broker-dealer, investment adviser or service
provider of your choice. Please note if you choose to implement all or part of the financial plan through PAS,
your IAR will receive additional compensation for any product purchases or additional investment advisory
services.
Subscription Based Financial Planning
Certain IARs are authorized by PAS to offer on-going financial planning services via Subscription-Based
Financial Planning. The subscription arrangement will provide you with the ability to engage your IAR for financial
planning services by paying an annual fee on either a monthly or quarterly basis. Your agreement
will renew annually unless you choose to terminate the agreement. Your IAR will provide you with analysis,
recommendations, and ongoing monitoring based on your current financial situation and goals. On an annual
basis you will receive a written summary of the terms of the engagement which will include an outline of your
goals, both accomplished and future, a summary of the meetings with your IAR, your fee arrangement, and a
reminder of the termination option within the agreement.
Listed below is an overview of the services that may be provided through the Subscription-Based Financial
Planning Program. Included with the services is access to your IAR throughout the subscription period. A full
description of each service can be found within the Subscription-Based Planning Agreement.
Core Services:
Initial Consultation, including obtaining and organizing essential documents
Obtaining essential documents
Organizing documents
Cash Flow and Debt Planning Analysis
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Net Worth Statement
Investment Analysis
Risk Analysis
Access to your Advisor throughout the subscription period
Advanced Planning:
Charitable Planning
Wealth Transfer Planning
Goals-based Planning
Education Planning and Funding
Retirement Planning
Tax Planning Strategies
Life Events
Business Planning
It is important to note that if your IAR provides advice related to a separate brokerage account, advisory account,
or other investment as part of this engagement, the Subscription-Based Financial Planning fee will be in addition
to any fees or commissions associated with those accounts. However, the advice provided within the
Subscription-Based Financial Planning arrangement cannot solely be comprised of existing PAS accounts.
Additionally, if you choose to implement recommendations from your IAR as part of this engagement, the fees or
commissions associated with products purchased or sold will be in addition to your Subscription-Based Financial
Planning fee.
Fiscalyze
When providing financial consulting services to business clients, certain IARs may utilize the services of The
Advanced Practice Network LLC, doing business as Fiscalyze (“Fiscalyze”), a third-party vendor who provides
services to PAS IARs. Fiscalyze charges a fee for these services which is in addition to the fee that a client pays
for the financial consulting services provided by the PAS IAR.
The services that Fiscalyze provides are not investment advice and consist of the following, all of which are
offered through the PAS IAR when providing financial consulting services to a client:
Inventory and Organization of Documents
Annual Review of Objectives
Personal & Family Checklist
Enterprise Checklist
Capital & Cash Flow Priorities Worksheet
Personal & Family Concerns Assessment
Enterprise Concerns Assessment
Business Continuity Analysis to explore the most likely interruptions to the business.
Qualified Plan Insights
Executive Benefits and Carve-out Insights
Employee Benefits Insights
Professionally Adjusted Business Valuation (Enterprise Drivers) Reports.
Margin Analysis (Profit Drivers)
Cash Cycle Analysis (Cash Drivers)
Lender Analysis
Forecasting Analysis
Capital Analysis
Comprehensive Gap Analysis
Industry Benchmarking Analysis
An inventory of strategies which tracks progress over time.
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Fiscalyze is owned by Kelly Kidwell, Eric McDermott, and Matthew Shipman (the “General Agents”). The
General Agents also own Pacific Advisors, LLC (“Pacific Advisors”). Pacific Advisors is a general
agency of The Guardian Life Insurance Company of America (“GLIC”), and as such has entered into
contracts with GLIC and PAS, pursuant to which the General Agents supervise and may influence the
PAS IARs associated with Pacific Advisors. These contracts also provide for compensation, in the form
of a certain percentage of the financial consulting fee (an “override”) that is charged to clients on the
financial plans provided by PAS IARs who are associated with Pacific Advisors, to be paid to the General
Agents. In addition to that override compensation, as owners of Fiscalyze, the General Agents also
receive compensation directly from Fiscalyze when a PAS IAR uses the Fiscalyze tool to provide
financial consulting services to a client. Thus, in the event a PAS IAR who is associated with Pacific
Advisors uses Fiscalyze, these General Agents will receive two types of compensation, overrides based
on the financial consulting fee and a portion of the fee that is paid to Fiscalyze for its services.
Fiscalyze Subscription Based Business Financial Consulting
Certain IARs are authorized by PAS to offer on-going Subscription-Based business financial consulting services
utilizing Fiscalyze. The subscription arrangement will provide you with the ability to obtain ongoing financial
consulting services for your business by paying an annual fee on either a monthly or quarterly basis. Your
agreement will renew automatically on an annual basis unless you choose to terminate the agreement. Your IAR
will provide you with analysis, recommendations, and ongoing monitoring based on the current financial situation
and goals for you and your business. On an annual basis you will receive a written summary of the terms of the
engagement which will include an outline of your goals, both accomplished and future, a summary of the
meetings with your IAR, your fee arrangement, and a reminder of the termination option within the agreement.
Listed below is an overview of the services that may be provided through the Subscription Based Business
Financial Consulting Program. Included with the services is access to your IAR throughout the subscription
period. A full description of each service can be found within the Subscription Based Business Financial
Consulting Agreement.
Personal Services
Review of Personal Financial Objectives
Personal & Family Concerns Assessment
Capital & Cash Flow Priorities Assessment
Personal & Family Inventorying and Organization of Documents
Personal Balance Sheet and Cashflow Insights
Personal Protection Insights
Personal Investment Insights
Sufficiency Insights
Personal Insights Briefing, Debriefing, and Follow-Up Coordination
An inventory of personal financial strategies which tracks progress over time
Enterprise Services
Annual Review of Enterprise Financial Objectives
Enterprise Inventorying and Organization of Documents
Enterprise Concerns Assessment
Business Continuity Analysis
Enterprise Financial Performance Insights
Census-Driven Insights
Enterprise Insights Briefing, Debriefing, and Follow-Up Coordination
An inventory of enterprise financial strategies which tracks progress over time
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Fiscalyze Get Organized and Take Control Financial Consulting
Certain IARs are authorized by PAS to offer on-going consulting services to assist clients with organization and
taking control of their finances. Your IAR will assist you with identifying the services needed, sourcing personal
and business data to be analyzed and assist you with using the analysis to evaluate business risk and business
decisions. In providing the Get Organized and Take Control Financial Consulting services, your IAR will also
utilize the reports and services of The Advanced Practice Network LLC, doing business as Fiscalyze. Listed
below is an overview of the services that may be provided through the Get Organized and Take Control Financial
Consulting program. A full description of the services can be found in the Get Organized and Take Control
Financial Consulting Agreement.
Get Organized and Take Control Services:
Essential Services
Inventory & Organization of Documents
Annual Review of Objectives
Cash Flow Analysis
Personal Balance Sheet Population
Organizing Tax Forms (Single Household/Single Entity Filings (1-2 Tax Returns Per Year)
Organizing Estate Documents (Basic Wills and Living Trusts)
Organizing Business Owners (Lifestyle Business/One Entity no Enterprise Value)
Advanced Services (all of the above in addition to the following)
Organizing Tax Forms (Multiple Household/Entity filings (more than 1-2 Tax Returns across Household,
Business & Trusts)
Organizing Estate Documents (Multiple/Complex Trusts such as Irrevocable, Dynastic Trusts)
Organizing Business Owners (Enterprise Business or Multiple Entities)
Annual Personal Financial Sufficiency Report and Specialist Consult
You and your IAR will meet for an initial consultation at no cost. If, at the end of the initial consultation you wish
to retain the services of your IAR, you will execute an agreement. By signing the agreement, you agree to pay
the disclosed fee for the analysis and/or recommendations produced by your IAR. The fee is based on the
service you selected, essential or advanced which includes a one-time set up fee and an ongoing annual fee that
you may elect to pay monthly or quarterly. The fee range is between $250 to $25,000.
Corporate Financial Education Services
Certain PAS IARs can work with business clients to provide group financial education seminars for the
employees of such businesses.
Business Exit Consulting
Certain IARs will analyze the financial situation of your business for the purpose of establishing business exit
planning strategies and recommendations.
Your IAR will coordinate with your accounting and legal advisors as well as other professionals you deem
appropriate or that your IAR recommends. These professionals are selected, retained, and paid for by you. Any
advice provided by these outside professionals is separate and distinct from the advice provided by your IAR
and any fees paid to outside professionals are separate and distinct from the fee charged as part of the Business
Exit Consulting Agreement.
You may choose either a Comprehensive Exit Plan or a Focused Exit Plan. A Comprehensive Exit Plan is a
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written action plan for accomplishing your objectives with regards to the growth of your business, the preservation
and realization of maximum business value, and your ultimate departure from the business within established
timelines and terms.
In a Focused Exit Plan, you will select your objectives from the following list:
Business Valuation
Incentive Planning
Ownership Transfer Planning
Business Continuity Planning
Personal Wealth Management Planning
Wealth Transfer Planning
Once the objectives have been established, the IAR will collect the requisite information to create the focused plan.
Please note that a Focused Exit Plan cannot solely be made up of the Personal Wealth Management Planning
or Wealth Transfer Planning. All of these components are more fully described within the Business Exit Consulting
Client Agreement.
Retirement Plan Consulting Services (Investment Advisory)
PAS may enter into an agreement with an employer sponsored qualified retirement plan to provide investment
advisory services to the plan. PAS, through its authorized IARs, will assist the named plan fiduciary in
determining the investment lineup available to the plan's participants. Only appropriately credentialed IARs
specifically approved by PAS are authorized to provide these services to plan sponsors. A summary of the
services is provided below. Plan sponsors should refer to their written agreement with PAS for more details
regarding the specific services to be provided as well as the fees charged.
Investment Option Recommendations – The PAS IAR will analyze the list of available investment options for the
qualified plan and provide the plan sponsor with a recommended list of core asset classes that, when combined,
constitute an investment lineup for a qualified plan seeking a basic level of complexity. The IAR will also provide
definitions of additional asset classes/categories that, when combined with core asset classes, will constitute
investment lineups for those plan sponsors seeking more sophisticated levels of complexity. The IAR will identify
for the plan sponsor's consideration one or more investment options from each asset class/category that are
appropriate for long-term strategic asset allocations and will evaluate the investment options, including comparing
their performance to appropriate benchmarks and peer group(s). The IAR will provide the plan sponsor with a
"core list" of recommended investment options within each of the core asset class groups, as well as
supplemental asset classes/categories and provide some general guidelines as to how many and what
management type (active or passive) of investment options are appropriate to select with respect to each of the
asset class groups to assist the plan sponsor in making its final investment option selections.
Monitoring of Investment Options – The IAR reviews investment option performance on a quarterly basis or on
such other agreed-to basis. Each investment option will be reviewed, and investment options that do not meet
the identified criteria will be placed on a watch list. The placement of an investment option on the watch list does
not mean that it will be recommended to be removed from the plan’s investment options lineup, but rather triggers
further due diligence on the investment option. The purpose of the due diligence is to determine if the original
reasons for selecting the investment option are still valid. The IAR shall provide the plan sponsor with a report
summarizing its review. Once an investment option is on the watch list, it will
remain on there until further due diligence indicates that it should be removed from the watch list or it is or it is
recommended for removal as an investment option. To be removed from the watch list, certain qualitative and
quantitative measures must be met. If, after further due diligence, the IAR determines that the investment option
no longer meets the criteria for remaining on the core list, the IAR will, to the extent available on the platform,
identify one or more suitable replacements for the plan sponsor to select from.
Additional Provisions – PAS and its IAR will not exercise any discretion or authority regarding the plan sponsor's
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selection of the specific securities, mutual funds, institutional funds, or funds available through group annuity
contracts and mutual funds that may be eligible investment options under the qualified plan. Furthermore, neither
the IAR nor PAS will have any discretion over plan assets in any capacity.
It is the sole responsibility of the plan sponsor or named fiduciary to review, approve and implement the
recommendation of the IAR for the following items:
the investment policy statement for the qualified plan.
the selection and retention of service providers (e.g., (without limitation) investment provider(s),
investment managers and advisers, a plan record-keeper and a third-party administrator). It is also the
plan sponsor or named fiduciary’s sole responsibility to supervise the performance of such providers.
the determination of the appropriate mix and number of asset classes to be included in the investment
options available under the qualified plan.
to the selection of the specific mutual funds, institutional funds, or funds available through group annuity
contracts that will be investment options under the qualified plan.
If a qualified plan contains a company stock or self-directed brokerage investment option, the IAR shall not be
required to take such investment options into account with respect to its determinations or recommendations.
The plan sponsor shall retain sole fiduciary responsibility with respect to such company stock or self-directed
brokerage option. The plan sponsor will agree to review at least annually and to advise the IAR of any changes in
the investment options that may be available under the qualified plan or any changes to the demographic or
other information previously provided to the IAR regarding the qualified plan. In providing these services to plan
sponsors, PAS and its IARs must utilize the software and other tools provided by Envestnet Retirement Solutions,
LLC (“ERS”). PAS, its affiliates and IARs are not affiliated with or under common ownership, control, or operation
with ERS. PAS agreements with plan sponsors for plan investment advisory services do not include services
provided by other PAS IARs, who may work separately with plan participants in their individual capacity, including
the provision of advice regarding rollovers.
This Brochure also constitutes the disclosure required to be provided to plan sponsors under the regulations
promulgated by the United States Department of Labor pursuant to Section 408(b)(2) of the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). The fee charged for these services and other
important information relating to the fees for the investment advisory services shall be contained within the Plan
Services Agreement for Investment Advisory Services under Section 3(21) of ERISA (“Plan Services
Agreement”). Please see the section entitled “ERISA Section 408(b)(2) Disclosure to Responsible Plan
Fiduciaries of ERISA-Covered Qualified Retirement Plans” later in this Brochure for further information. In addition
to the program described above, in limited circumstances, certain PAS IARs may enter into joint work
arrangements whereby such professionals refer plans to other PAS IARs who are credentialed to provide such
plan investment advisory services. In such instances, the credentialed IAR will serve as the primary client
contact. The referring IAR may receive initial and ongoing compensation for the referral. Please contact your IAR
for more details.
Investment Advice to Retirement Plan Participants
Certain IARs are authorized by PAS to offer investment advice to participants of ERISA retirement plans. These
services will consider aspects of your financial circumstances and the investment options allowed and selected
by the retirement plan fiduciary for use by its participants.
At the beginning of the relationship your IAR will provide you with the Retirement Plan Participant Investment
Advice Client Agreement, which will detail the terms and conditions pertaining to the services, including the fee.
In addition, you will be required to complete a risk tolerance questionnaire. Upon completion and review of a risk
tolerance questionnaire, your IAR will provide you with a recommendation regarding the selection of your
investment options and allocation of your plan assets best suited to your goals and risk tolerance. On at least a
semi-annual basis, your IAR will develop and provide you with a report, detailing investment recommendations
which shall be limited to the investments available within your retirement plan investment line up selected by the
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retirement plan fiduciary.
Retirement Plan Services (Non-Investment Advisory)
PAS may enter into an agreement with an employer sponsored qualified retirement plan to provide certain non-
investment advisory services to the plan. The PAS IAR will assist in assessing, analyzing, and addressing the
needs of the plan. Below are the services made available to the plan sponsor and/or the plan participants.
Plan Governance and Committee Education
Reviewing retirement plan committee structure and requirements
Assisting plan sponsor to determine plan objectives
Reviewing participant education and communication strategy
Assisting with responding to participant requests for additional information. Assisting the plan sponsor to
develop and maintain a fiduciary audit file
Coordination of data and plan design with the designated third-party administrator
Plan Service Provider Selection/Review and Vendor Management
Assisting plan sponsor with his/her determination of the appropriate funding vehicle for the Plan
Providing periodic benchmarking of fees and services to assist review for reasonableness
Assisting the plan sponsor to generate and evaluate service provider requests for proposals (RFPs) and/or
requests for information (RFIs)
Assistance with service provider transition and/or plan conversion
Services to be provided to the Plan Participants: Employee Investment Education and Communication
Providing group enrollment and investment education meetings for employees
Providing periodic updates, upon request or via newsletter
Assisting participants with retirement readiness
PAS Proprietary Investment Advisory Programs
PAS is the sponsor of the PAS Proprietary Programs. PAS Proprietary Programs offer a range of investment
strategies, from conservative to ultra-aggressive growth.
The following description applies to all PAS Proprietary Programs other than VestWiseTM, the digital advisory
program offered by PAS. An IAR will analyze your individual financial situation and make recommendations as to
an appropriate program based on your individual needs and investment objectives. Prior to funding a PAS
Proprietary Program account, your PAS IAR will help you complete an account application, a client questionnaire
and/or other forms in order to determine your investment objectives and risk tolerance, also known as the
Investor Risk Rating. The Investor Risk Rating is the level of risk a client is willing to take with their investments
based upon questions asked within the client questionnaire. Your IAR will provide you with recommendations in
the form of a proposal (“Proposal”) based on the information you provide. Your Proposal includes your
recommended PAS Proprietary Program, which may include load-waived and no-load mutual funds, exchange-
traded funds (“ETFs”), closed-end funds, stocks, and bonds as well as separately managed accounts.
PAS Proprietary Programs include both discretionary and non-discretionary programs. In a discretionary
program, PAS (for VestWiseTM), your IAR (for Park Avenue Signature PortfolioSM) or the applicable third- party
strategist, investment manager, or overlay manager (in all other discretionary Proprietary Programs), manages
your assets within the parameters of the program and model portfolio you select. Each discretionary Proprietary
Program also allows PAS, the applicable IAR, strategist, investment or overlay manager to place trades for your
account at its discretion without requiring your prior approval. This gives PAS, the applicable IAR, strategist,
investment or overlay manager the authority to determine, without obtaining your specific consent, the securities
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to be bought or sold, and the amount of the securities to be bought or sold for your account. In a discretionary
program, you have the ability to impose any reasonable restrictions or modify any existing restrictions on the
management of your account.
The non-discretionary Proprietary Program Park Avenue Portfolio SelectSM has been designed to give you, the client,
flexibility to use your account as you deem appropriate within certain prescribed limits. Your IAR shall make
recommendations for portfolio transactions within the parameters of your strategy and within but not exceeding,
your Investor Risk Rating, and must obtain your permission prior to effecting any transactions in your account.
For all PAS Proprietary Programs, either PAS or your IAR is available on an ongoing basis to assist you in
evaluating your portfolio strategy and asset allocation. Your IAR will provide you with advice and guidance that is
based on the information you provide at the time you open your PAS Proprietary Program account and as you
update or amend it from time to time. To assist you in managing your account assets, PAS will provide you with:
Periodic performance reports showing the performance of your PAS Proprietary Program account assets;
and
Opportunities for you to engage in periodic account reviews with your IAR to address progress toward
asset allocation and your investment objectives.
You may transfer securities from outside accounts into your PAS Proprietary Program account; however, your
IAR may recommend that you sell some or all of the securities if he or she believes that holding such securities
is not appropriate for the current recommended investment strategy. Any securities held in your account that are
classified as Unsupervised Assets are not managed by PAS or your IAR. These may include securities transferred
into your PAS Proprietary Program account from outside accounts that your IAR has identified to you as not
appropriate for your current investment strategy for the particular account. These assets may remain in the
account at your discretion but shall be classified as Unsupervised.
Unsupervised Assets are not included in the periodic performance reports for your PAS Proprietary Program
account. PAS and your IAR do not provide investment advisory services of any kind with regard to Unsupervised
Assets, do not charge an advisory fee on such assets and do not have any responsibility with respect to the
management of any holdings classified as Unsupervised Assets. PAS, your IAR, Strategist or Investment
Manager do not consider Unsupervised Assets when providing investment advice for your PAS Proprietary
Program account.
Your account can be managed in a tax-sensitive manner; however, neither PAS nor your IAR may provide tax
advice or tax management services. You are responsible for any taxable events in all instances. You should
always consult with your tax advisor for specific tax advice.
Envestnet Asset Management, Inc.
PAS has contracted with Envestnet Asset Management, Inc. (“Envestnet”), an SEC registered investment
adviser, to provide a technology structure for PAS and its clients through Proprietary Programs other than
VestWiseTM
to efficiently connect with third-party asset managers referred to as Investment Managers or
Strategists and to act in some Programs as co-adviser to clients. Envestnet provides overlay management
services on a discretionary basis administering model portfolios developed by the Investment Manager or
Strategist and taking directions from the Investment Manager or Strategist to adjust asset allocations, add,
remove, or replace securities in the account, and rebalance the account as it deems necessary. Envestnet also
provides advice related to program design and support, including the structure and design of asset allocation
portfolios and underlying investment research on Separately Managed Accounts (“SMAs,” which are portfolios of
individually owned securities managed by an asset manager), mutual funds, and Exchange- Traded Funds
(“ETFs”) that may be available within certain of the PAS Proprietary Programs. However, Envestnet is not
responsible for the specific investment choices made with respect to the portfolios developed and maintained by
the Strategist or Investment Manager. The IAR in consultation with their client is required to fill out a client
questionnaire. Once the client questionnaire is completed, Envestnet will be responsible for determining the
suggested target asset mix.
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For all PAS Proprietary Programs, you have the ability to impose any reasonable restrictions or modify any
existing restrictions on the management of your account. Clients may impose new, or change any existing,
investment restrictions at any time by contacting their IAR.
The following is a description of each of the PAS Proprietary Programs:
Park Avenue Portfolio SelectSM Program
The Park Avenue Portfolio SelectSM program is a non-discretionary program where your selected IAR advises
and may recommend to you various investment vehicles, such as mutual funds, ETFs, stocks, and bonds, in
accordance with your investment objectives and Investor Risk Rating, utilizing model portfolios for a range of
investment objectives. Although your IAR will furnish you with advice and guidance, all transactions in your
Park Avenue Portfolio SelectSM
account will take place only upon your specific approval. You assume full
responsibility for all trading decisions.
Based upon your investment objectives, your IAR will recommend a model portfolio that is constructed with a
variety of investments to fulfill your recommended strategic risk/return strategy. When building your portfolio,
your IAR may recommend investments from a wide array of investment options, including mutual funds, ETFs,
equity securities, exchange-listed securities, over-the-counter securities, securities of foreign issuers (including
American Depository Receipts (“ADRs”), European Depository Receipts (“EDRs”), and Global Depository
Receipts (“GDRs”), corporate debt, commercial paper, certificates of deposit, United States government
securities, and municipal securities. You are under no obligation to accept such recommendations or to
authorize transactions through PAS or the IAR. A mutual fund-only option is also available under the program.
Any purchase or sale of securities in your account may cause the account to vary from your initial asset
allocation and investment objectives.
Client-Initiated Transactions – You may request your IAR to execute transactions that are initiated solely by you
without a recommendation from your IAR (client-initiated transactions). These client-initiated transactions are
solely your responsibility. PAS will not be responsible for the performance of these client-initiated transactions;
however, PAS will include such assets in the Total Client Fee calculation. The advice of your IAR is a key service
of the Park Avenue Portfolio SelectSM
program. A pattern of client-initiated transactions may indicate that this
program is no longer appropriate for you as you would not be utilizing the advice of your IAR.
If you have completed a client-initiated transaction and have acquired a security without the advice of your IAR,
so long as you hold the position in your Park Avenue Portfolio SelectSM
account, PAS will take that asset into
consideration:
- as part of the overall account assets;
- when PAS gives you periodic asset allocation advice;
- when PAS values your account holdings; and
- when PAS provides analyses and reports on the account’s performance.
PAS may also recommend that you consider selling the asset if, and when PAS deems it appropriate.
Park Avenue Portfolio Select typically assesses ticket charges to clients for the purchase and sale of certain
securities in a client’s account. The ticket charges are retained by PAS and are not shared with your IAR. IARs may
elect to pay the ticket charges on a client’s behalf. Park Avenue Portfolio Select clients should understand that their
IAR may elect to pay ticket charges for the accounts of some but not all of their clients. If your IAR elects to pay your
ticket charges, you should understand that the annual fee you pay may be higher than what you would otherwise
pay if your IAR did not elect to pay ticket charges for your account, and your IAR may have a financial incentive to
trade less for your account. Clients who choose to open a Park Avenue Portfolio Select account should carefully
consider these factors and discuss the costs and benefits of whether they or their advisor should pay ticket charges.
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PAS Wrap Fee Programs
FoundationsSM, Quantitative InnovationsSM, Park Avenue Strategist SelectSM, Park Avenue Strategist Select
PlusSM, Park Avenue Separately Managed Account SelectSM, Park Avenue Unified Managed Account Select℠,
Park Avenue Signature PortfolioSM and VestWiseTM
are PAS wrap fee programs. Under a wrap fee program, you
pay a single asset-based fee for investment advisory services and execution of your transactions. Unless
otherwise noted, administrative and investment advisory fees, along with transaction fees, are “wrapped” into
one comprehensive fee, which is paid quarterly. A portion of the wrap fee is used to pay PAS and your IAR for
investment advisory services.
Wrap fee program portfolio managers may employ “trading away” practices, in which they use a broker other
than PAS to execute trades for which a commission or other transaction-based fee is charged, in addition to the
wrap fee. Although transaction fees are usually included in the wrap program fee, sometimes you will pay an
additional transaction fee for investments bought and sold outside the wrap fee program. For more information
regarding trade away practices, please go to www.parkavenuesecurities.com.
Each PAS wrap fee program has its own Wrap Fee Brochure which describes in detail the investment options and
services for each program. To obtain a Wrap Fee Brochure for one of the programs listed, please request the
brochure from your IAR or call PAS at (800) 600-4667. Below is a brief description of each PAS wrap fee program.
FoundationsSM and Quantitative InnovationsSM Programs
The Foundations and Quantitative Innovations programs are discretionary investment advisory programs
sponsored by PAS that provide clients with access to model portfolios managed by Integrated Capital
Management, Inc. (“iCM”), a third-party investment manager that has been retained by Envestnet Asset
Management, Inc. (“Envestnet”). Envestnet provides overlay management of the iCM investment models by
performing administrative and trading services, such as directing the rebalancing of the portfolios invested in the
models. By executing the Client Agreement (which includes the Statement of Investment Selection), you grant
Envestnet the discretionary authority to invest, reinvest, and otherwise rebalance your account assets at
Envestnet’s discretion. Model portfolios are created and managed by iCM, which allocates the portfolios across
investment asset classes to create a blend that fits your investment objectives and Investor Risk Rating.
Envestnet performs administrative and/or trading duties at the direction of iCM via a licensing agreement
between Envestnet and iCM. The portfolios are managed pursuant to one of the model portfolios created and
maintained by iCM in a single account allocated among different mutual funds and/or ETFs. iCM provides
ongoing management that includes the ability to adjust asset allocations, add, remove, or replace securities in
the account, and rebalance the account as it deems necessary. The Foundations program consists of mutual
fund only portfolios (both standard and tax-sensitive), representing various investment
styles and asset classes. The Quantitative Innovations program utilizes diversified model portfolios (both
standard and tax-sensitive), composed of selected mutual funds and ETFs representing various investment
styles and asset classes. iCM will continually monitor the portfolios, and at times make adjustments to the asset
class percentages of the models as well as to the mutual fund and ETF allocations within each asset class in
each model portfolio. The programs employ multiple model portfolios which are designed to reflect risk and
volatility levels that range from conservative to ultra-aggressive.
Park Avenue Strategist SelectSM and Park Avenue Strategist Select PlusSM Programs
The Park Avenue Strategist Select and Strategist Select Plus programs are discretionary investment advisory
programs sponsored by PAS that provide clients with access to third-party investment advisory firms, referred to
as Strategists, that have been retained by Envestnet. These programs offer single asset allocation portfolios
created and managed by the Strategist using mutual funds and ETFs. Envestnet provides overlay management
of the investment models developed and maintained by the Strategist by performing administrative and trading
services, such as directing the rebalance of the portfolios invested in the models. The Park Avenue Strategist
Select Plus program offers additional Strategists that use individual securities in separately managed accounts
as well as mutual funds and ETFs to create portfolios.
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Park Avenue Separately Managed Account SelectSM Program (SMA Select)
The SMA Select Program is a discretionary investment advisory program sponsored by PAS that provides clients
with access to the investment strategies of third-party investment managers and advisory firms referred to as
Investment Managers that have been retained by Envestnet. Envestnet provides SMA Select Program clients
with the ability to access one or more Investment Managers, either directly using a separately managed account
for each Investment Manager where the Investment Manager trades directly for the account or indirectly through
the use of an investment strategy model created and maintained by the selected Investment Manager but
administered by Envestnet by providing overlay management of the investment models through the performance
of administrative and trading services. An SMA Select Program account will contain one Investment Managers’
held in a separate custodial account.
Park Avenue Unified Managed Account SelectSM Program (UMA Select)
The UMA Select Program is a discretionary investment advisory program sponsored by PAS that provides clients
with access to the investment strategies of third-party investment managers and advisory firms, referred to as
Investment Managers, that have been retained by Envestnet. The UMA Select Program provides recommended
asset allocation models which consist of asset allocation targets or sleeves across various asset classes and
investment strategies. Based upon your investment objectives and Investor Risk Rating, your IAR will
recommend Investment Manager(s) who may invest in mutual funds, ETFs, as well as individual stocks and
bonds to fulfill your asset allocation targets based on the risk/return strategy. Your IAR may also recommend a
Strategist portfolio from the Strategist Select/Strategist Select Plus program to populate an asset allocation
sleeve. You will complete the UMA Select Program account by selecting which Investment Manager strategies to
populate within each asset allocation sleeve.
Envestnet acts as the overlay manager and administers the UMA Select Program by implementing the model
portfolios provided and maintained by the individual Investment Manager(s) selected (an “Investment Model”) by
you. An UMA Select Program account may contain one or multiple Investment Models investing in different asset
classes according to the selected portfolio allocation strategy. The UMA Select Program account may also
contain mutual funds, ETFs, individual stocks, bonds, or strategist model portfolios to complete the strategy. The
securities within the selected Investment Models, as well as any mutual funds, ETFs, or individual stocks and
bonds outside of the Investment Models, will be held in a single custodial account. Your IAR has the ability to
make
changes to the Program Account within your Investor Risk Rating and upon your approval by removing or
replacing one Investment Manager with another. By executing the Client Agreement, you grant Envestnet the
authority to buy and sell securities and investments for the account pursuant to the direction of the Investment
Manager and perform rebalancing or other such discretionary authorities you agree upon. In certain cases, the
Investment Manager may directly trade client assets within the UMA Select Program instead of providing an
Investment Model to Envestnet. In those instances, Envestnet shall be authorized to delegate the investment
discretion described above to the Investment Manager.
Park Avenue Signature PortfolioSM Program
The Signature Portfolio Program is a discretionary investment advisory program whereby investment
management services and advice are offered on a fully discretionary basis through the PAS IAR you select. You
authorize PAS through your IAR to purchase and sell securities according to your investment objectives on a
discretionary basis. Based upon your investment objectives and Investor Risk Rating, your IAR will build a model
portfolio that is constructed with a variety of investments to fulfill your risk/return strategy. When building your
portfolio, your IAR may select investments from a wide array of investment options, including mutual funds,
ETFs, equity securities, exchange-listed securities, over-the-counter securities, securities of foreign issuers
(including American Depository Receipts (“ADRs”), European Depository Receipts (“EDRs”), and Global
Depository Receipts (“GDRs”), corporate debt, commercial paper, certificates of deposit, United States
government securities, and municipal securities. Your IAR will have your permission to buy or sell securities, in
quantity, price and at the time that your IAR sees fit without your prior consent in accordance with the investment
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objectives selected by you. Any purchase or sale of securities in your account may cause the account to vary
from your initial asset allocation and investment objectives. Envestnet performs administrative and/or trading
duties at the direction of your PAS IAR via a licensing agreement between PAS and Envestnet.
VestWiseTM
VestWise™ is the branded name for the PAS automated or digital (i.e., internet/web-based) investment advisory
solution. The VestWise program consists of Model Portfolios whose underlying holdings consist of a series of
individual Exchange Traded Funds, (“ETFs”). Franklin Advisers, Inc. (“Franklin Advisers”), an investment adviser
registered with the SEC, provides PAS with the Model Portfolios for the VestWise program, which are periodically
updated by Franklin Advisers acting in the role of a “Model Provider.” PAS acts as the sponsor and the
discretionary investment manager for this program, which means PAS is provided the authority to manage the
securities held in your VestWise account without seeking prior trading approval from you. If you elect the
recommended VestWise strategy (“Model Portfolio”) and open an account, PAS uses this discretion to make
changes to the holdings within the account over time consistent with the selected Model Portfolio.
The technology platform being utilized by PAS to provide the VestWise program is offered by AdvisorEngine, an
affiliate of Franklin Advisors. PAS pays AdvisorEngine an annual technology fee that is calculated based on the
assets under management on the platform.
The VestWise program is intended to be a hybrid of a digital adviser (i.e., internet/web-based adviser) and a
traditional human adviser. Your IAR will be available to assist you with the following:
Reviewing the Model Portfolio VestWise has recommended for you; and
Providing you with advice and guidance, upon your request, based on the information provided at the time
you opened your VestWise account and as you update or amend it from time to time.
PAS will provide you with:
Discretionary investment management of your VestWise account;
Periodic performance reports showing the performance of VestWise account assets;
Opportunities for you to engage in periodic account reviews to address progress toward your investment objectives
and goals for the account; and
Automated quarterly rebalancing at the end of each calendar quarter using rebalancing rules established by
PAS.
Lending Services
Non-Purpose Loan Program
You may apply for a non-purpose loan from Pershing LLC through the PAS Non-Purpose Loan Program using an
eligible securities account as collateral. These eligible securities accounts may include one or more of your PAS
Proprietary Program accounts. In order for PAS Proprietary Program accounts to be eligible to serve as collateral
for a non-purpose loan, the account may not serve as collateral for any margin lending or reinvestment into any
securities or insurance products. You will be required to open a brokerage account to support the loan and will
receive a separate statement for this account.
If you participate in the Non-Purpose Loan Program, you will pay interest to Pershing LLC and PAS on the loan
value in addition to any Program advisory fees charged in the PAS Proprietary Program account being used as
collateral. PAS IARs do not receive any portion of the interest paid by clients for non-purpose loans.
Securities Based Line of Credit (“SBLOC”) through Tri-State Capital Bank (“Tri-State”)
You may apply for a Securities Based Line of Credit (“SBLOC”) from Tri-State using an eligible securities
account as collateral. These eligible securities accounts may include one or more of your PAS Proprietary
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Program accounts. In order for PAS Proprietary Program accounts to be eligible to serve as collateral for a non-
purpose loan, the account may not serve as collateral for any margin lending or reinvestment into any securities
or insurance products.
If you participate in SBLOC, you will pay interest to Tri-State and PAS on the loan value in addition to any
Program advisory fees charged in the PAS Proprietary Program account being used as collateral. PAS IARs do
not receive any portion of the interest paid by clients for non-purpose loans.
Investment Credit Line
High net worth investors may apply for the BNY Mellon, N.A. Investment Credit Line program (ICL), a flexible line
of credit that provides liquidity for personal or business needs. The ICL is secured by qualifying liquid assets held
in your investment account(s) custodied at Pershing, LLC. Many forms of collateral are accepted, such as bonds,
domestic equities, mutual funds, and government securities. The minimum credit line size is
$1,000,000 requiring assets valued at least $1,500,000 in Pershing accounts. Interest is paid only on the funds
borrowed. For additional information about this program speak with your IAR.
Mortgage Program
High net worth clients may apply for mortgage programs provided by BNY Mellon, N.A. The minimum loan
amount is $500,000. Qualified borrowers may borrow up to 100% of the home’s value by pledging qualifying
assets held in accounts at Pershing, LLC in lieu of a cash down payment. Financing may be used for the
purchase of single-family, primary and vacation homes, condos, and co-ops but not investment properties. For
additional information about this program speak with your IAR.
Important Considerations relating to Lending Services
In certain circumstances, your IAR may recommend, and PAS may approve Lending Services in your
advisory account. Your IAR will benefit from recommending Lending Services because you do not have
to liquidate assets in your account to pay for items with cash, which would diminish the assets held in
the account and the potential fees and commissions that could be earned by your IAR from holding or
engaging in future transactions with those assets. For example, with a fee-based account, by
recommending a Non-Purpose loan to fund some purchase or financial need rather than liquidate
securities, PAS and your IAR continue to earn fees on the full account value. PAS will also receive a
portion of the loan interest when you participate in the Pershing Non-Purpose Loan and / or the Tri-State
SBLOC Programs. Furthermore, there are conflicts of interest associated with the various lending
programs as PAS does not earn interest on the Investment Credit Line, therefore creating an incentive to
recommend the Pershing and/or Tri-State lending programs in which PAS does share in the interest
payments with the lender but which may have higher interest rates than the Investment Credit Line
program. You may also seek lending services using your advisory account as collateral through third-
party banks which do not have a relationship with PAS and which may offer more competitive interest
rates.
You must meet certain eligibility requirements and complete loan documentation prior to applying for Lending
Services. Specifically, you will be required to execute loan documents with Pershing and/or BNY Mellon
depending on the Lending Services being sought.
Funds borrowed and proceeds from any recommended Lending Service may not be used to purchase securities
or fund brokerage accounts.
The decision to use PAS Proprietary Program account assets as collateral rests with you and should only be
made if you understand:
the risks of borrowing and the impact of the use of borrowed funds on advisory accounts;
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how the use of loans may affect your ability to achieve investment objectives;
the risk that you may lose more than your original investment; and
the possibility you may not benefit from collateralizing your account for a loan in a Program account if the
performance of your account does not exceed the interest expense being charged on the loan plus the
additional advisory fees incurred by your account as a result of the deposit of the loan proceeds.
Due to the fact your PAS Proprietary Program account will be pledged to support any loans extended under the
lending services program; you will not be permitted to withdraw any of the assets from the account unless there
is a sufficient amount of collateral otherwise supporting the loan (as determined by PAS, Tri-State, or Pershing in
their sole discretion).
If the market value of the collateralized account depreciates, you may be required to deposit additional funds.
Failure to promptly meet a request for additional collateral or repayment or other circumstances (e.g., a rapidly
declining market) could cause PAS, in our discretion, to liquidate some or all of the collateral account(s) to meet
the loan requirements. Depending on market circumstances, the prices obtained for the securities may be less
than favorable. Any required liquidations may disrupt your long-term investment strategies and may result in
adverse tax consequences. PAS does not provide legal or tax advice; you should consult your legal and tax
advisors regarding the legal and tax implications of borrowing and using securities as collateral for a loan. You
are personally responsible for repaying the loan in full, even if the value of the collateral is insufficient.
Neither PAS nor its IARs will act as investment adviser to you with respect to the liquidation of securities held in a
PAS Proprietary Program account to meet a loan demand. Those liquidations will be executed in PAS’ capacity as
broker- dealer and creditor and may, as permitted by law, result in executions on a principal basis
in your account. In addition, as creditors, PAS may have interests that are adverse to your interests. Additional
limitations and availability may vary by state.
Defaults – Non-purpose loans, SBLOC, investment credit lines and the 100% financing mortgage option are full
recourse, demand loans and clients with collateralized loan accounts may need to deposit additional cash or
collateral or repay part or all of the loan if the value of the portfolio declines below the required loan-to-value
ratio. Repayment may be demanded at any time.
There are substantial risks associated with the use of securities as collateral for a loan. For further information,
clients should carefully read the application and disclosure information provided for the program selected.
Margin Loans
A margin loan is created when you borrow funds from your account using your security investments as collateral
to purchase additional securities or withdraw funds.
Not all securities are eligible to be used for collateral (considered “marginable”) and not all customers are eligible
for a margin loan.
When a margin loan is created, accounts are charged interest on the loan amount in addition to other fees in
your account. The interest is charged by PAS’ clearing firm Pershing LLC with rates based upon the Federal
Funds Target Rate, plus an additional percentage charge depending on the size of the loan. The additional
percentage charge above the Federal Funds Target Rate may be as high as 8%. PAS will retain a portion of the
additional percentage rate charged above the Federal Funds Target Rate.
Margin loans can increase potential losses. As previously stated, marginable investments in a portfolio provide
the collateral for a margin loan. While the value of that collateral fluctuates according to the market, the amount
borrowed stays the same or will increase due to interest charged. If the value of the margined securities decline
to the point where they no longer meet the minimum equity requirements for the margin loan, there will be a
margin call. When this happens, PAS or Pershing LLC will request that more cash or marginable securities be
deposited into the account to meet the minimum equity requirement and satisfy the margin call. Failure to meet a
request for additional cash or securities deposit could cause PAS or Pershing, at their discretion, to liquidate
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some or all of the securities in your account to satisfy the margin call.
Various risks are associated with margin loans. Clients should carefully review disclosures regarding risks, fees,
and other considerations appearing in margin account agreements prior to establishing a margin loan.
Important Considerations Relating to Margin Loans
PAS will earn revenue on margin loan interest. This revenue, which increases based on the amount of
the margin loan held in your account, represents a conflict of interest as PAS has a financial incentive to
recommend or maintain a margin loan. This compensation is retained by PAS and is not shared with
your IAR however, your IAR has a conflict when recommending a margin loan as it will maintain or
increase the assets under management within the account which is the basis of the overall advisory fee
paid to your advisor. This conflict occurs because your advisory fee is based on the total market value
of the securities and cash balances in your account. When initially creating a margin loan, the total
market value of your account will either increase if additional securities are purchased to create the loan
or, be retained if a withdrawal is taken to create the loan.
Alternative Investments and Institutional Capital Network, Inc.
PAS has contracted with Institutional Capital Network, Inc. (“iCapital”) to utilize iCapital’s alternative investment
technology platform.
iCapital and its affiliates receive asset based and other fees for providing advisory and other services to the
alternative investments that they issue and/or manage, including alternative investments made available through
its platform. iCapital therefore, will have an incentive to include one or more affiliated alternative investments
through the platform.
The alternative investments offered by PAS issue multiple share classes to investors. The share classes offered
in PAS advisory programs will contain no up-front sales charges or ongoing distribution and/or servicing fees
payable to PAS.
Customers that agree to invest in an alternative investment will be subject to the eligibility requirements of the
issuer; details of such eligibility requirements may be found in the product prospectus or offering documents. The
Alternative investments offered in PAS advisory programs require investors to qualify as a Qualified Purchaser
or an Accredited Investor. Your IAR will review and verify your qualification status prior to any purchase of an
alternative investment in your account.
Certain PAS IARs are granted access to the iCapital platform whose alternative investments may be purchased
in the PAS Signature Portfolio and Portfolio Select programs. Only PAS approved alternative investments may
be purchased in the program which include Private Equity, Private Credit, Real Estate, and Hedge funds.
PAS makes available alternative investment funds issued by HPS Investment Partners, LLC (“HPS”).
PAS’ parent company, The Guardian Life Insurance Company of America (“GLIC”), owns a minority
stake in HPS. This minority ownership creates a conflict as customer investments into HPS funds
positively impacts GLIC’s investment in HPS. Neither PAS nor GLIC will share profits from GLIC’s HPS
investment with your IAR therefore, your IAR does not have a financial incentive to recommend an HPS
product.
Common Risks Associated with Alternative Investments
Alternative investments, which are generally defined as anything other than traditional stock or bonds and not
traded on an exchange or a public market, often referred to as private markets, involve a higher degree of risk
and complexity than traditional investments. As such, alternative investments are not suitable for all investors. A
prospectus or offering document that discloses all risks, fees and expenses, and risk factors associated with a
particular alternative investment may be obtained from your IAR and must be read carefully before investing.
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Investments in alternatives investment strategies can expose you to certain specific risks. The following is a non-
exhaustive list of the risks and considerations associated with alternative investments:
Transparency: Alternative investments may not offer the same level of transparency as traditional
investments which are required to provide frequent and full disclosure;
Liquidity: Alternative Investment are highly illiquid and are difficult to sell or be transferred. You may not be
able to redeem your investment for an extended period;
Fees: Alternative investment fees are generally higher than those associated with traditional investments;
Valuation: Alternative Investment are highly illiquid and are difficult to sell or be transferred. If your IAR
purchases an Alternative Investment for your account, it will be included for purposes of calculating PAS’
advisory fee. PAS relies on the issuer and Pershing to provide a good faith, fair market value. The timing and
process for fair market valuation of Alternative Investments is not as reliable as valuations of publicly traded
securities. Depending on the size of the fee and the market value of the Alternative Investment over the life
of the investment, PAS and your IAR could earn more revenue than if the same investment was held in a
brokerage account or directly with the issuer. Therefore, to earn these ongoing advisory fees, PAS and your
IAR have an incentive to recommend that you purchase interests through your advisory account instead of in
a brokerage account.
Investment strategies which may be employed by Alternative Investments:
o Concentration: Alternative investment strategies may be highly concentrated in a few funds or holdings.
o Leverage: The use of borrowing (leverage) exposes an investor to additional levels of risk including
greater losses from investments than would otherwise have been the case without borrowing; margin
calls or changes in margin requirements may force premature liquidations of investments; and losses on
investments where the investment fails to earn a return that equals or exceeds the cost of the leverage.
o Lack of diversification: The portfolio may not generally be as diversified as other investment vehicles.
Accordingly, investments may be subject to more rapid change in value than would be the case if the
portfolio were required to maintain a wide diversification among types of securities, geographical areas,
issuers and industries. Accordingly, a loss in a single position could have a materially adverse impact on
a portfolio.
o Event-driven trading: Event-driven trading involves the risk that the event identified may not occur as
anticipated or may not have the anticipated effect, which may result in a negative impact upon the market
price of securities held in the portfolio.
Donor-Advised Funds
A donor-advised fund (DAF) works like a charitable investment account, for the sole purpose of supporting
charitable organizations you care about. The DAF is a separately identified account that is maintained and
operated by a sponsoring 501(c)(3) charitable organization. When you contribute cash, securities, or other assets
to a DAF you are generally eligible to take an immediate tax deduction. Then those funds can be invested for
tax-free growth and you can recommend grants to virtually any IRS-qualified public charity. Once the donor
makes the contribution, the sponsoring organization has legal control over it. However, the donor retains
privileges with respect to the distribution of funds and the investment of assets in the account.
Through Pershing, PAS makes available three DAF options. American Endowment Foundation and Renaissance
Charitable Foundation both allow clients to select their IARs to manage their charitable assets in accounts
custodied at Pershing. The BNY Mellon Charitable Gift Fund offers various investment strategies through the
fund’s investment manager, BNY Mellon, N.A. Each DAF sponsor provides donor support services and a portal
that enables clients to recommend grants and view fund activity history.
The American Endowment Foundation and Renaissance Charitable Foundation Funds are for clients who wish
to make a charitable contribution but continue working with their PAS IAR to manage contributed assets in
accounts held at Pershing. These accounts will be invested in either the Park Avenue Strategist Select Program
or the Strategist Select Plus Program. PAS and the IAR will receive advisory fees from accounts invested in
these Programs as described within the Statement of Investment Selection.
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If the donor selects the BNY Mellon Charitable Gift Fund, the donor can choose from several investment options
using BNY Mellon N.A. as investment manager and the assets are custodied away from Pershing.
The Gift Fund offers five diversified investment strategies and a cash reserve option. The PAS IAR will not act in
the capacity of Authorized Representative on the account and neither PAS nor the IAR will receive any
compensation from this arrangement.
The donor advised fund options pose a conflict of interest in that IARs have an incentive to recommend
the DAF which pays advisory fees to the IAR over the option with no compensation.
Third-Party Investment Advisory Programs
PAS offers various Third-Party Investment Advisory Programs in which PAS, unless otherwise noted, acts as a
solicitor for an unaffiliated Third-Party Investment Adviser (each, a “Third-Party Investment Adviser”) and
receives a fee. In these programs, you will sign an investment advisory agreement directly with the Third- Party
Investment Adviser or a tri-party agreement which shall include both PAS and the Third-Party Investment
Adviser. Your IAR will provide you with the Third-Party Investment Adviser’s Form ADV Part 2, which you are
encouraged to review as it contains important information such as the program fees and expenses and any
conflicts of interest of the Third-Party Investment Adviser which may exist. Following the approval of your
application, the Third-Party Investment Adviser shall allocate your funds in accordance with the model portfolio
you select. Depending upon the program, the Third-Party Investment Adviser shall provide one or more of the
following: (i) construct model portfolios with various investment objectives; (ii) select and monitor mutual funds,
ETFs, money managers and/or other securities as permitted, for inclusion in the program; and (iii) allocate,
manage and, in some programs, rebalance assets in accordance with the model portfolio selected. Please be
aware that similar to any type of securities investing, when investing in a model portfolio developed by a Third-
Party Investment Adviser, there is no assurance that your investment objectives will be achieved.
In its role as a solicitor, your IAR will work with you to select an appropriate Third-Party Investment Advisory
Program based on a number of factors, including but not limited to your financial needs, preferences, and cost.
Once you have selected a Third-Party Investment Advisory Program, your IAR will gather information about your
investment objectives, risk tolerance and other pertinent information through a client questionnaire typically
provided by the Third-Party Investment Adviser to assist you in the selection of a model portfolio. You may accept
or reject your IAR’s recommendation of a Third-Party Investment Advisory Program or model portfolio.
Your IAR will answer all questions about the program and the Third-Party Investment Adviser and will educate you
about the features, advantages, disadvantages, risks, and costs associated with the Third-Party Investment
Advisory Program selected. Your IAR will also assist you in completing the application and paperwork required
by the Third-Party Investment Adviser and shall initiate the steps necessary for your participation in the Third-
Party Investment Advisory Program. Your IAR will forward to PAS all account opening documentation and
information, including any reasonable investment restrictions requested by you. PAS will then forward such
documentation to the Third-Party Investment Adviser for review and approval. The Third-Party Investment
Adviser is solely responsible for reviewing, accepting, or rejecting and implementing any reasonable investment
restrictions imposed by you.
If you have granted the Third-Party Investment Adviser discretion under an applicable Third-Party Investment
Advisory Program, you have the ability to add or modify any previously requested investment restrictions
imposed on the Third-Party Investment Adviser. Your IAR, on an ongoing basis, shall review and discuss your
participation in the Third-Party Investment Advisory Program(s) and model portfolio(s) and shall communicate
changes in your financial situation to the Third-Party Investment Adviser, as necessary. PAS will forward any
updated information it receives from you to the Third-Party Investment Adviser for review and assist you in
making any appropriate changes to your account, if necessary.
PAS does not serve as a broker-dealer for your Third-Party Investment Advisory Program account and does not
place trades in connection with the securities held in your account.
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Securities-Backed Lines of Credit Offered Through Third-Party Investment Advisory Programs
You may be eligible to use your Third-Party Investment Advisory Program account as collateral for a Securities-
Based Line of Credit (“SBLOC”).
If you participate in an SBLOC program, you will pay interest to on the loan value in addition to any advisory fees
charged in the Third-Party Investment Advisory Program account being used as collateral. Neither PAS nor its
IARs receive any portion of the interest paid by clients for SBLOC services.
To determine if your Third-Party Investment Advisory Program account is eligible for SBLOC services, please
consult with your PAS IAR.
Important Considerations relating to SBLOC services
In certain circumstances, your IAR may recommend, and your account may be approved for SBLOC services.
Your IAR will benefit from recommending SBLOC services because you do not have to liquidate assets in your
account to pay for items with cash, which would diminish the assets held in the account and the potential fees
and commissions that could be earned by your IAR from holding or engaging in future transactions with those
assets. For example, with a fee-based account, by recommending an SBLOC loan to fund some purchase or
financial need rather than liquidate securities, PAS and your IAR continue to earn fees on the full account value.
There are substantial risks associated with the use of securities as collateral for a loan such as:
the risk of borrowing and the impact of the use of borrowed funds on advisory accounts;
the risk that you may lose more than your original investment;
the possibility you may not benefit from collateralizing your account for a loan in a Third Party Advisory
program account if the performance of your account does not exceed the interest expense being charged on
the loan plus the additional advisory fees incurred by your account as a result of the deposit of the loan
proceeds; &
the risk of being required to deposit additional funds into your Third-Party Investment Advisory Program
account if the account depreciates in value.
For more information about SBLOC services through your elected Third-Party Investment Advisor, inclusive of
any potential conflicts the Advisor may have in offering these services, please review the Advisory Brochure of
your Third-Party Investment Advisor.
If you elect to, and are approved for SBLOC services, it is important you understand these risks and carefully
read the application and disclosure information provided when applying for SBLOC services.
The following is a list of Third-Party Investment Advisory Programs available through PAS, where PAS acts as a
solicitor, or in some instances, as adviser or co-adviser:
Third-Party Investment Advisers
SEI Investment Management Corp.
AssetMark, Inc.
Matson Money, Inc.
Morningstar Investment Services, Inc.
BNY Mellon
Stonebridge Capital Management*
Gould Asset Management, LLC*
Silvercrest Asset Management Group, LLC*
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Orion Portfolio Solutions, LLC
Efficient Advisors, LLC
Please note that from time to time one or more of the above-listed programs may not be available to new clients.
Additional information about these Third-Party Investment Advisory Programs is available through your IAR, or
you may access the Form ADV for each of these advisers via the SEC’s website at www.adviserinfo.sec.gov.
The primary Third-Party Investment Advisory Programs PAS offers are summarized below.
*Noted Third-Party Investment Advisory Programs are only offered through specific IARs of PAS. Please contact
your IAR if you have questions regarding the programs offered through these firms
SEI Investment Management Corporation
SEI Investment Management Corporation (“SIMC”) sponsors and is adviser to the SEI programs, which are
offered through PAS for investment by its clients, such as high net worth individuals, trusts, endowments and
foundations, and institutions. PAS offers two types of programs through SEI: (i) the SEI Asset Management
Program which is an institutional mutual fund asset allocation program; and (ii) the SEI Managed Account
Solutions program which is a wrap fee program that charges a bundled fee that includes advisory, brokerage
and custody services.
SEI Asset Management Program (closed to new clients as of April 2, 2018)
For the SEI Asset Management Program, your IAR will assist you in the establishment of your account, which is
custodied at SEI Trust Company. The relationship between you and SEI Trust Company is governed by a separate
custodial agreement. Under the SEI Asset Management Program, you grant PAS limited authority with respect to
reallocations in your account based on changes made by SIMC to the asset allocation models. PAS will direct SEI
Trust Company to allocate your investments in accordance with the asset allocation policy adopted by you. You
have the ability to impose any reasonable restrictions or modify any existing restrictions on the management of
your account.
SEI Managed Account Solutions
Under the SEI Managed Account Solutions Program, SIMC enters into a tri-party investment advisory agreement
with you and PAS, which provides for the management of your assets in accordance with the terms of the
Investment Management Agreement. Pursuant to the Investment Management Agreement, you appoint PAS as
your investment adviser for the purpose of assisting you in selecting an appropriate asset allocation strategy and
selecting available sub-advisers that have been assigned to the strategy by SIMC. You appoint SIMC, through
its manager-of-managers structure, as your investment adviser to manage the assets in each Managed Account
Solutions portfolio in accordance with the strategy selected by you with the assistance of PAS. You may elect to
invest in one or more of the Portfolios. Portfolios may include: (i) allocations to one or more asset classes
managed through your selection of specific Portfolio Managers; (ii) allocation to investment models consisting
solely of investments in SEI Funds (“SEI Fund Models”) or exchange traded funds or (iii) an allocation to a DFS
Strategy, which are portfolios of SEI Funds or ETFs intended for investors in or near retirement. You have the
ability to impose any reasonable restrictions or modify any existing restrictions on the management of your
account.
Under the SEI programs, PAS is responsible for gathering information about your current financial situation, risk
tolerance, time horizon, and asset class preference. PAS uses tools made available by SEI, including SEI’s
proprietary proposal tools, to develop the appropriate asset allocation strategy for you. Based upon your
information, you will work with PAS to select from one of several asset allocation models developed by SEI, which
may be composed of SEI mutual funds. SEI may provide PAS with assistance in developing client investment
proposals using SEI mutual funds or managed accounts. Your IAR will continue to review the account for program
suitability and your IAR will retain responsibility for an annual review of your account.
Any securities in your SEI account that are not managed under the SEI programs described above will be held in
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Client Directed Portfolios. Securities which are held in Client Directed Portfolios are not included in the periodic
performance reports of the SEI program portfolio you have selected. PAS, SIMC and your IAR do not provide
investment advisory services of any kind with regard to Client Direct Portfolios, do not charge an advisory fee on
such assets and do not have any responsibility with respect to the management of holdings within Client Directed
Portfolios. SEI does not take holdings held within Client Directed Portfolios into consideration when providing
investment advice for your SEI program account.
SEI Institutional Program
PAS IARs are compensated for referrals to the SEI Institutional Group. SIMC offers investment management and
investment advisory services directly to institutional clients through SEI’s business segment called Institutional
Investors (the “Institutional Group”). SIMC’s Institutional Group delivers integrated retirement and non-profit
investment solutions to institutional clients including, but not limited to, corporate and union sponsored pension
plans, public plans, defined contribution plans (including 401(k) plans), endowments, charitable foundations, and
hospital organizations (each a, “Client” and together the “Clients”). All investment advisory services regarding the
Client’s SEI Institutional Group will be provided by the SEI Institutional Group pursuant to an agreement between
the Client and SEI Institutional Group.
Please review the Fee Disclosure Statement or contact your representative at SEI for more information on SEI’s
respective investment advisory practices.
AssetMark, Inc.
AssetMark, Inc. (“AssetMark”) is the sponsor and adviser of the AssetMark investment advisory programs
(“AssetMark Platform”) and works with PAS to implement the AssetMark Platform for PAS clients. As part of its
services, AssetMark provides account administration and has developed internet-based software, which
provides PAS and its IARs with the ability to directly monitor client accounts, download information concerning
changes in the AssetMark Platform, and access current information relating to the AssetMark Platform.
To establish an account on the AssetMark Platform, you will enter into a Client Services Agreement with
AssetMark and PAS. In establishing your account, you may complete a questionnaire, or otherwise provide
information to PAS, to enable you and PAS to identify your risk tolerance and investment objectives. You may be
asked to provide information concerning your investment experience, anticipated need for liquidity, potential
timing of the need for retirement funds, and other investment needs and parameters. This information will assist
you and PAS in selecting the risk/return profile that is most closely aligned with your investment goals.
AssetMark makes a number of different investment options available to clients through the AssetMark Platform.
These include Mutual Fund Accounts, ETF Accounts, Guided Portfolios, Privately Managed Accounts and
Unified Managed Accounts.
AssetMark’s Custom GPS Select – This product is available to eligible PAS IARs who are Series 7 licensed.
Your IAR has the ability to make changes to the asset allocation and /or investment selection of the Custom
GPS Select portfolio selected within your prescribed risk profile and investment objectives upon your approval.
AssetMark retains responsibility for the management of your account and will confirm changes made to a pre-
existing Custom GPS Select portfolio by your IAR to ensure any new allocation continues to align with your risk
profile and investment objectives.
Your IAR will continue to review the account for program suitability and will retain responsibility for an annual
review of your account.
Matson Money, Inc.
Matson Money, Inc. (“Matson”) sponsors and is adviser to the Matson Money Fund Platform, which is offered
through PAS for investment by its clients. To establish an account through the Matson Money Fund Platform, you
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enter into an investment management agreement with Matson and PAS under which Matson is granted
discretionary authority to invest your assets and PAS acts as the soliciting adviser. Under the Matson Money Fund
Platform, you respond to a client questionnaire that assesses your risk tolerance and investment objectives.
Based on your responses to the questionnaire, Matson will assign you to one of its various model portfolios.
Each model portfolio is composed of mutual funds managed by Matson, currently the Free Market U.S. Equity
Fund, Free Market International Equity Fund and Free Market Fixed-Income Fund (the “Matson Funds”). Each
Matson Fund is a “fund of funds,” which invests primarily in shares of no-load mutual funds managed by
Dimensional Fund Advisors (“DFA”) which, as sub-adviser to each Matson Fund, selects the underlying DFA
mutual funds based on the investment characteristics specified by Matson and described in the Matson Funds
prospectus. Each Matson Fund is designed to target specified percentages of certain asset classes in the Matson
Fund’s applicable investment category to seek maximum portfolio diversification, enhanced return potential and
diminished portfolio volatility. Matson reserves the right, in its sole discretion, to create, and allocate assets in
client accounts to, additional Matson Funds in the future.
Matson may also invest your assets in unaffiliated cash sweep vehicles for temporary or other defensive
purposes. More complete information is available in the Matson Funds prospectus.
IARs who wish to offer the Matson Money advisory programs are required to pay a fee to Matson in the
amount of $10,000. The fee includes educational and training courses, some of which are required by
Matson prior to permitting participation as a solicitor. Matson also requires IARs to solicit at least
$100,000 of client assets within the first year of acting as a solicitor. If this minimum is not met, Matson
reserves the right to terminate its relationship with your IAR. As the amount of assets referred to Matson
by your IAR increases, the amount of marketing assistance provided to your IAR also increases, at no
additional cost. Therefore, IARs who offer the Matson advisory programs have an incentive to select
Matson over another program.
Your IAR will continue to review the account for program suitability and will retain responsibility for an annual
review of your account.
Morningstar Investment Services, LLC
Morningstar Investment Services LLC (“Morningstar”) is the sponsor and adviser to the Morningstar Managed
Portfolios Program (the “Morningstar Program”) which is offered through PAS for investment by its clients. The
Morningstar Program consists of multiple investment strategies with multiple portfolios intended for a range of
clients based on such factors as age, financial situation, time horizon, risk tolerance, and any reasonable
restrictions that you may place on the portfolio selected for your account.
The Morningstar Program includes various strategies consisting of mutual funds, exchange-traded funds, and
equity securities; Morningstar or an affiliate provides discretionary management for the Morningstar Program
strategies.
To establish an account, you enter into an investment management agreement with Morningstar under which
Morningstar is granted discretionary authority to invest your assets. Your IAR will assist you with filling out a
client questionnaire to assist in your selection of an appropriate investment strategy from those available within
the Morningstar Program (i.e., mutual fund strategies, stock basket strategies and exchange-traded funds
strategies) and in determining whether any reasonable restrictions on the investment of your account assets
should be imposed. This information will be provided to Morningstar before your account is opened including,
when applicable, your basis for selecting a portfolio other than the one identified by the Morningstar Program
questionnaire/proposal system.
PAS will continue to review the account for program suitability and your IAR will retain responsibility for an annual
review of your account.
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This program is also available through Park Avenue Strategist SelectSM.
Orion Portfolio Solutions, LLC
Orion Portfolio Solutions, LLC (“Orion”) is the sponsor and adviser to the Orion Strategist Program (as defined
below) which is offered through PAS for investment by its clients. Through this program Orion provides a fee-
based platform for PAS IARs to utilize Orion’s selected institutional portfolio strategists (the “Orion Strategist
Program”) that are vetted and monitored by Orion. For the Orion Strategist Program, Orion retains third party
investment managers that are not affiliated with OPS (“Strategists”), to design and manage model portfolios that
IARs can recommend to clients for management of client assets.
To establish an account through Orion you must enter into an investment management agreement with Orion
and PAS under which Orion is granted discretionary authority to invest your assets and PAS acts as a solicitor.
Your IAR will continue to review the account for program suitability and will retain responsibility for an annual
review of your account.
Certain Orion programs are also available through Park Avenue Strategist SelectSM.
Efficient Advisors, LLC
PAS IARs may refer ERISA qualified plan assets to Efficient Advisors, LLC (“Efficient”). Efficient acts as an
investment manager and controls the investment of plan assets. Efficient provides investment–related services
to qualified plan assets as an investment adviser registered under the SEC and provides these services in its
capacity as a fiduciary within the meaning of § 3(38) of ERISA.
Efficient provides the following services:
Construct, maintain and monitor model asset allocation portfolios (Models) for Plan participants.
Develop or assist with the development of an investment policy statement (IPS) for the Plan.
Exercise full investment discretion with regard to buying, managing, and selling assets held in Models.
Monitor investment options.
Meet with plan sponsor on a periodic basis to discuss the reports and the investment recommendations.
Select a qualified default investment alternative under ERISAsection404(c)(5).
Communicate to the plan's investment committee all significant changes pertaining to the assets it
manages or the investment management firm itself. PAS IARs may provide the following services to the
plan sponsor:
Assisting plan sponsor with completing all appropriate documentation to support plan implementation.
Conducting enrollment meetings with participants and providing investment education services to plan
participants.
ManagedPlan™ Program
The ManagedPlan™ program is available on the Envestnet Wealth Management Technology platform and is a
comprehensive retirement plan solution whereby Envestnet Retirement Solutions, LLC (“ERS”) will perform
implementation services with the retirement plan record-keeper, PCS Retirement, LLC (“PCS”).
ERS provides investment related services to qualified plans such as 401(k), 403(b) and 401(a) plans, profit
sharing plans, defined benefit pension plans and cash balance plans, and acts in the capacity as a fiduciary
within the meaning of Rule 3(38) of ERISA. When acting as a fiduciary, ERS acts in accordance with the
Investment Advisers Act of 1940, as amended (“Advisers Act”) and for Plans subject to the Employee Retirement
Income Security Act of 1974, as amended, (“ERISA”), in accordance with ERISA Title I rules. In providing Plan
Sponsor Services, ERS acts with the care, skill, prudence, and diligence that a prudent person, acting in the same
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capacity and with the same information, in a similar situation would utilize. ERS provides an investment strategy
(“Strategist Model”) of a non-affiliated third-party investment manager (“Third Party Strategist”), whereby the
Third-Party Strategist, acting as an investment model provider, constructs an asset allocation and selects the
underlying investments for each portfolio. The Strategists are American Funds, Blackrock, and Orion.
The Plan Sponsor is responsible for selecting the Third-Party Strategist that it wishes to make available to its
Plan. Acting as the “investment manager” (as defined in Section 3(38) of ERISA), ERS performs overlay
management of the Strategist Model by monitoring the investment strategy and, in certain cases, facilitating the
routing of trade orders to the recordkeepers for execution, and periodically updating and rebalancing each
Strategist Model pursuant to the direction of the Third-Party Strategist. ERS may, from time-to-time, replace
existing Third-Party Strategists and cannot guarantee the continued availability of Strategist Models.
ERS retains final decision-making authority with respect to removing and/or replacing investments in the core
lineup, and communicates instructions to the appropriate third-party, including the Plan’s record keeper,
custodian, and/or third-party administrator to facilitate investment changes.
PAS IARs may refer qualified plan assets to ERS to invest in the ManagedPlan™ program and may provide the
following services to the plan sponsor:
Assisting plan sponsor with completing all appropriate documentation to support plan implementation.
Conducting enrollment meetings with participants and providing investment education services to plan
participants.
The annual fee for the referral and ongoing services provided by your PAS IAR ranges from 50bps to 175bps, a
portion of which is retained by PAS. The fee does not include recordkeeping or individual participant fees, which
are fully disclosed in the client agreement and proposal. The fee also excludes other related charges such as
custody and clearing, Third Party Administrator (TPA) fee, and 3(38) services provided by ERS.
BNY Mellon Wealth Management
PAS IARs may refer ultra-high net worth clients to BNY Mellon Wealth Management for Investment advisory
services while also providing ongoing client services in a co-advisory capacity. The investment management of
the client’s BNY Mellon account will be provided by BNY Mellon pursuant to an agreement between the client
and BNY Mellon. BNY Mellon provides the following services to clients:
Strategically designed platform of investment solutions tailored for private clients.
Actively managed investment strategies across a range of asset classes and styles.
Customized objective-based allocation recommendations.
A separate agreement between PAS and you govern the services the PAS IAR will provide as it relates to the
BNY Wealth Management program. The services your PAS IAR will provide are:
Ongoing holistic advice and guidance across your overall investment portfolio;
Interviewing you prior the introduction to BNY Mellon’s services to ascertain your financial position,
investment goals and objectives, investment limitations, reasonable restrictions (if any) and risk tolerance.
Determining the suitability of the introduction to BNY Mellon and determining whether the BNY Mellon
services may be suitable.
Contacting you at least annually to determine whether there has been a change in your financial situation or
investment objectives.
Participate in the BNY Mellon annual review process with you.
Please review the fee disclosure document or your PAS IAR for more information on BNY Mellon’s respective
investment advisory practices.
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Stonebridge Capital Management
Certain PAS IARs are compensated for referrals to Stonebridge Capital Management (“Stonebridge”). All
investment advisory services regarding the client’s Stonebridge account will be provided by Stonebridge
pursuant to an agreement between the client and Stonebridge.
Stonebridge may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets
among unaffiliated independent investment managers (“Independent Managers”) in accordance with the client’s
designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day
responsibility for the active discretionary management of the allocated assets. Stonebridge shall continue to
render investment advisory services to the client relative to the ongoing monitoring and review of account
performance, asset allocation and client investment objectives. Factors which Stonebridge shall consider in
recommending Independent Manager[s] include the client’s designated investment objective(s), management
style, performance, reputation, financial strength, reporting, pricing, and research. Please review Stonebridge’s
Form ADV Part 2A or contact your representative at Stonebridge for more information on Stonebridge’s
respective investment advisory practices.
Gould Asset Management LLC
Certain PAS IARs are compensated for referrals to Gould Asset Management LLC. (“Gould”). Gould provides
investment management services, primarily through individually managed accounts for individuals and
institutions. Unless otherwise noted, Gould constructs portfolios primarily or exclusively using mutual funds,
including traditional open-end, exchange-traded, and closed-end funds. Such mutual funds may be primarily or
exclusively index or index-like funds, depending on the investment strategy. Gould’s management agreement
with the client generally provides Gould with authority to act on a discretionary basis with client assets. Please
review Gould’s Form ADV Part 2A or contact your representative at Gould for more information on Gould’s
respective investment advisory practices.
Silvercrest Asset Management Group LLC
Certain PAS IARs are compensated for referrals to Silvercrest Asset Management Group LLC (“Silvercrest”).
Client accounts are generally managed on a fully discretionary basis where Silvercrest makes all decisions as to
which securities are bought or sold and/or the total amount bought or sold. Silvercrest tailors its advisory
services to the individual needs of its clients. Silvercrest's portfolio managers apply specific objectives and
guidelines for each client portfolio which they are responsible for managing. Please review Silvercrest’s Form
ADV Part 2A or contact your IAR for more information on Silvercrest’s respective investment advisory practices.
Assets Under Management
As of December 31, 2023, PAS maintained $11,881,593,369 of Regulatory Assets Under Management of which,
$10,134,454,678 were managed on a discretionary basis and $1,747,138,691 were managed on a non-
discretionary basis. In its capacity as a solicitor or co-adviser, PAS maintained assets under administration of
$8,997,671,211.