Park Avenue Securities LLC

Park Avenue Securities LLC 10 Hudson Yards, New York, NY 10001 Phone: 888-600-4667 Web: https://www.parkavenuesecurities.com/ April 23, 2026 Park Avenue Signature Portfolio℠ Wrap Fee Program Brochure This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of Park Avenue Securities LLC (“PAS”). If you have any questions about the contents of this Brochure or would like to obtain a free copy of this Brochure, please contact us at (888) 600-4667 or visit https://www.parkavenuesecurities.com/. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about PAS is also available on the SEC’s website at https://adviserinfo.sec.gov/. PAS is a registered investment adviser and conducts its business under marketing name Park Avenue® Wealth Management. Registration as an investment adviser does not imply a certain level of skill or training. PAS017976 (4/26)  2. Material Changes Park Avenue Securities, LLC. (“PAS”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”) conducting business under marketing name Park Avenue® Wealth Management (“Park Avenue”, the “Firm”, “we”, “our” or “us”). Pursuant to SEC rules, this item summarizes the specific material changes, if any, that have been made to this Form ADV Signature Portfolio Wrap Fee Program disclosure brochure (“Brochure”) since the last annual update of this Brochure on March 19, 2025. When required or appropriate, we will also provide clients interim summary updates of material changes to this Brochure. You are strongly encouraged to read this Brochure in detail and contact your investment adviser representative (“IAR”) with any questions. Clients may ask for a copy of our current Brochure, which includes all material changes since the previous Brochure, or a summary of material changes to the previous Brochure at any time, without charge, by contacting us at (888) 600-4667 or via the Contact Us link at https://www.parkavenuesecurities.com/. Clients may also obtain a copy of this Brochure or a copy of any other of our Form ADV disclosure brochures by accessing and downloading them from our website at https://www.parkavenuesecurities.com/ under Form ADV Brochures. The following is a summary of material changes to this Brochure since the last annual update on March 19, 2025. April 23, 2026 Update Park Avenue Securities LLC begins operating under the marketing name Park Avenue® Wealth Management. Our legal name remains Park Avenue Securities LLC, and we will continue to be the registered investment adviser providing your advisory services. March 20, 2026 Update Item 9. Additional Information  Disclosure and descriptions of IAR conflicts related to outside business activities and IAR loan/lending arrangements are provided under section Other IAR Conflicts. December 31, 2025 Update Item 4. Services, Fees and Compensation has been amended as follows:  A description of PAS’s ERISA 3(38) Investment Management Services has been added.  Information has been added related to PAS’s parent company, The Guardian Life Insurance Company of America (“GLIC”), obtaining warrants from Hamilton Lane and Hamilton Lane’s management of a portfolio of GLIC’s general account. Item 9. Additional Information  Additional information has been added related to new additional compensation paid by Park Avenue to certain IARs.  Additional information has been added regarding third-party payments in the form of revenue sharing being paid to PAS. March 19, 2025 Update Item 4. Services, Fees and Compensation has been amended as follows: 2 PAS017976 (4/2026)   Additional disclosures and descriptions of available accounts and relationships with PAS’ lending services, and PAS’ capacity as broker-dealer of record on all PAS Proprietary Program accounts.  Additional disclosures and descriptions related to program fees paid to PAS for the PAS Proprietary Programs and the Cash Management Sweep Program.  Additional disclosure and descriptions related to Alternative Investment offerings.  Additional disclosures and descriptions related to Householding for Annual Platform Fees. Item 6. Portfolio Manager Selection and Evaluation has been amended as follows:  Additional disclosures and descriptions of PAS’ order aggregation practices. Item 9. Additional Information has been amended as follows:  Additional disclosure and descriptions related to client referrals and other compensation.  Additional language regarding PAS being deemed to have custody of certain client funds. 3 PAS017976 (4/2026)  3. Table of Contents Section: Page: 1. Cover Page ................................................................................................................................................................................. 1 2. Material Changes ....................................................................................................................................................................... 2 3. Table of Contents ....................................................................................................................................................................... 4 4. Services, Fees and Compensation ............................................................................................................................................... 5 5. Account Requirements and Types of Clients ……………………………………………………………………………………………………………………………. 26 6. Portfolio Manager Selection and Evaluation . ............................................................................................................................ 26 7. Client Information Provided to Portfolio Managers ................................................................................................................... 32 8. Client Contact with Portfolio Managers..................................................................................................................................... 32 9. Additional Information ............................................................................................................................................................. 32 4 PAS017976 (4/2026)  4. Services, Fees and Compensation Park Avenue Securities LLC (“PAS”), doing business under the marketing name Park Avenue® Wealth Management (“Park Avenue”, the “Firm”, “we”, “our” or “us”), is a dually registered broker-dealer and investment adviser that makes available to you several proprietary and nonproprietary investment advisory programs and services. This Brochure provides you with information about the Park Avenue Signature Portfolio℠ Program (“Signature Portfolio”) where we act as the sponsor and your Investment Advisor Representative (“IAR”) acts as the discretionary investment manager. If you wish to learn about other investment advisory programs and services that we offer, you may contact us by calling (888) 600-4667 or your IAR to receive a similar disclosure brochure for those programs and services. Certain of our IARs market their practices using marketing names that differ from the name under which we primarily conduct our advisory business. In these circumstances, clients should be aware that all investment advisory services described herein are provided by IARs through and on our behalf, not the marketing names that IARs use to market their practices. The Signature Portfolio program provides clients the ability to invest in a discretionary managed open architecture investment advisory account. Park Avenue has entered into a clearing arrangement with its clearing broker- dealer, Pershing, LLC (“Pershing”) to hold and value the account owner’s securities. Signature Portfolio℠ is a wrap fee program. Wrap fee programs bundle together several service providers - an investment adviser, a broker-dealer, a clearing firm, and a custodian and offer most of these services for a single Total Client Fee. There are no individual ticket charges assessed to the client for trades within a wrap fee program. Some clients prefer having the various services "packaged" together within a wrap fee program; others prefer to select their own providers for the various services needed to manage their investment portfolios. Similarly, some clients prefer a fee structure that converts trading costs into an asset-based fee calculated on the same basis as the Total Client Fees; others prefer trading costs to be assessed on a per trade basis. Depending on a few factors, such as the number of transactions, number of shares, and nature of the securities transactions in an advisory account, the overall fees and charges borne by the client over time could be more or less than the fees and charges that would be charged if the same services were provided on a separate basis. Understanding your Relationship with Park Avenue We are subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and as a registered investment adviser, we, along with our IARs, have a fiduciary duty to you. This generally means that Park Avenue and our 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 we have identified conflicts of interest within specific sections that are otherwise describing the services we provide or the fees or compensation we or our IARs receive. Within the advisory programs described in this Brochure, we provide services as an investment adviser under the Advisers Act. In providing investment advice, your Park Avenue Investment Adviser Representative (“IAR”) can select from among different products and programs. This includes the advisory program described in this brochure and other advisory programs described in Park Avenue Firm Brochure. The majority of Park Avenue IARs can also act in his or her capacity as a registered representative of Park Avenue providing securities recommendations in a Park Avenue 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 Park Avenue. There are IARs associated with Park Avenue who are not licensed as a registered representative. These individuals may not provide securities recommendations in Park Avenue brokerage accounts and will only offer investment advisory services described within this brochure and other advisory programs described the Park Avenue Firm and other Wrap Fee Brochures. For more information about the IAR providing advisory services, 5 PAS017976 (4/2026)  you should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time you engage the IAR. You should discuss with your IAR the benefits and costs associated with the different advisory programs available at Park Avenue 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 IARs ongoing obligations when acting as an IAR versus a registered representative. Our IARs assist clients in pursuing their financial goals by providing personalized financial planning services and investment solutions. Any information you receive from us or our IARs relating to tax considerations affecting your financial arrangements or transactions is not intended to be tax advice and you should not rely upon it as tax advice. Neither we nor our IARs provide tax, legal, or accounting advice. AVAILABLE ACCOUNTS AND RELATIONSHIP TYPES When you choose to purchase products and services through us and work with our financial professionals, you have the option of investing through a transaction-based account, such as a brokerage account, a fee-based investment advisory account, or both. It is important for you to understand the services you will receive, the fees, costs, and expenses you will pay, and conflicts of interest of ours and of your financial professional in connection with each of these different types of accounts and relationships with us and your financial professional. The services, fees, costs, expenses, and conflicts of interest are summarized below and described in much greater detail in our Form CRS, Regulation Best Interest (“Reg BI”) Disclosure Document and Forms ADV, Part 2A, as applicable, which are available on our website at https://www.parkavenuesecurities.com/. In addition, if considering investing into a Third-Party Investment Advisory Program, you are encouraged to review the Third- Party Investment Adviser’s Form ADV Part 2 which will contain important information such as the program fees and expenses and any conflicts of interest of the Third-Party Investment Adviser which may exist. Transaction-Based Account, Such as a Brokerage Account As a broker-dealer, we offer 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, we may offer general, impersonal investment advice in the form of publications and other services. We will not be deemed to be providing investment advisory services unless it has entered into a contract with the client for that purpose. With a transaction-based account, such as a brokerage account, you will pay commissions and other charges (such as sales loads on mutual funds and other securities and investment products) at the time of each transaction, such as the purchase or sale of a mutual fund, stock, bond, option, Alternative Investments (“AI”), or other security or investment product. These commissions and other charges are Park Avenue’s and your Park Avenue financial professional’s primary source of compensation for the transaction-based advice your Park Avenue financial professional provides when recommending such transactions. When serving as your broker, your Park Avenue financial professional can make recommendations and provide guidance to you in selecting securities, other investment products, and services. Your Park Avenue financial professional may also provide investment education and research services, which are incidental to the brokerage services Park Avenue provides. A transaction-based account can potentially be more appropriate for you than a fee-based investment advisory account if you do not want ongoing investment advice on assets held in your account, or ongoing management of your account, and instead want only periodic or on- demand advice and recommendations specific to the purchase and sale of securities and other investment products. Additionally, this type of account can potentially result in lower costs for you if you expect to trade on an infrequent or occasional basis. When Park Avenue and your Park Avenue financial professional make securities and investment strategy recommendations to you as broker-dealer for your transaction-based account, such as a brokerage account, Park Avenue and your Park Avenue financial professional will be acting in their broker-dealer capacities for such account and are required to act in your best interest, without placing their financial or other interests ahead of your interests. You should be aware that Park Avenue and Park Avenue financial professionals are subject to 6 PAS017976 (4/2026)  various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles Park Avenue and your Park Avenue financial professional plays in a transaction, Park Avenue’s and your Park Avenue financial professional’s compensation arrangements, and Park Avenue’s financial and other arrangements with custodians, clearing firms, and other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in our Form CRS and Reg BI Disclosure Document, as well in the other important client disclosures available on our website, https://www.parkavenuesecurities.com/. 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 Park Avenue 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:  You want an adviser to provide occasional advice and recommendations on certain investments and 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. For additional information on our broker-dealer services and transaction-based account offerings, please see our Form CRS and Reg BI Disclosure Document, which are available on our website at www.parkavenuesecurities.com. Our Form CRS and Reg BI Disclosure Document may also be requested by contacting Park Avenue at (888) 600-4667 or via the Contact Us link at https://www.parkavenuesecurities.com/. For detailed information regarding the commissions, trading/execution fees, and brokerage service charges that Park Avenue establishes, controls, and charges clients when serving as a broker-dealer of record for transaction-based accounts held with Pershing, LLC (“Pershing”) as our clearing firm and custodian, please see our Fee and Commission Schedule for Accounts with Pershing (the “Client Fee Schedule”) which is provided to you at account opening, will change over time, and can be found on our website at www.parkavenuesecurities. Before consenting to any broker-dealer relationship with us or our financial professionals, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation we and our financial professionals will receive, and Park Avenue’s and our financial professionals’ conflicts of interest. After reviewing these disclosures, please address any questions you may have with your Park Avenue financial professional. Fee-Based Investment Advisory Account A fee-based investment advisory account, sometimes called a “managed account,” can potentially be more appropriate for you than a transaction-based account, such as a brokerage account, if you want ongoing investment advice and management of your account. Park Avenue offers a number of different investment advisory account programs and acts as the sponsor and broker-dealer in connection with some of those different investment advisory account programs. With a fee-based investment advisory account, you will pay an ongoing investment advisory fee based on the value of the assets held in your account in exchange for ongoing investment advice and management of your account and related services. This asset-based fee is Park Avenue’s and your IAR’s primary source of compensation related to the servicing of investment advisory accounts. The Park Avenue investment advisory accounts that are currently offered to new clients charge an “all-inclusive’ 7 PAS017976 (4/2026)  bundled fee based on the value of the assets in your account. This bundled fee usually includes a portfolio management fee, transaction, trading, and execution costs, and investment advice and is sometimes referred to as a “wrap fee.” Fees vary depending on which Park Avenue advisory program accounts you use. Investment advisory account fees are billed either in arrears (i.e., following the completion of the applicable billing period) or in advance (i.e., at the beginning of the applicable billing period) depending on the advisory program you select, and your billing methodology (i.e., in arrears or in advance) will be specified, your Statement of Investment Selection (“SIS”) and Terms and Conditions (for Park Avenue Proprietary Program Accounts, other than VestWise), the VestWise Investment Advisory Agreement, or the account opening documentation of the Third- Party Investment Advisor Program Accounts (collectively, the “Client Agreement”), or other account opening documentation. Fee charges are specified in your Client Agreement or other account-opening documentation, based on the assets held within your account for services including, but not limited to, ongoing investment advice, investment selection and recommendations, asset allocation, execution of transactions (depending on the program you are in), custody of securities, and account reporting services. Please see your Client Agreement and other account-opening documentation for additional information. After reviewing these documents, please address any questions you have with your IAR. For all Park Avenue Proprietary Program Accounts other than VestWise, our advisory fees are generally negotiable. The Park Avenue Portfolio Select Program charges separately for asset management services, ongoing investment advice, and transaction costs. In this Program, you will be charged for any transaction, trading, and execution fees, costs, and expenses that applicable to trades and other transaction occurring within your account, as described in your account-opening documentation, in addition to your asset-based advisory fees (unless your IAR has agreed to incur such charges and expenses specific to your Park Avenue Portfolio Select Program account). Applicable transaction, trading, execution, and other fees, costs, and expenses are described in detail in the applicable Client Agreement, SIS, transaction, trading, execution, and brokerage service fee schedules, other account-opening documentation, and Form ADV, Part 2A. When Park Avenue and your Park Avenue financial professional serve as investment adviser for your fee-based account, Park Avenue and your Park Avenue financial professional will be acting in their investment advisory capacities for such account and are fiduciaries, without placing their financial or other interests ahead of your interests. Additionally, when Park Avenue and your Park Avenue financial professional provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA, Park Avenue and your Park Avenue financial professional are fiduciaries within the meaning of Title I of ERISA and the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”), as applicable, which are laws governing retirement accounts. You should be aware that Park Avenue and Park Avenue financial professionals are subject to various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles Park Avenue and your Park Avenue financial professional play in a transaction, Park Avenue’s and your Park Avenue financial professional’s compensation arrangements, and Park Avenue’s financial and other arrangements with custodians, clearing firms, and other service providers, its affiliates, third- party product and service providers, and others. Important information regarding these conflicts of interest is provided in our Form CRS and Reg BI Disclosure Document, as well as in the other important client disclosures available on our website, www.parkavenuesecurities.com. 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. You should periodically discuss the various investment advisory program options with your IAR. Park Avenue IARs are compensated for servicing your Park Avenue investment advisory accounts and providing general investment advice for the Program. The compensation paid to IARs is generally comparable, except for VestWise™, the digital advisory program offered by Park Avenue, which has a lower fee structure. The 8 PAS017976 (4/2026)  compensation paid to Park Avenue and Park Avenue’s IARs for Park Avenue Programs may be more than what Park Avenue and the IAR would receive if you pay separately for investment advice, brokerage, and other services. Under Park Avenue Proprietary Programs, clients must establish an account through Park Avenue with Pershing LLC (“Pershing”). Pershing acts as the clearing firm and custodian for client assets within Park Avenue Proprietary Programs. Accordingly, all trading activity under Park Avenue 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. In addition, for all Park Avenue Proprietary Programs, Park Avenue is serving as the broker-dealer of record. By signing the SIS and Client Agreement, client authorizes and directs Park Avenue and the IAR to trade through Pershing, the applicable custodian and clearing firm. When Park Avenue acts in the capacity of the broker-dealer on your account, it receives additional compensation which it would not otherwise receive if another firm acted in the capacity of the broker-dealer on your account. Park Avenue’s receipt of additional compensation in its capacity as the broker-dealer on your account creates a conflict of interest for Park Avenue because Park Avenue has a financial incentive to, among other things, recommend itself as the broker-dealer of record and Pershing as the custodian for your account (rather than other available broker-dealers and custodians). For additional details regarding the conflicts of interest that Park Avenue has in connection with the various revenue streams it receives as your broker-dealer, please see Item 9, Additional Information, below. Park Avenue addresses these conflicts of interest by disclosing them to you; providing you with the Client Fee Schedule, which discloses the amount and rate of transaction, trading, execution, and brokerage services charges you will incur for your Park Avenue Proprietary Program accounts for which Park Avenue serves as the broker-dealer of record, the services you receive, and the securities and other investment products you purchase, hold, and sell in your account; not sharing any transaction, trading, execution, or brokerage service charges with the IARs that recommend products, share classes, transactions, strategies, or services for your account; and by requiring that there be a review of your account and transactions at account opening and periodically to determine whether they are suitable and in your best interest in light of your investment objectives, financial circumstances, and other characteristics. Pershing handles the delivery and receipt of securities purchased or sold on behalf of Park Avenue 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. For additional information on our investment advisory programs and services, please see our Form CRS and Forms ADV, Part 2A, which are available on our website at www.parkavenuesecurities.com, and through the SEC’s website at www.adviserinfo.sec.gov. Our Form CRS and Forms ADV, Part 2A may also be requested by contacting us at (888) 600-4667. Before consenting to any investment advisory relationship with us or our financial professionals, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation we and our financial professionals will receive, and conflicts of interest of ours and of our financial professionals. After reviewing these disclosures, please address any questions you may have with your financial professional. Rollovers and Fiduciary Acknowledgement When Park Avenue and its IARs provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA and 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, Park Avenue and its IARs are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not necessarily mean Park Avenue 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, Park Avenue, or the IARs. With respect to rollover transactions, certain portions of this Brochure disclosure are intended to comply with 9 PAS017976 (4/2026)  requirements under the U.S. Department of Labor’s Prohibited Transaction Exemption 2020-02, specifically; information regarding the scope of services provided by Park Avenue and its IARs, (ii) the fiduciary acknowledgement above, and (iii) the description of the material conflicts of interest under which Park Avenue and your IARs are operating. Rollovers Park Avenue and your IAR get paid when you engage in a rollover transaction. Park Avenue can recommend that you rollover assets from your workplace retirement plan or from an existing IRA into an IRA account with Park Avenue. When you engage in a rollover to an IRA, Park Avenue 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 Park Avenue and your IAR to make a rollover recommendation. Transferring an Existing Account to Park Avenue 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, the previously described charges. 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 Park Avenue 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. Investing in the Signature Portfolio Program To invest in the Signature Portfolio program, you must establish an account through Park Avenue with Pershing, which clears trades and acts as custodian for your assets. Accordingly, all trading activity in connection with Signature Portfolio will be processed through your 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 your behalf, receives, and distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender offers, and redemptions. Pershing sends statements of all activity in clients’ accounts no less than quarterly. For the Signature Portfolio program, Park Avenue has contracted with Envestnet Asset Management, Inc. (“Envestnet”), a U.S. Securities and Exchange Commission (“SEC”) registered investment adviser, to provide a technology structure for Park Avenue and your IAR to utilize when trading your account. In this program, Envestnet performs administrative and/or trading duties at the direction of your Park Avenue IAR via a licensing agreement between Park Avenue and Envestnet. If you choose to invest your assets in a Signature Portfolio account, you will sign a client agreement, which consists of the Statement of Investment Selection and Terms and Conditions (the “Client Agreement”). The Client Agreement and other account opening documentation will detail all the important terms and conditions pertaining to your account, including the management fee and the termination provisions. You are encouraged to read all the terms of the Client Agreement and other account opening documentation. Pursuant to the Client 10 PAS017976 (4/2026)  Agreement, you direct Park Avenue to invest your funds in the account in accordance with your Statement of Investment Selection and the strategy chosen by you. Park Avenue believes investors are best served by constructing well diversified portfolios that are consistent with their risk tolerance and investment objectives. Prior to funding your account, your IAR will assist you in completing an account application, a Client Questionnaire (“Client Questionnaire”) and/or other forms necessary 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 and is used to help map to a risk-based strategic asset allocation strategy. The strategic asset allocation strategy will be outlined within your Statement of Investment Selection and is designed around exposures to broad asset classes such as stocks and bonds. At account establishment, clients may choose an asset allocation that represents a risk level that is more or less aggressive than the Investor Risk Rating . During the life of your account, your selected Park Avenue IAR may, on a discretionary basis, change the individual investments of your account resulting in an asset allocation with risk that is equal to or less than your Investor Risk Rating. Signature Portfolio is a discretionary investment advisory program whereby investment management services and advice are offered on a fully discretionary basis through the Park Avenue IAR you select. As part of the Signature Portfolio program, you delegate to your IAR full authority to buy, sell, or otherwise effect investment transactions involving your assets in the account. Your account may be invested in mutual funds, ETFs, and general securities (including but not limited to individual stocks and bonds). While Park Avenue, through its IARs, has been granted discretionary authority by you over transactions that occur in your accounts, Park Avenue and your IAR have no authority to direct withdrawals out of your account without your prior consent. You may make deposits to your account at any time and request withdrawals with notice to your IAR. However, in the event your withdrawals cause the account value to fall below a level where Park Avenue, in its sole discretion, determines the account is not suitable for you, the investment advisory agreement between you and Park Avenue may be subject to immediate termination. Depending on the cash sweep vehicle selected, cash awaiting investment may be placed in money market funds that pay shareholder servicing and/or distribution fees. Your IAR will periodically review performance and other periodic reports provided to you (i.e., quarterly performance reports) and will meet with you at least annually to review your financial situation and investment objectives and to determine whether you wish to impose any reasonable restrictions on the management of your account. Clients should be aware that these reports are not official account statements regarding the assets held in, and the transactions effected in, your account. These reports are provided for informational purposes only and should not be relied upon for making investment decisions or tax purposes. You should promptly notify Park Avenue or your IAR upon discovery of any errors, discrepancies, or irregularities in these reports. Additionally, you are required to notify Park Avenue or your IAR of any changes to your financial situation or investment objectives. There is no guarantee that the objectives of any portfolio will be realized. In addition, a client may lose money by having their assets managed in accordance with any portfolio or strategy offered through the Signature Portfolio program. 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 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. For the Signature Portfolio program, any securities, positions, or holdings identified by Park Avenue as being ineligible must be sold or moved to a brokerage account. 11 PAS017976 (4/2026)  Alternatively, for consolidated reporting purposes and convenience, certain securities may be held in the Signature Portfolio program and classified as Unsupervised Assets. These may include securities transferred into your Signature Portfolio account from outside accounts that your IAR has identified to you as not appropriate for your current investment strategy for the particular account. In these cases, Park Avenue and its IARs will not serve in an investment advisory capacity with respect Unsupervised Assets, Park Avenue and its IARs will not provide investment advisory services or oversight of the Unsupervised Assets, and the Unsupervised Assets will be excluded from the calculation of the Signature Portfolio account’s advisory fee and performance and excluded from periodic performance reports for your Signature Portfolio account. While Unsupervised Assets are not included in the calculation of Park Avenue Proprietary Program account advisory fees, client’s Unsupervised Assets are subject to all other applicable fees as described in the transaction, trading, execution, and brokerage service fee schedules and other documentation applicable to their Park Avenue Proprietary Program account, including but not limited to, annual custody and valuation fees. Your account can be managed in a tax-sensitive manner; however, neither Park Avenue 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. The Signature Portfolio program is designed to comply with Rule 3a-4 under the Investment Company Act of 1940. Each account is managed based on your financial situation and stated investment objectives, in accordance with reasonable investment restrictions imposed by you on the management of the assets in the account. Although we will accept reasonable restrictions as described above, we will not have any obligation to manage your account in accordance with any investment guidelines, policy statements or other documents unless we specifically agree to do so, in writing. In addition, your IAR shall conduct an annual review of the account(s) with you. Your IAR shall implement any changes you request to your investment objectives because of changes in personal or financial circumstances. Therefore, we ask that you keep your IAR fully informed of any changes in your personal and financial information for us to manage your account(s) appropriately. Park Avenue provides you with a range of investment advisory services including:  Assistance in defining the parameters that will form the basis for the management of your account, including your financial and risk profile information and investment objectives;  Recommendation and implementation of an investment strategy;  Management of the account;  Review of your account(s) to ensure adherence to the investment objectives;  Paper and/or electronic reporting of your account performance on a quarterly basis;  Provision of custody, trade execution, and confirmation and statement generation, through the custodian; and  Year-end tax information. ERISA 3(38) Investment Management Services As part of the Signature Portfolio Program, Park Avenue and authorized IARs may also provide discretionary investment management for qualified retirement plans subject to the Employer Retirement Income Security Act of 1974 (“ERISA”). When providing these services, Plan sponsors will appoint Park Avenue as an “investment manager” within the meaning of ERISA Section 3(38). Park Avenue and IARs providing this service will acknowledge their status as a fiduciary within the meaning of ERISA Section 3(21)(A). Further, Park Avenue and the authorized IAR will be appointed as an investment manager within the meaning of ERISA Section 3(38). These services, referred to as the Signature Portfolio 3(38) program, offers the majority of, but not all investment options offered by the Signature Portfolio program with model portfolios designed to align with participant needs and plan objectives. The IAR makes and implements investment decisions on a discretionary basis pursuant to the qualified retirement plans Investment Policy Statement. Plans electing the services of the Signature Portfolio 3(38) program will complete the Plan Services Agreement for Investment Management Services (“Services Agreement”), which serves as the Terms and Conditions of the 12 PAS017976 (4/2026)  Signature Portfolio 3(38) program services and must accept the Investment Policy Statement (“IPS”) and the Statement of Investment Selection (“SIS”) on behalf of the retirement plan. The Services Agreement, IPS, and SIS will serve as the complete client agreement. These documents and other account opening documents will detail the important terms and conditions pertaining to the Signature Portfolio 3(38) services, including the management fee and the termination provisions. Plan sponsors are encouraged to read all the terms contained in these documents and other account opening documentation provided. Pursuant to the client agreement, plan sponsors direct Park Avenue to invest plan funds in the account in accordance with the Statement of Investment Selection, IPS, and the strategy chosen by the plan sponsor. Only appropriately credentialed IARs specifically approved by Park Avenue are authorized to provide these services. A summary of the services is provided below. Plan sponsors should refer to their Services Agreement and SIS for more details regarding the specific services to be provided as well as the fees charged. In addition to the Services Agreement, participating Plans must enter into a separate brokerage agreement between the Plan Sponsor and Park Avenue which will govern brokerage and custody services to be provided by Park Avenue and Pershing (as custodian), as well as trading and reporting services to be provided by Envestnet Asset Management, Inc., as described within this Brochure, including for the Signature Portfolio 3(38) services. Park Avenue, its affiliates and IARs, are not affiliated with or under common ownership, control, or operation with Pershing or Envestnet. Please review this Brochure for information related to Pershing and Envestnet services; this Brochure in its entirety; the Services Agreement; the IPS; the SIS; and the separate brokerage agreement to be entered into between plan sponsor and Park Avenue. In providing services as a broker-dealer under the Wrap Fee Program, Park Avenue is not acting as a fiduciary under ERISA. Investment Management Service – The Park Avenue IAR will select investments based upon, and in accordance with, the plan’s IPS. The IAR will provide a draft IPS based on a risk profile, any applicable investment restrictions and additional information communicated by the plan sponsor and/or the named plan fiduciary to the IAR. The IPS will set out the objectives for structuring a program of investments for the plan. It is the sole responsibility of the plan sponsor or named fiduciary to review and approve the IPS and to implement the recommendation of the IAR for the adoption of the IPS. The IAR will then select the covered investments for the plan based upon, and in accordance with, the IPS approved by the plan sponsor and/or the named plan fiduciary. Monitoring of Investment Options – The IAR reviews investment performance regularly and in accordance with the terms of the IPS. Each investment will be reviewed and monitored based upon the IPS. The IAR shall provide the plan sponsor and/or the named plan fiduciary with a report providing a statement of the investments on a quarterly basis and will also provide such other information that the IAR determines. The plan sponsor and/or the named plan fiduciary, and not Park Avenue, is responsible for the following:  Approving the IPS and SIS for the plan (following the recommendations and drafting of the investment policy statement provided by the IAR).  The selection and retention of service providers (e.g., (without limitation) a plan recordkeeper and a third- party administrator), and with respect to the excluded investments, any other advisers selected and any investment managers with respect to excluded investments. It is also the plan sponsor and/or the named fiduciary’s sole responsibility to supervise the performance of such providers. If a plan contains such excluded investments, the IAR shall not have an obligation to monitor or consider such assets (including but not limited to with respect to evaluating the plan’s overall asset allocation). Park Avenue agreements with the plan sponsor and/or the named plan fiduciary do not include services provided by other Park Avenue IARs, who may work separately with plan participants in their individual capacity, including the provision of advice regarding rollovers. 13 PAS017976 (4/2026)  With respect to the Signature Portfolio 3(38) services, this Brochure 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 ERISA. The fee charged for these services and other important information relating to the fees for the Signature Portfolio 3(38) services shall be contained within the Services Agreement and SIS. 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. The Signature Portfolio 3(38) services is a “Wrap Fee Program”, which means that one bundled fee is charged for investment management, custody, and brokerage services (including trading and reporting services) provided as part of the Signature Portfolio 3(38) services, as described within this Brochure. For additional information on wrap fees generally and the specific fees applicable to a particular plan, please review this Brochure in its entirety, the Services Agreement, the IPS, the SIS, and the brokerage agreement between the plan sponsor and Park Avenue. Please also refer to the ERISA Section 408(b)(2) Disclosure to Responsible Plan Fiduciaries of ERISA-Covered Qualified Retirement Plans section below. ERISA Section 408(b)(2) Disclosure to Responsible Fiduciaries of ERISA-Covered Qualified Retirement Plans The federal law that regulates the administration and operation of retirement and other benefit plans, known as the Employee Retirement Income Security Act of 1974 or ERISA, requires “fiduciaries” of ERISA-covered plans (“Plans”) to act solely in the interest, and for the exclusive benefit of, plan participants and beneficiaries. As part of this obligation, the “administrator” of each plan and/or the named plan fiduciary or another responsible fiduciary named by the plan document must make informed decisions in selecting plan services and investments. Regulations adopted by the U.S. Department of Labor (“DOL”), called the “section 408(b)(2) regulations,” require service providers to ERISA-covered retirement plans to describe in writing information about their services and compensation (“Disclosure”). This Disclosure is provided in connection with the section 408(b)(2) regulations and is intended to assist you, as the responsible fiduciary of your Plan (“you”), in reviewing the services and compensation of Park Avenue and your IAR. This ERISA Section 408(b)(2) Disclosure to Responsible Fiduciaries of ERISA-Covered Qualified Retirement Plans applies only to such Plans and the Signature Portfolio 3(38) services. The Retirement Plan Investment Management Services is a “Wrap Fee Program”, as described further above. This means that in connection with the account subject to the Retirement Plan Investment Management Services, Pershing provides custody and clearing services and therefore acts as a subcontractor for Park Avenue, and Envestnet provides trading, reporting, and other services. Park Avenue, its affiliates and IARs, are not affiliated with or under common ownership, control, or operation with Pershing or Envestnet. Legal, Accounting, Tax Advice and Plan Administration Not Provided with Signature Portfolio 3(38) Services Please note that Park Avenue does not and cannot provide legal, accounting or tax advice to you or to the Plan. You are responsible to maintain the Plan in compliance with requirements applicable to tax-qualified plans under the Internal Revenue Code, including, where applicable, receipt of a favorable determination letter, and Park Avenue does not have any responsibility for such matters. Park Avenue does not accept any responsibility for the administration of your Plan, including (without limitation) the timely transmission of required contributions, filing required governmental reports, preparing, or providing notices and communications to your Plan's participants as required by applicable law and regulation, or notifying you that any such notices or communications are required. You should seek the advice of your legal and other advisors with respect to these and other matters that might arise relating to the operation and administration of the Plan. Our Compensation for Signature Portfolio 3(38) Services 14 PAS017976 (4/2026)  The fees charged to your Plan for providing services are as described within the Services Agreement and SIS. Park Avenue may pay up to 95% of the Total Client Fee received in connection with the services provided for your account to your IAR. If you have questions about the compensation that is paid to Park Avenue and the IAR, please ask your IAR or contact Park Avenue at 888-600-4667. For the Signature Portfolio 3(38) services, Park Avenue does not charge any additional fees for brokerage transactions (other than certain Brokerage costs and charges described within section Program Fees) in your account and if such fees are collected by Park Avenue. With respect to compensation received by Pershing and Envestnet as part of the Signature Portfolio 3(38) services “Wrap Fee Program”, please review the following: this Brochure; the Services Agreement; and the separate brokerage agreement to be entered into between plan sponsor and Park Avenue. There is no fee for the termination of the Signature Portfolio 3(38) services or Plan Advisory Services although brokerage related account termination charges will apply. Other Matters pertaining to Signature Portfolio 3(38) Services In providing services to a Plan, Park Avenue relies on information provided by the Plan and, if there is any material change in information pertaining to the Plan, the Plan must promptly notify Park Avenue in writing and provide relevant updated information. The Plan is responsible for the exercise of proxy voting and other shareholder rights pertaining to investments held by the Plan. In addition, neither Park Avenue nor the IAR may provide any investment or other advice with respect to assets of the Plan that may be invested in stock issued by the plan sponsor and/or a self-directed brokerage option that permits participants the opportunity to allocate some or all of their participant accounts to other investments, or with respect to continuing such investments as a part of the Plan. All investments fluctuate in value and the value of the investments, when sold, may be greater or lesser than the original cost. Park Avenue does not and cannot warrant or guarantee any level of performance by any of the investments or that any investment will be profitable over time. The Plan and its participants are assuming the market risk involved in the investment of Plan assets. Past investment performance does not guarantee any level of future investment performance. Park Avenue provides advisory and/or investment management services for other clients and may give advice and take action in the performance of duties for such other clients (including those who may have similar retirement plan arrangements), which may differ from advice given, or in the timing and nature of action taken, with respect to your Plan. Park Avenue has no obligation to advise the Plan in the same manner as we may advise any other clients of Park Avenue. In addition, if Park Avenue learns confidential information in providing services to another client, Park Avenue cannot divulge any confidential information to the Plan or act upon such confidential information in providing services to Plans. Some IARs engage in outside business activities that Park Avenue does not supervise, such as (without limitation) providing retirement plan consulting, administration, recordkeeping, or similar services with respect to retirement plans. Park Avenue does not endorse or recommend any IAR or any other person to provide services to Plans that are not within the scope of services described by this Disclosure and the Services Agreement with Plans, and Park Avenue will not supervise any IAR with respect to any such outside business activities. Therefore, if IARs are engaged to provide services other than the services described by this Disclosure and the Services Agreement, it will be the Plan’s responsibility to determine whether the services are appropriate for the Plan and to monitor the services. If you have any questions relating to this Disclosure, please contact your IAR or our Home Office directly at 888-600-4667. Program Fees Fees for the Signature Portfolio program are negotiable by mutual agreement between you and Park Avenue. Subject to negotiation and upon approval of Park Avenue, the maximum annual Total Client Fee is 2.05%. Fees 15 PAS017976 (4/2026)  do not include underlying expense ratios of any mutual funds and/or ETFs selected by your IAR. These expense ratios may be found in the Model Portfolio Fact Sheet contained within the Proposal. The Total Client Fee is based on the average daily balance of assets in a client’s account during the previous calendar quarter (or if the account is opened mid-quarter on a pro rata-basis) and is payable in advance for the following quarter and specified in the Client Agreement or other account opening documentation. You will pay one total fee for the services provided in the Signature Portfolio program. The services include the brokerage and advisory services provided by Park Avenue and your IAR, the technology related services provided by Envestnet, the advisory related services provided by Envestnet the brokerage services involved in purchasing and selling the securities in your account, and the custodial and clearing services provided by Pershing. Your fee is separated into different components:  An Adviser Fee for the advisory services provided by your IAR which currently ranges from 0.50% to 1.75% of assets under management; and  A Platform Fee, which is paid to Park Avenue, as the sponsor for the Signature Portfolio Program, and for the technology related services and/or the advisory related services provided by Envestnet and Park Avenue, and the brokerage services involved in purchasing and selling the securities in your account. The Platform Fee varies depending on assets under management. Please see section Annual Platform for additional information. The Total Client Fee is shown in your Statement of Investment Selection. The fee is calculated at the end of each quarter and is debited from the account on the 10th day of the month (or the next business day if the 10th day is a non-business day), of the following quarter. If you choose a standard fee schedule rather than a negotiated fee, and your assets exceed a fee breakpoint or fall below a fee breakpoint, your Total Client Fee will be adjusted to the appropriate fee schedule in the subsequent quarter. IARs have an incentive to negotiate their Adviser Fee to a higher level when the platform portion of the fee decreases so your Total Client Fee remains level rather than decreasing at certain breakpoints. If cash or cash-equivalent funds in your account are not sufficient to pay the fee or any of the other fees charged in connection with your account, investments in your account may be liquidated in order to pay the outstanding fees. If your account is managed for only a portion of the quarter, the fee will be prorated accordingly. The Total Client Fee does not include costs or charges associated with liquidation of a client’s account and related charges, including but not limited to, express postage and handling charges, returned check charges, wire or transfer fees, transfer taxes or exchange fees, fees for paper statements and paper confirmations or other fees mandated by law, or non-brokerage related fees such as IRA trustee or custodian fees and tax qualified retirement plan account fees. In addition, Individual Retirement Accounts (“IRAs”) will be assessed a $125 termination fee upon account termination. These related charges are collected by Pershing; however, Park Avenue marks up the noted charges by as much as 150% and retains the markup. For example, to process a domestic overnight check, Pershing charges Park Avenue $12, you will be charged $15 (Pershing collects $12, Park Avenue collects $3). The markup on these charges helps defray our costs associated with maintaining and servicing client accounts. The additional compensation due to the markup presents a conflict of interest because Park Avenue receives a financial benefit when it provides services in connection with maintaining and servicing your account. However, because your IAR does not share in these other account fees, your IAR does not have a financial incentive to recommend certain transactions or recommend that Park Avenue provide such additional services. A full listing of charges is listed in the current Client Fee Schedule which is provided to you at account opening, will change over time, and can be found on our website at https://www.parkavenuesecurities.com/, or may be obtained by calling us at (888)-600- 4667. Annual Platform Fee The annual Platform Fee is a component of the Total Client Fee as described in your Statement of Investment Selection. The annual Platform Fee ranges in the aggregate from .05% to .30% of assets under management with a minimum annual fee of $90.00 per household, which will result in an annual fee percentage above .30% 16 PAS017976 (4/2026)  for the Platform Fee if a client’s household assets under management fall below a certain threshold. Should your account’s balance during a quarter be below the point at which at least $22.50 in Platform Fees, on average, are generated, your client fee shall be increased incrementally to satisfy the minimum. Using the example from above, if an account with a balance of $50,000 during a quarter generated a Platform Fee of $24.00, the $22.50 minimum quarterly fee would have been satisfied and no additional expense would be incurred. However, if an account with a balance of $35,000 during a quarter generated a Platform Fee of $22.20, the $22.50 minimum quarterly fee would not have been satisfied, resulting in the incremental increase of your client fee to make up for the additional $0.30. On average, account balances greater than $42,000 will not see any impact from this minimum fee. For accounts with balances less than this amount, the Platform Fee portion of your Total Client Fee shall be increased incrementally to satisfy the minimum quarterly Platform Fee. This may cause your Total Client Fee percentage to be greater than the percentage indicated on the SIS, may fluctuate from quarter-to-quarter, and is dependent on the value of your account’s assets during the prior quarter. Fluctuations in the account value during some quarters may cause the annual Platform Fee to be higher or lower than if the Platform Fee were calculated annually on the average account value because of the possible annual minimum Platform fee being assessed in a particular quarter or the possible Annual Platform fee breakpoints that may be achieved by a client account. A full listing of charges is listed in the Client Fee Schedule, which can be found in your account opening documents, or you may obtain a current version of the Client Fee Schedule by calling Park Avenue at (888)-600- 4667. Upon termination of your account, you will receive a pro-rata refund representing the period from termination date to the end of the quarter. No refunds are made in the case of a partial withdrawal from the account. Householding for Annual Platform Fee Park Avenue shall allow householding for multiple Park Avenue Proprietary Program accounts, other than VestWise. Park Avenue policy in determining client accounts that qualify as a household generally defines “household” as Park Avenue Proprietary Program accounts, other than VestWise, of the same account owner, spouses, domestic partners, parents, and children and will consider the total assets held across the full relationship versus each account individually when determining the minimum annual platform fee applicable to each individual account. You are responsible for identifying these accounts and working with your Park Avenue IAR to include them in the correct household for billing purposes. In certain circumstances, Park Avenue may, in its sole discretion, permit Park Avenue Proprietary Program accounts falling outside of the criteria listed above to be grouped as a household. To the extent your Park Avenue Proprietary Program account is subject to householding discounts for applicable Park Avenue Proprietary Program account fee components, the Total Client Fee you incur will in certain circumstances be lower than the Total Client Fee reflected in the fee table of your SIS. Fees are negotiated with each client based upon, among other things, the size and complexity of each client’s circumstances. Each IAR will negotiate with each client to determine the fees the client will be charged, therefore, fees vary among IARs and clients and some IARs charge higher fees than other IARs for similar or identical services. The fees charged by each entity providing services to the Park Avenue Proprietary Programs vary based on the securities and other investment products used, the size of the client’s account and/or household, and other factors. Advisory Account Balance Current Annual Platform Fee[1] Future Annual Platform Fee (As of Oct..1, 2021) Adjustment to Annual Platform Fee to Reach $90 Minimum Family Relationship $55 each (Total = None 2 separate accounts, $25,000 each (Total = $50,000) $55 each (Total = $110) $110) +$13 to meet the minimum $35,000 $77 $90 Accounts or Family Relationships with $35,000 in aggregate assets [1] Your individual account platform fee may differ from this example; please contact your IAR if you would like more information 17 PAS017976 (4/2026)  For Individual Retirement Accounts (“IRAs”) being added to a household it is the client’s responsibility to consider the balances and activities of that account in a household and determine if it’s appropriate to household such account. A client should contact their legal or tax advisor to understand any possible unanticipated tax consequences of householding such accounts. If a client determines that they wish to exclude an IRA account from a billing group, the client is required to contact Park Avenue Securities or their financial advisor to request that the account not be included in the household. Mutual Funds, Close Ends Funds and ETFs in Proprietary Advisory Programs In addition to the Total Client Fee, you pay the fees and expenses of the mutual funds, closed-end funds, and ETFs (mutual funds, closed-end funds, and ETFs collectively, “Fund(s)”) in which your account is invested. Fund fees and expenses are charged directly to the pool of assets the Fund invests in and are reflected in each Fund’s net asset value. These fees and expenses are an additional cost to you and are not included in the fee amount in your account statements. Each Fund expense ratio (the total amount of fees and expenses charged by the Fund) is stated in its prospectus. The expense ratio generally reflects the costs incurred by shareholders during the Fund’s most recent fiscal reporting period. Current and future expenses may differ from those stated in the prospectus. You do not pay any sales charges for purchases of Funds in the programs described in this Brochure. However, some Funds may charge, and not waive, a redemption fee on certain transaction activity in accordance with their prospectuses. Please refer to the applicable prospectus for more information. If you have authorized prospectus redirection to Park Avenue in a discretionary Proprietary Program, you may contact your IAR or Park Avenue to review or obtain a copy of the prospectus for Funds used within the Park Avenue Proprietary Programs. You should be aware that, in addition to the Total Client Fee paid by you for advisory services under a Park Avenue Proprietary Program, each investment company (i.e., mutual fund) in the program also has its own separate investment management fees and other expenses. These mutual funds may include assets managed by Park Avenue Institutional Advisers LLC (“PAIA”), an affiliate of Park Avenue, as a sub-adviser to certain mutual funds offered by Victory Capital. Further, certain mutual funds with a front-end sales charge may be purchased in a client’s account at net asset value (“NAV”) without a sales charge to a client (“NAV Funds”). Certain mutual funds available through the Park Avenue Proprietary Programs make payments to broker-dealers, including Park Avenue, with respect to sales of mutual fund shares pursuant to Rule 12b-1 under the Investment Company Act of 1940 (“Rule 12b- 1 Service/Distribution Fees”) or otherwise as administrative service fees. These fees are described in the prospectus for the respective mutual fund. Such payments are made from mutual fund assets and have the effect of reducing mutual fund performance. Park Avenue does not negotiate these payments, which are made solely at the discretion of the mutual fund. Park Avenue credits any Rule 12b-1 Service/Distribution Fees it receives to client accounts (except for certain money market mutual funds and FDIC sweep vehicles). Park Avenue shall not be responsible for any misstatement or omission or for any loss attributable to such misstatement or omission contained in any Fund prospectus, fact sheet or any other disclosure document provided to us for distribution to you. Mutual Fund Share Class Selection The following is applicable to Park Avenue Proprietary Programs, exclusive of VestWise™, mutual fund portfolios managed by a third-party Strategist or third-party Investment Manager, and funds used within the Cash Management Sweep Program. investor eligibility requirements prescribed by a mutual fund company; When negotiating and discussing your Total Client Fee, you should understand that mutual fund companies offer a variety of share classes with different expense levels. These expense levels, known as expense ratios, are fees and expenses charged by the mutual fund company and that investors will pay to purchase, hold, and sell shares of a mutual fund. You should not assume that you will be invested in the share class with the lowest expense ratio for a mutual fund due to the following factors:   Park Avenue’s mutual fund share class selection processes. 18 PAS017976 (4/2026)  An investor who holds a more expensive share class of a mutual fund will pay higher fees over time and earn lower investment returns than an investor who holds a less expensive share class of the same mutual fund. When evaluating the reasonability of fees, you should consider not just the fees that you pay for investment advisory services through Park Avenue, but also the additional fees and expenses charged by the mutual fund companies in your account. For detailed descriptions of the components of a fund’s expense ratio by share class, please refer to the mutual fund prospectus. In addition, an overview of mutual funds share classes is available within the Park Avenue Mutual Fund Disclosure document located at www.parkavenuesecurities.com/legal/mutual-disclosure. As a matter of practice, Park Avenue will not invest clients into share classes containing sales charges and distribution fees such as 12b-1 fees. After determining the share classes that the Programs are eligible to purchase, pursuant to each fund’s prospectus, we will further evaluate each of these share classes and aim to select the lowest cost available share class for which the majority of the programs’ clients are eligible to purchase. This results in Park Avenue excluding certain share classes with the lowest expense ratios if the majority of clients are not eligible to purchase, such as certain Retirement share classes. Moreover, while we avoid using share classes that charge a Distribution Fee, such as a 12b-1 fee, as part of our Programs, if a Distribution Fee bearing share class is transferred into a client account, the fees are credited to client accounts monthly, as applicable, until the share class is converted pursuant to Park Avenue’s share class conversion process. Please read the section below for additional details related to share class conversions. In some instances, among the various share classes issued by a mutual fund company, a fund company may offer share classes that include a fee referred to as a Sub-Transfer Agent Fee (“Sub-TA Fee”) and share classes that do not contain this fee. Sub-TA Fees are paid by the mutual fund company to a third-party provider to subsidize certain services otherwise done by the mutual fund company, such as processing daily transactions, maintenance of account balances, mailing of prospectuses, etc. The Sub-TA Fee increases the total expense ratio of a fund. The amount of a Sub-TA Fee may differ by mutual fund company. Details related to the cost of a Sub-TA Fee are described within fund prospectuses. As matter of practice, in these instances, Park Avenue will select the share class containing the Sub-TA Fee for use within the Programs. This means that Park Avenue may not select the lowest cost share class for which the client is eligible even if there is a less costly share class that does not charge Sub-TA Fees. The Sub-TA Fee compensates Pershing, LLC (Park Avenue’ custodian) for sub-accounting, recordkeeping, and related services at the individual account level. Pershing, LLC passes along a surcharge to Park Avenue for any mutual fund that is part of a Park Avenue advisory Program which does not contain a Sub-TA Fee. Park Avenue’ practice of selecting a share class that contains a Sub-TA Fee when a share class of the same fund without a Sub-TA Fee is available, causes a conflict of interest as Park Avenue has a financial interest in selecting the Sub- TA bearing share class to avoid the Pershing, LLC surcharge. In the Park Avenue Portfolio Select, Park Avenue UMA Select and Park Avenue Signature Portfolio programs, your IAR can make mutual fund recommendations as part of your overall asset allocation. The mutual funds made available for recommendation and selection by your IAR in these programs will only be those with which Park Avenue has a selling agreement and those that have been deemed appropriate for these programs by Park Avenue. You should not assume that you will be invested in the share class with the lowest expense ratio for a mutual fund in the Park Avenue Portfolio Select, Park Avenue UMA Select and Park Avenue Signature Portfolio programs. Share Class Conversions. At least annually, Park Avenue will review the mutual fund share classes held within the Park Avenue Portfolio Select and Park Avenue Signature Portfolio programs. Mutual funds recommended by 19 PAS017976 (4/2026)  IARs in the UMA Select program will also be reviewed. If a lower cost share class is found to be available in these programs, pursuant to the funds’ eligibility requirements and Park Avenue’ share class selection processes, Park Avenue will process a conversion to a lower cost share class. Therefore, you may hold a higher cost share class of a mutual fund in these circumstances for up to twelve months before Park Avenue converts your investment to a lower cost share class. Until the conversion is implemented, we will continue to retain shares of the less favorable class for your account. Park Avenue will only convert share classes to a lower cost share class. If you are already invested in a share class that is lower in cost than what is available in these programs, as described above, you will retain your investment and will not be converted to a higher cost share class. Park Avenue SMA Select and UMA Select, Park Avenue Strategist Select and Strategist Select Plus, and Quantitative Innovations and Foundations Investment Manager Mutual Fund Share Class Selection Park Avenue IARs may also recommend the use of third-party Strategists or third-party Investment Managers within the above referenced Programs who may use mutual funds as part of an asset allocation for your account. Each Strategist or Investment Manager has their own policy regarding mutual fund share class selection and they are responsible for the mutual fund share classes chosen. Park Avenue cannot require an Investment Manager or Strategist to use the lowest cost share class available. Park Avenue also reviews a Strategist/Investment Manager’s mutual fund share class selection as part of Park Avenue’s ongoing due diligence process to determine the continued use of such Strategist/Investment Manager. Please refer to the applicable Strategist or Investment Manager’s Form ADV Part 2A or Wrap Fee Program disclosure included in your account opening documents or at www.adviserinfo.sec.gov for information regarding their mutual fund share class selection. You should not assume that you will be invested in the share class with the lowest expense ratio for a mutual fund in the Park Avenue SMA Select, Park Avenue UMA Select, Park Avenue Strategist Select, Park Avenue Strategist Select Plus, and Park Avenue Quantitative Innovations and Foundations programs. Cash Management Sweep Program A Cash Management Sweep Program (“Sweep Program”) is a service Park Avenue makes available to clients which allows clients to automatically transfer free credit balances to either a money market fund product (the “Money Market Sweep”) or an account at a bank whose deposits are insured by the Federal Deposit Insurance Corporation (“Bank Sweep”). Park Avenue Proprietary Program Accounts (“Accounts”) are eligible to participate in the Sweep Program. The Park Avenue Sweep Program is comprised of a Bank Sweep product, which all clients shall be defaulted to at account opening, as well as specific money market funds which serve as overflow funds for accounts whose Bank Sweep product balance exceeds certain Federal Deposit Insurance (“FDIC”) limits. At the time you open your Account, you shall be defaulted to one of two Bank Sweeps. All Accounts, except for IRA and Retirement Plan Accounts, will be defaulted to the Dreyfus Insured Deposits Program (DIDV). The default DIDV Bank Sweep product is an FDIC insured multi-bank deposit sweep program. Additionally, balances in DIDV within the same account which are in excess of the $2.5 million FDIC insured limit will be automatically redirected to the Dreyfus Government Money Fund (DGUXX). IRA and Retirement Plan Accounts will default to DIDM—a design of the Dreyfus Insured Deposit Program specifically for IRA/Retirement Accounts. Any balances within the same IRA/Retirement Plan Account over the $2.5 million in FDIC coverage will be diverted to the Dreyfus Government Money Fund (DGVXX). When depositing into either the default DIDV or DIDM Dreyfus Insured Deposit Programs, you will receive a Disclosure Statement and Terms and Conditions of the program you are defaulted into. Amongst other items, the Disclosure Statement and Terms and Conditions detail various conflicts of interest associated with the Dreyfus Insured Deposit Program you are participating in, how interest rates are determined, and risks associated with the program. In addition, the Disclosure Statement and Terms and Conditions will provide a description of the DGUXX or DGVXX Dreyfus Money Fund associated with your Sweep Program. You are encouraged to carefully read and understand the Disclosure Statement and Terms and Conditions. The Disclosure Statement and Terms and Conditions is readily available on the Park Avenue Cash Management webpage at https://www.parkavenuesecurities.com/cash-management, by contacting your IAR, or by contacting our Home 20 PAS017976 (4/2026)  Office at 888-600-4667. In addition, if invested into either DGUXX or DGVXX Dreyfus Money Funds, you will receive a prospectus of the fund you are invested into. Park Avenue has a conflict of interest by offering the DIDV Bank Sweep and the DGUXX Money Market Sweep Programs. Park Avenue receives a significant economic benefit when cash balances are swept into these Sweep Programs, rather than being reinvested in other investment funds or securities. For the DIDV Bank Sweep, Park Avenue receives a share in the earned income based on the amount of assets placed within the Bank Sweep. Park Avenue also receives a distribution from the DGUXX Money Market Sweeps used for overflow balances pursuant to the Fully Disclosed Clearing Agreement with its clearing firm, Pershing, LLC. The income earned from the DIDV Bank Sweep and the distribution received from the DGUXX Money Market Sweep, both of which are generated from, and paid by client deposits, are in addition to the Total Client Fee paid by clients to Park Avenue, related to investing in Park Avenue Proprietary Program Accounts. This conflict gives us a financial incentive to (i) select the DIDV and DGUXX Sweep Programs as the default Sweep Programs for all Proprietary Program Accounts other than IRA and Retirement Plan Accounts, rather than other Sweep Programs that are available that pay Park Avenue relatively lower or no revenue; (ii) recommend or advise clients to increase their deposits within the DIDV and DGUXX Sweep Programs; (iii) recommend or advise clients to invest in Proprietary Program Accounts that default into the DIDV and DGUXX Sweep Programs rather than accounts held directly with Third-Party Investment Advisory Programs; and (iv) recommend a Sweep Program option based on the compensation we receive instead of your needs. As a result, if you are invested in a Sweep Program option that pays Park Avenue a fee, the cost to you may be more than if you are invested in a Sweep Program that does not pay Park Avenue a fee. You may choose to opt out of the Sweep program by contacting your IAR. For additional information regarding payments received by Park Avenue regarding the DIDV Bank Sweep and Money Market alternative option, please review Item 9, Additional Information, specifically Dreyfus Insured Deposits Program. For more information on the Bank Sweep and Money Market overflow options as well as current yields and available bank lists please go to the following pages: https://www.parkavenuesecurities.com/cash- management and http://www.pershing.com/rates. Please note that Park Avenue does not offer all of the sweep options listed on the Pershing website. Assets held in any of the Sweep Programs will be included in the calculation of the client’s Total Client Fee, (i.e., they are considered “billable assets”). Your Account may require a certain amount of cash to remain in the Sweep Program to cover for certain costs associated with your Account. Different Sweep Program vehicles will have different rates of return, may pay Park Avenue a distribution fee, have different costs, and have different terms and conditions, such as FDIC insurance or SIPC protection, depending on the sweep vehicle. If the rate of return received from Sweep Programs fall below that of your Total Client Fee, you will experience a net negative overall return with respect to your Sweep Program deposits. The sweep vehicle is reflected on your account opening documents and on your statements. The selection of a more expensive share class of a Money Market Fund will negatively impact your overall investment returns. Sweep Program vehicles are not intended for use as a long-term investment option and are best used for short periods of time. You may be able to earn a higher yield through a different investment, and you should consult with your IAR about the available sweep options. Federal Deposit Insurance Corporation insured bank deposits are not protected by Securities Investor Protection Corporation. Although a money market mutual fund seeks to preserve the value of your investment at $1 per share, it may be possible to lose money by investing in a money market mutual fund. Shares of a money market mutual fund or the balance of a bank deposit product held in your account may be liquidated upon request with the proceeds credited to your account. Please see the money market fund’s prospectus or the bank deposit product’s disclosure document or contact your financial professional for additional information. Pursuant to SEC Rule 10b-10b(1) confirmations are not sent for purchases into money market mutual funds processed on the 21 PAS017976 (4/2026)  Sweep Program. Over any given period, the interest rates on cash balances in the Bank Sweep product may be lower than the rate of return on money market vehicles which are not FDIC insured or on bank account deposits offered outside the Sweep Program. If any sweep vehicles designated within the Sweep Program becomes unavailable at any time for any reason, Park Avenue will select an alternative in its discretion provided Park Avenue gives you 30 days advance written notice of such change and you do not object. In this event, the free credit balances in your Account will be placed into the alternative Sweep Program option. As noted earlier, all accounts will be automatically invested in a Bank Sweep vehicle. However, Park Avenue realizes an economic benefit from the DIDV Bank Sweep by sharing in the earned income based on the amount of assets placed within the Bank Sweep. For Accounts which hold a sweep vehicle charging a distribution fee retained by Park Avenue, Park Avenue does not share the distribution fee with your IAR. Therefore, your IAR does not have a financial incentive to recommend a Sweep Program option based on whether it pays a distribution fee or not. For additional information on money market funds and FDIC-Insured Deposit Sweeps, including applicable distribution fees, please see the fund prospectuses which are available on the following pages: https://www.parkavenuesecurities.com/cash-management and http://www.pershing.com/rates. Lending Services Offered to Park Avenue Proprietary Program Clients Non-Purpose Loan Program You may apply for a non-purpose loan from Pershing LLC through the Park Avenue Non-Purpose Loan Program using an eligible securities account as collateral. These eligible securities accounts may include one or more of your Park Avenue Proprietary Program accounts. In order for Signature Portfolio 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 Park Avenue on the loan value in addition to any Signature Portfolio Total Client Fee charged in the account being used as collateral. Park Avenue 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 Park Avenue Proprietary Program accounts. In order for Park Avenue 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 Park Avenue on the loan value in addition to any Program advisory fees charged in the Park Avenue Proprietary Program account being used as collateral. Park Avenue 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. 22 PAS017976 (4/2026)  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 Park Avenue 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, Park Avenue and your IAR continue to earn fees on the full account value. Park Avenue 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 Park Avenue 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 Park Avenue 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 Park Avenue 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 Signature Portfolio 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;  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 that you may not benefit from collateralizing your account for a non-purpose loan in a Signature Portfolio 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 because of the deposit of the loan proceeds. Due to the fact your Park Avenue 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 enough collateral otherwise supporting the loan (as determined by Park Avenue, 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 us, 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 23 PAS017976 (4/2026)  adverse tax consequences. Park Avenue 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 Park Avenue nor its IARs will act as investment adviser to you with respect to the liquidation of securities held in a Signature Portfolio account to meet a loan demand. Those liquidations will be executed in Park Avenue’ 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 a creditor Park Avenue may have interests that are averse 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 Park Avenue’s 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%. Park Avenue 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, Park Avenue 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 Park Avenue or Pershing, at their discretion, to liquidate 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 Park Avenue 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 Park Avenue has a financial incentive to recommend or maintain a margin loan. This compensation is retained by Park Avenue 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. 24 PAS017976 (4/2026)  Alternative Investments and Institutional Capital Network, Inc. Park Avenue 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 Park Avenue issue multiple share classes to investors. The share classes offered in Park Avenue advisory programs will contain no up-front sales charges or ongoing distribution and/or servicing fees payable to Park Avenue. 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 Park Avenue advisory programs require investors to qualify as a Qualified Purchaser, Qualified Client, and/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 Park Avenue IARs are granted access to the iCapital platform whose alternative investments may only be recommended, purchased, and advised on in the Park Avenue Signature Portfolio and Portfolio Select programs. Park Avenue approved alternative investments which may be purchased, recommended, and advised on in the Park Avenue Signature Portfolio and Portfolio Select Programs include, but are not limited to, non- traded real estate investment trusts, Delaware Statutory Trusts, hedge funds, private equity, and private credit programs that may include non-traded Business Development Companies (collectively “AIs”). Alternatively, certain AIs that are not available to be recommended, purchased, and advised on may only be held in Park Avenue Proprietary Program accounts as Unsupervised Asset. Clients should carefully consider the investment objectives, risks, costs, and expenses of an AI and particular AI share class before investing. This and other important information is available in each AI’s prospectus, private placement memorandum, or other offering documents, which can be obtained from your IAR. Clients should be aware that investing in AIs involves material risks, including liquidity risks, risks related to the difficulty in valuing certain AIs as a result of the assets in which they invest, risks related to the inability to obtain daily or otherwise current valuations for certain AIs, and other special risks, that clients could lose all or a portion of the AI investment. Additionally, clients should be aware that AI investments will in certain circumstances involve additional fees and expenses, including, but not limited to, fees imposed by AI platforms and investment vehicles through which Park Avenue makes certain AIs available to clients. Please see section Methods of Analysis, Investment Strategies and Risk of Loss for common risks associated with investing in Alternative Investments. Park Avenue makes available alternative investment funds issued by Hamilton Lane Advisors, LLC (“Hamilton Lane”). Park Avenue’s parent company, The Guardian Life Insurance Company of America (“GLIC”), has appointed Hamilton Lane to manage a portfolio of GLIC’s general account and in exchange has obtained warrants from Hamilton Lane. These warrants may be exercised in shares of Hamilton Lane, cash, or a combination of shares of Hamilton Lane and cash. The warrants issued by Hamiton Lane to GLIC creates a conflict as customer investments into Hamilton Lane funds will generate earnings and additional compensation for GLIC. Neither Park Avenue nor GLIC will share profits from GLIC’s compensation earned through the warrants issued by Hamilton Lane with your IAR therefore, your IAR does not have a financial incentive to recommend a Hamilton Lane product. Tax Harvesting Subject to meeting minimum balance requirements, you may direct Park Avenue to employ a tax harvesting 25 PAS017976 (4/2026)  strategy in taxable accounts. Once the tax harvesting threshold is met, Park Avenue will sell securities in your account at a gain or loss to offset potential capital gains, although the type and amount of capital gains will not be monitored by Park Avenue for this purpose. By authorizing tax harvesting, Park Avenue will sell one or more securities in the account and will hold proceeds in cash to avoid the 30-day wash rule. Once 30 days have passed, the funds will be reinvested in the model. Within the Signature Portfolio program, Park Avenue may select another ETF not substantially comparable to the security harvested to replace the securities that have been purchased or sold in your account. You should consult with your professional tax advisors or review the Internal Revenue Service (“IRS”) website at www.irs.gov regarding the consequences of tax harvesting in light of your particular circumstances and its impact on your tax return. If your IAR recommends a tax harvesting strategy for your account, that advice is not intended as tax advice. Neither Park Avenue nor your IAR represent that any particular tax results will be obtained. You are responsible for monitoring any accounts in your household, or accounts for which you maintain control (at Park Avenue or with another firm) to ensure that transactions in the same security or a substantially similar security do not create a “wash sale.” A wash sale is the sale at a loss and repurchase of the same security, or substantially similar security, within 30 days. If a wash-sale transaction occurs, the IRS may disallow or defer the loss for current tax reporting purposes. More specifically, the wash-sale period for any sale at a loss consists of 61 days: the day of the sale, the 30 days before the sale, and the 30 days after the sale, (these are calendar days, not trading days). The wash-sale rule postpones losses on a sale if replacement shares are bought around the same time. The effectiveness of the tax harvesting strategy to reduce your tax liability will depend on your entire tax and investment profile, investments (e.g., taxable, or non-taxable) or holding period (e.g., short-term, or long-term). 5. Account Requirements and Types of Clients The Signature Portfolio program has a minimum initial investment requirement of $10,000. All accounts will maintain a cash balance as prescribed by the account’s asset allocation. Park Avenue provides investment advisory services to individuals, high net worth individuals, pension and profit- sharing plans, charitable organizations, and corporations. 6. Portfolio Manager Selection and Evaluation Park Avenue does not select, review, or recommend outside portfolio managers for its Signature Portfolio program. Your Park Avenue IAR is the sole portfolio manager available with respect to your account and you select the Park Avenue IAR to manage the account. This may create a conflict of interest in that other investment advisory firms that use outside portfolio managers may charge the same or lower fees than our firm for similar services. Park Avenue generally requires that its IARs involved in discretionary asset management meet certain criteria established by Park Avenue to be permitted into the program and go through a review and approval process. Each Park Avenue IAR is also generally required to possess Financial Industry Regulatory Authority (FINRA) Series 7, 63 and 65 or 66 licenses. Park Avenue does not calculate the performance record of the IARs, however, Park Avenue may at its discretion calculate and review such performance or use the services of a third-party vendor to calculate and review such performance. Park Avenue does calculate performance for each account which is compared to certain selected benchmarks. Please see the Review of Accounts section for additional detail. Each Park Avenue IAR develops a unique strategy based on his or her knowledge, experience and understanding of your needs. As such, recommendations by the IAR for individual investment portfolios will differ. This individualized approach allows you and your IAR to work together to achieve your investment goals. Park Avenue extends maximum latitude to you and your IAR, within this individualized approach, as to the 26 PAS017976 (4/2026)  method in which your account will be managed. You may impose restrictions in investing in certain securities or types of securities in accordance with your values or beliefs. You may call at any time during normal business hours to speak directly with your IAR about your account, financial situation, or investment needs. Performance Based Fees and Side by Side Management Park Avenue does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Methods of Analysis, Investment Strategies and Risk of Loss Depending on a client’s particular situation, needs and expectations, there are various methods of analysis and investment strategies that your IAR may use when managing assets. Park Avenue IARs generally use fundamental and technical analysis when analyzing securities. Fundamental analysis involves assessing a company’s or security’s value based on factors such as sales, assets, markets, management, products, services, earnings, and financial structure. Technical analysis involves studying trends and movements in a security’s price, trading volume, and other market-related factors in an attempt to discern patterns. Sources of information for analysis include research material acquired from outside vendors, financial newspapers and magazines, annual reports, prospectuses, filings with the SEC and company press releases. Each IAR manages, on Park Avenue’s behalf, client assets in the Signature Portfolio account, by employing his or her own investment strategy and methods of analysis, which may or may not include one or a combination of the following techniques: review of third-party research reports, use of model investment portfolios, use of fundamental and technical analysis to review securities, etc. Park Avenue IARs are available to answer any questions that a client may have with respect to how a client’s account is managed. Regarding investment advisory services, Park Avenue subscribes to various market and investment publications and services directly or indirectly through Pershing. Park Avenue IARs also analyze the prospectuses and offering memoranda of mutual funds, ETFs, and other securities where such documentation is available in developing and evaluating investment strategies. National conventions, professional meetings and membership in industry organizations also serve to provide Park Avenue and its IARs with continuing access to the practical experiences of others and current developments. Investing in securities involves risk of loss that clients should be prepared to bear. Clients may experience loss in the value of their account due to market fluctuations. There is no guarantee that a client’s investment objectives will be achieved by participating in any of the programs described in this Brochure. Prior to investing, clients should carefully read a copy of the current prospectus for each security, where a prospectus is available, or other offering documents associated with the particular investment. The prospectus or offering documents contains information regarding the fees, expenses, investment objectives, investment techniques, and risks of each particular investment. The investment returns on a client account will vary and there is no guarantee of positive results or protection against loss. No warranties or representations are made by Park Avenue or its IARs concerning the benefits of participating in the programs described in this Brochure. Park Avenue and IARs do not provide legal or tax advice. Clients with tax or legal questions should seek a qualified independent expert. Depending on the types of securities you invest in, you may be subject to the following investment risks including, but not limited to: Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market risks. 27 PAS017976 (4/2026)  Credit Risk: also known as default risk, is the possibility that a bond issuer will not pay interest as scheduled or repay the principal at maturity. Credit risk may also be a problem with insurance companies that sell annuity contracts, where your ability to collect the interest and income you expect is dependent on the claims-paying ability of the issuing insurance company. Sociopolitical Risk: The possibility that instability or unrest in one or more regions of the world will affect investment markets. Terrorist attacks, war and pandemics are examples of events, whether actual or anticipated, that impact investor attitudes toward the market in general and result in system wide fluctuations in stock prices. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on discoveries of oil and then refining it, a lengthy process, before they can generate a profit. These companies carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic climate. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of loss if the company is unable to meet the terms of its loan obligations. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Liquidity Risk: When consistent with a client’s investment objectives, guidelines, restrictions and risk tolerances, client portfolios may be invested in illiquid securities, subject to applicable investment standards. Investing in an illiquid (i.e., difficult to trade) security may restrict the ability to dispose of investments in a timely fashion or at an advantageous price, which may limit the ability to take full advantage of market opportunities. Accounts may hold securities which are partnerships. Some partnerships are relatively liquid and may be either exchange listed or traded over the counter. However, most partnership securities are often illiquid and are subject to significantly less regulation than public investments. Fixed Income Risks: Portfolios that invest in bonds and other fixed income securities are subject to certain risks, including but not limited to, interest rate risk, credit risk, prepayment risk and market risk, which could reduce the yield that an investor receives from his or her portfolio. Foreign and Emerging Markets Risk: Investments in securities of foreign and emerging markets issuers involve different investment risks than those affecting obligations of U.S. issuers. Public information may be limited with respect to foreign and emerging markets issuers, and they may not be subject to uniform accounting, auditing and financial standards and requirements comparable to those applicable to U.S. companies. Additional risks include future political and economic developments, the possibility that a foreign jurisdiction might impose or charge withholding taxes on income payable with respect to foreign and emerging markets securities, and the possible adoption of foreign governmental restrictions such as exchange controls. In addition, foreign currency exchange rates may affect the value of securities in the portfolio. High-yield Bond Risk: Investments in high-yielding, non-investment grade bonds involve higher risk than investment grade bonds. Adverse conditions may affect the issuer's ability to make timely interest and principal payments on these securities. Structured Products Risk: These products often involve a significant amount of risk and should only be offered to clients who have carefully read and considered the product's offering documents, as their structure may be based on derivatives or other types of securities, which may be volatile. Structured products are intended to be 28 PAS017976 (4/2026)  “buy and hold” investments and are not liquid instruments. Interval Fund Risk: Investors investing in interval funds are subject to certain risks, including but not limited to fund shares not being listed on a public exchange, the lack of secondary markets, liquidity being provided only through repurchase offers by the fund on a schedule stated within the product prospectus (i.e. quarterly offers), no guarantee that an investor will be able to sell all the shares that the investor desires to sell during repurchase offer periods. Investors should consider these investments to be of limited liquidity. In addition, investing in interval funds may be speculative and involves a high degree of risk, inclusive of the risks associated with leverage. Investors should carefully read the fund’s prospectus prior to investing in an interval fund. Derivatives Risk: Derivatives are securities whose price is dependent upon or derived from one or more underlying assets. The derivative itself is a contract between two or more parties. Its value is determined by fluctuations in the underlying asset. Derivatives may involve significant risks and are not suitable for everyone. Derivatives trading can be speculative in nature and carry substantial risk of loss, including the loss of principal. Small/Mid Cap Risk: Stocks of small or mid-sized, emerging companies may have less liquidity than those of larger, established companies and may be subject to greater price volatility and risk than the overall stock market. Diversification Risk: Investments that are concentrated in one or few industries or sectors may involve more risk than more diversified investments, including the potential for greater volatility. Security Selection and Asset Allocation Risk: Securities selected from a particular asset class (e.g., stocks, bonds, money market instruments) may experience unusual market volatility or may not perform as expected. An asset allocation program does not guarantee achievement of a client’s investment objective nor protect against loss. ETF Risk: ETFs are subject to the following risks: (i) the market price of an ETF’s shares may trade above or below the net asset value; (ii) there may be an inactive trading market for an ETF; (iii) the ETF may employ an investment strategy that utilizes high leverage ratios; (iv) trading of an ETF’s shares may be halted, delisted, or suspended on the listing exchange; and (v) the ETF may fail to achieve close correlation with the index that it tracks. Real Estate Risk: Investment in real estate and real estate related assets is subject to the risk of adverse changes in national, state, or local real estate conditions (resulting from, for example, oversupply of or reduced demand for space and changes in market rental rates); obsolescence of properties; changes in the availability, cost, and terms of mortgage funds; and the impact of tax, environmental and other laws. 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. 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 Park Avenue’s advisory fee. Park Avenue 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 29 PAS017976 (4/2026)   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, Park Avenue 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, Park Avenue 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. Directed Brokerage Clients in the Signature Portfolio program must establish an account through Park Avenue with Pershing, which clears trades and acts as custodian for clients’ assets under the Park Avenue Advisory Programs. Accordingly, all trading activity in connection with the Signature Portfolio program will be processed through clients’ accounts with Pershing. Pershing acts in the capacity of a clearing firm and performs centralized custody, bookkeeping and execution functions. Pershing handles the delivery and receipt of securities purchased or sold on behalf of Park Avenue’s clients who are part of the Signature Portfolio program, receives and distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender offers and redemptions. Not all investment advisory firms will require their clients to direct brokerage. By directing brokerage, Park Avenue may be unable to achieve most favorable execution of your transactions, and this practice may cost you more money. Best Execution Investment advisers are obligated to provide “best execution” of customer orders where the adviser has the responsibility to select broker-dealers to execute client trades. “Best execution” refers to using reasonable diligence to seek to obtain the best price to buy or sell a security under prevailing market conditions. Park Avenue does not select other broker-dealers for processing of client transactions. Park Avenue must transmit all trades to Pershing for execution. Park Avenue’s objective in executing client trades is to obtain the most favorable execution and to aggregate and allocate trades fairly and equitably across all its clients. Park Avenue has adopted policies and procedures that are designed so that trading practices do not unfairly or systematically favor one client, group, or strategy over another. Park Avenue regularly receives reports from Pershing which contain information regarding the trade order execution experience of Pershing for all of its customers. Park Avenue undertakes an on-going review of its relationship with Pershing, including a quarterly review of trade order flows. Soft Dollars Soft dollars are defined as arrangements under which products or services other than the execution of securities transactions are obtained by an adviser from or through a broker-dealer in exchange for the direction of securities trades to the broker-dealer. Park Avenue does not have any soft dollar arrangements. Order Aggregation Park Avenue IARs generally manage their client’s accounts independently of one another based on each client’s specific needs and objectives, and transactions for each client account are often executed independently. 30 PAS017976 (4/2026)  Although each account is individually managed, your IAR may buy and sell the same securities for many advisory accounts simultaneously. In the Signature Portfolio Program, IARs will often aggregate the purchase or sale of multiple clients’ securities together to help facilitate best execution and provide each client with the same execution price. Aggregating multiple client orders together is particularly useful when Park Avenue or your IAR is utilizing model portfolio management strategies (multiple client accounts in the same model). IARs servicing accounts invested in the Signature Portfolio Program may determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, and the liquidity of the securities purchased or sold. If IARs do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. If different prices are paid for securities in an aggregated transaction, each client in the transaction will receive the average price paid for the block of securities in the same aggregated transaction. If the client trade is aggregated with other client accounts and is executed at the same price, the client will receive the same price per unit. Park Avenue may aggregate trades unless it believes that aggregation is not consistent with its duty to seek best execution for clients in the aggregate and consistent with the terms of the client’s investment advisory agreement. Park Avenue may exclude from aggregation those client accounts that have relevant restrictions or pending client activity. If trades are not aggregated, clients may pay prices for the transactions that are different from what they may have paid had the trades been aggregated. When aggregating, Park Avenue may, consistent with its policies and procedures and fiduciary duties, include proprietary and/or employee accounts in an aggregated order. If we are not able to completely fill an aggregated transaction, we will allocate the filled portion of the transaction following fair dealing principles, e.g., pro-rata, trade rotation. Voting Client Securities As a matter of firm policy and practice, Park Avenue generally does not vote proxies on behalf of advisory clients. Clients of the Signature Portfolio Program are however, offered two options for shareholder voting for securities held in their accounts: a. Elect to retain the right to vote: If elected, you will retain the responsibility for receiving voting materials and voting for any, and all securities maintained in your portfolio. The final decision of how to vote rests solely with you. b. Delegate voting authority to Park Avenue by enrolling in Proxy Delegation Services: Park Avenue has contracted with Institutional Shareholder Services Inc. (“ISS”), a global provider of independent and objective shareholder meeting research and recommendations to assist Park Avenue in managing its voting responsibilities on behalf of Park Avenue clients who delegate voting responsibility to Park Avenue. In addition, your election to enroll in Proxy Delegation Services authorizes Park Avenue to instruct Pershing, as your Park Avenue Signature Portfolio account custodian, to send to ISS any proxies, proxy solicitation materials, annual reports, and any other proxy voting related materials in connection with proxy solicitations that would have otherwise been provided to you directly as the shareholder. If you elect to enroll into Proxy Delegation Services, please note that Park Avenue has adopted ISS’s Proxy Voting Guidelines to use for purposes of its Proxy Delegation Services. The Park Avenue Proxy Voting Guidelines can be found on our website at https://www.parkavenuesecurities.com/. The voting guidelines are applicable to US exchange traded securities. In the event a proxy vote is issued for a non-US exchange traded security or, if ISS is unable to issue a recommendation for a certain vote, these shareholder voting matters shall go unvoted. If you have any questions regarding the Park Avenue Voting Guidelines or how a particular proxy solicitation was voted for on your behalf, please contact your Investment Advisory Representative or our Home Office directly at 1-888-600-4667. Your proxy voting election will serve as your election related to all securities held in your account. You can change your proxy voting election at any time by contacting your IAR. To learn more about ISS’ proxy voting guidelines that Park Avenue has elected to use for the purposes of Proxy Delegations Services, you may visit our website at https://www.parkavenuesecurities.com/. 31 PAS017976 (4/2026)  To learn more about Institutional Shareholder Services Inc., you may visit their website at https://www.issgovernance.com/ and/or the SEC Investment Adviser Public Disclosure website at https://adviserinfo.sec.gov/. 7. Client Information Provided to Portfolio Managers Park Avenue and your IAR will have access to your (i) account opening documents, which include, among other things, your investment objective, risk tolerance and any client-imposed restrictions on management of assets; (ii) online access to the account; (iii) confirmations; (iv) account statements; and (v) your quarterly performance reports. 8. Client Contact with Portfolio Managers There are no restrictions placed on clients’ ability to contact and consult with their Park Avenue IAR regarding the Signature Portfolio program. 9. Additional Information Disciplinary Information: The following is a chronological summary of material disciplinary events relating to Park Avenue Securities, LLC. (“PAS”) and its management personnel in the last 10 years. 11/18/2016 – In connection with the misappropriation of funds from two customers by an unregistered sales assistant, FINRA censured and fined PAS $195,000 in its capacity as a broker-dealer for failing to enforce its written supervisory procedures regarding the monitoring of customer trades and for failing to establish and maintain a supervisory system reasonably designed to follow up on the performance of its supervisors with regard to monitoring trade executions, in violation of NASD Rules 3010(a), 3010(b) and FINRA Rule 2010. FINRA noted, PAS also failed to establish, maintain, and enforce a supervisory system reasonably designed to review and monitor the transmittal of funds from the accounts of its customers to third party accounts and outside entities, in violation of NASD Rules 3010, 3012(a)(2)(B)(i) and FINRA Rule 2010. 4/11/2018 – FINRA censured and fined PAS $300,000 in its capacity as a broker-dealer for failing to implement a supervisory system and written supervisory procedures reasonably designed to train and supervise Registered Representatives’ recommendations regarding the sale of multi-share class variable annuities, including L-Share Contracts, to ensure their suitability. FINRA also found the Firm had no surveillance procedures to determine and monitor rates of variable annuity exchanges. FINRA found the foregoing to be in violation of NASD Rule 3010 and FINRA Rules 2330, 3110 and 2010. 3/11/2019 - PAS without admitting or denying the findings, consented to the entry of an Order Instituting Administrative and Cease and-Desist Proceedings (“Order”) by the U.S. Securities and Exchange Commission (“SEC”). Pursuant to the Order, the SEC found that from January 1, 2014 through October 31, 2018 certain PAS clients participating in proprietary advisory programs were invested in mutual fund share classes with higher costs (in the form of Rule 12b-1 fees) without adequately disclosing that lower-cost share classes (without Rule 12b-1 fees) of those funds were available. Specifically, PAS did not adequately disclose conflicts of interest related to its receipt of Rule 12b-1 fees, and the availability of mutual fund share classes that did not pay such fees. PAS consented to the entry of the Order that it violated Sections 206(2) and 207 of the Investment Advisers Act of 1940 and agreed to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 207. PAS agreed to pay disgorgement of $508,083 and prejudgment interest of $56,184 to affected clients. Additionally, as part of the Order, PAS has enhanced its disclosure regarding mutual fund share class selection, considered whether existing clients should be moved to a lower-cost share class, and updated its policies and procedures regarding mutual fund share class selection. 7/16/2019 – PAS without admitting or denying the findings, was censured by the Financial Industry Regulatory Authority (“FINRA”) in its capacity as a broker-dealer for failing to reasonably supervise the application of sales charge waivers for mutual fund purchases made by certain retirement plan and charitable organization customers. By failing to reasonably supervise such mutual fund sales to ensure that eligible purchasers received 32 PAS017976 (4/2026)  the benefit of applicable sales charge waivers, FINRA found that PAS violated NASD Conduct Rule 3010 (for misconduct before December 1, 2014), FINRA Rule 3110 (for misconduct on or after December 1, 2014 and FINRA Rule 2010. As part of this settlement, PAS agreed to pay restitution to eligible customers on the terms specified below, in the amount of $640,552 (i.e., the amount eligible customers were overcharged, inclusive of interest). PAS also agreed to ensure that waivers are appropriately applied to all future purchase transactions made by retirement plan and charitable organization customers. FINRA recognized the extraordinary cooperation of PAS for initiating an investigation prior to detection or intervention by FINRA to identify whether applicable customers received sales charge waivers, for promptly establishing a plan of remediation to customers and taking action to correct the violative conduct. 5/31/2023 – In connection with an undisclosed outside business activity of a PAS Registered Representative, PAS, without admitting or denying the findings, agreed to a Letter of Acceptance, Waiver, and Consent with FINRA for the purpose of settling alleged FINRA rule violations. PAS was censured and fined $30,000 by FINRA for violating FINRA Rule 3110 by failing to investigate red flags that the Representative was engaged in an undisclosed outside business activity, unapproved private securities transactions and FINRA Rule 2010. 9/24/2024 – PAS, without admitting to or denying the findings, was censured by the Financial Industry Regulatory Authority (“FINRA”) in its capacity as a broker-dealer for failing to reasonably supervise mutual fund share class recommendations to retirement plan customers, from January 2019 through July 2021. FINRA found that PAS’ supervisory system and WSPs were not reasonably designed to achieve compliance with FINRA Rule 2111 or the Care Obligation of Regulation Best Interest. As part of this settlement, FINRA issued a $125,000 fine. PAS paid restitution to eligible customers in 2022 in the amount of $91,344, which was the amount eligible customers were overcharged, inclusive of interest. Other Financial Industry Activities and Affiliations Park Avenue Securities, LLC (“PAS”), doing business under marketing name Park Avenue® Wealth Management, 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. PAS is an affiliate of The Guardian Insurance & Annuity Company, Inc. (“GIAC”), a Delaware insurance company. PAS is also an affiliate of Guardian Wealth Partners, LLC (“GWP”) and Park Avenue Institutional Advisers, LLC (“PAIA”), SEC registered investment advisers. GWP and PAIA are indirect wholly owned subsidiaries of GLIC. PAS or its IARs may recommend mutual funds whose investment adviser is a PAS affiliate, such as PAIA. PAIA is the sub-adviser to certain mutual funds offered by Victory Capital. Therefore, we have an incentive and conflict to recommend certain products which are managed by PAIA due to the additional compensation earned by such affiliate. In addition, PAS makes available alternative investment funds issued by Hamilton Lane Advisors, LLC (“Hamilton Lane”). PAS’ parent company, GLIC, has appointed Hamilton Lane to manage a portfolio of GLIC’s general account and in exchange has obtained warrants from Hamilton Lane. These warrants may be exercised in shares of Hamilton Lane, cash, or a combination of shares of Hamilton Lane and cash. While not considered a proprietary investment, the warrants issued by Hamiton Lane to GLIC creates a similar conflict. Many IARs of PAS are also agents of GLIC and GIAC and may sell a wide range of products issued by those entities, such as life insurance and variable annuities. IARs receive no additional compensation for recommending insurance products issued by affiliates or mutual funds managed by affiliates than they would if they recommend insurance products or mutual funds issued by or managed by non-affiliates. An IAR may have an incentive to recommend a particular Proprietary Investment Advisory Program or Third-Party Investment Advisory Program in favor of another because of the receipt of higher fees or non- cash benefits such as additional services which include marketing support and training provided by the sponsor of the Third-Party Advisory Program. 33 PAS017976 (4/2026)  Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Park Avenue has adopted a code of ethics (“Code of Ethics”) for all supervised persons of the firm, which governs the ethical standards of conduct and securities trading by supervised persons. The Code of Ethics includes provisions relating to, among other things, a prohibition on trading based on material non-public information or confidential information, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons of Park Avenue must acknowledge the terms of the Code of Ethics annually. Park Avenue will provide a copy of the Code of Ethics to any client or prospective client upon request. It is Park Avenue policy that the firm will not affect any principal or agency cross transactions for client accounts. Park Avenue will not permit cross trades between client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker- dealer, buys from or sells any security to any advisory client. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Review of Accounts At account opening, Park Avenue, through its IARs, gathers information from a client about that client’s financial situation, risk tolerance, investment objectives and any reasonable restrictions that the client wishes to impose upon the management of the account. Each IAR periodically reviews reports and otherwise consults with the client and contacts the client to review the client’s financial situation and investment objectives. At the annual meetings or on a more frequent basis, the client’s IAR will review the client’s account. This review is designed to determine that the selected portfolio and the client’s positions thereunder are still appropriate and consistent with the client’s financial circumstances. In addition, the client has the ability to add or modify any reasonable investment restrictions, if applicable. Clients should notify their IARs of any changes in their financial situation, risk tolerance, investment objectives or account restrictions. Park Avenue employs individuals who are registered with the Financial Industry Regulatory Authority (“FINRA”) as principals (“Registered Principals”), who review all Park Avenue proprietary program accounts for suitability. Accounts are reviewed by the Registered Principals prior to being opened. Accounts are monitored on an ongoing basis by Registered Principals. Custody Although Park Avenue’s Proprietary Program Account assets are held by a qualified custodian, Park Avenue is deemed to have custody of client funds because it has the ability to direct such custodians to deduct advisory fees from the client’s account and because some client accounts have standing letters of instruction (“SLOAs”) or other similar asset transfer authorization agreements which gives us the authority to transfer funds to a third- party. Client Referrals and Other Compensation Park Avenue and/or its IARs may receive compensation pursuant to solicitation agreements for introducing clients to the Third-Party Investment Adviser and for providing certain ongoing services. This compensation is typically equal to a percentage of the investment advisory fee charged by that investment adviser. Because IARs receive compensation from these investment advisers for referring clients and because such compensation may differ depending on the individual agreement with each investment adviser, the IAR may have an incentive to recommend one of these Third-Party Investment Advisers over another with which Park Avenue has a less favorable compensation arrangement or alternative investment advisory programs. Full disclosure of all referral arrangements, including Part 2 of Form ADV and a promoter’s disclosure statement, will be given to the client at 34 PAS017976 (4/2026)  the time of referral. Park Avenue has arrangements with a number of individuals (“Promoters”) under which the Promoters introduce potential advisory clients to Park Avenue in exchange for a referral fee. Whenever Park Avenue pays a referral fee, we require the prospective client to receive a copy of this Brochure and a separate disclosure statement that includes the following information: (1) the Promoter’s name and relationship with Park Avenue; (2) the fact that the Promoter is being paid a fee; (3) the amount of the fee; and (4) whether the fee paid to us by the client will be increased above our normal fees in order to compensate the Promoter. In general, the advisory fees paid to us by clients referred by Promoters are not increased as a result of a referral. Other Compensation and Conflicts We have an incentive to recommend the product or account type that results in additional fees and revenues for us. We can recommend that you invest through different account type arrangements, such as through a brokerage account, an account directly held with the issuer of the investment (or its transfer agent), or an advisory account. Depending on factors such as the type and level of services you require as well as the frequency of trading in your account, one of these account types may be more cost-effective for you than the others. In addition, we receive miscellaneous account and service fees and other compensation (which are in addition to advisory fees) in connection with brokerage accounts or advisory accounts that we do not receive with a directly held account. We can also recommend that you invest in products that have higher up-front compensation along with ongoing trail payments. The availability of different products and account types incentivizes us and our IARs to recommend the product or account type that results in additional fees and revenues for us and your IAR even though another type of account may be more cost-effective for you. How We Addresses Certain Compensation Related Conflicts of Interest  Park Avenue discloses potential conflicts of interest to clients through documents such as this disclosure document, disclosures on the our website and other materials discussing the products and services offered.  Park Avenue credits 12b-1 fees and service fees from mutual funds, other than those associated with the Cash Management Sweep Program, and all FundVest® program fee payments to client accounts within Park Avenue Proprietary Programs.  Park Avenue IARs do not receive any portion of the payments Park Avenue receives under the agreement between Park Avenue and Pershing.  Park Avenue IARs do not receive any portion of the revenue received from mutual fund compensation arrangements, or mutual 12b-1 fees/service fees. Park Avenue does not include within these revenue sharing arrangements assets held within plans covered by Title I of ERISA, or a plan described in Section 4975(e)(1) of the Internal Revenue Code. Listed below are potential additional payments that Park Avenue may receive and the potential conflicts of interest they create. You should consider these potential conflicts of interest prior to investing in Park Avenue Proprietary Programs as the receipt of such payments provides a financial incentive for Park Avenue to recommend Park Avenue Proprietary Programs over Third-Party Advisory Programs. Pershing Additional Payments Through an agreement with Pershing, Park Avenue earns the following payments from Pershing. These payments are not applicable to clients of Third-Party Advisory programs. 1) Park Avenue receives a recurring fixed payment from Pershing annually on the total dollar value of legacy assets transferred from Park Avenue’s previous custodian. 2) Park Avenue receives payments from Pershing on the total amount of assets in client accounts placed on the Pershing custodial platform annually, and for asset growth year over year, which shall also include assets of Park Avenue’s affiliate, Guardian Wealth Partners. This payment excludes the total dollar value of legacy assets transferred from Park Avenue’s previous custodian. The receipt of such payments from Pershing provides a financial incentive for Park Avenue to recommend Park Avenue Proprietary Programs over Third-Party 35 PAS017976 (4/2026)  Advisory Programs. 3) Park Avenue receives an annual fixed technology allowance credit in the amount of $200,000 for reasonable and documentable costs incurred by Park Avenue in association with the implementation of technology solutions provided by Pershing, its affiliates and/or other third party providers. 4) Park Avenue receives an annual discretionary fee allowance credit in the amount of $200,000 for Pershing related fees Park Avenue would like to absorb through this credit. 5) Park Avenue earns interest payments on non-purpose loans that have interest rates above the Federal Funds Rate +1.75%. For example, if the interest rate on a non-purpose loan is 5% and the Federal Funds is 3%, Park Avenue will earn .25% of what a client pays (5%-4.5%). The receipt of such payments provides a financial incentive for Park Avenue to recommend and approve non-purpose loans. 6) Pershing agrees to share certain service fees received by Pershing from mutual funds that participate in the FundVest® program. The FundVest® program is an open architecture platform of mutual funds and no- transaction fee mutual funds offered by Pershing. These mutual funds are offered within Park Avenue Proprietary programs. The percentage of service fees Pershing shares with Park Avenue is based on the level of assets held by Park Avenue clients within the FundVest® program and generally ranges between 50- 55% of such services fees received by Pershing from participating mutual funds. Furthermore, Park Avenue addresses this conflict by crediting back all FundVest® program fee payments that it receives to clients invested in the Park Avenue Proprietary Programs. For additional details about Pershing’s mutual fund no-transaction- fee program, or a listing of funds that pay Pershing networking or omnibus fees, please refer to www.pershing.com/mutual_fund.htm. 7) Park Avenue has an incentive to have IARs recruited to us transfer their client accounts to Park Avenue because Pershing provides us with rebates for such account transfers. Pershing will reimburse us for out-of- pocket expenses associated with transfer and termination fees upon the successful onboarding of a newly hired IAR who transitions their client accounts from a financial services firm that does not clear through our clearing firm. Dreyfus Insured Deposits Program For the DIDV Bank Sweep each month, depository institutions pay a fee (“Deposit Fee”) equal to a percentage of the average daily deposit balance in your deposit account(s) at the banks participating in the program (“Program Banks”) to Park Avenue, Pershing, and a third-party administrator. The fee paid to Park Avenue will not exceed 600 basis points (6%) on an annualized basis over a rolling 12-month period. The combined fee paid to Park Avenue, Pershing, and the third-party administrator will not exceed 675 basis points (6.75%) on an annualized basis on the average daily balances held in these deposit accounts over a 12- month rolling period. Park Avenue has discretion in determining the size of the portion of the fee it receives. This directly negatively impacts the interest rate yield client deposits will receive. Park Avenue may waive any portion or the entirety of its share of the fee received from Program Banks. Your IAR will not receive any portion of the fees paid to Program Banks. The amount of fee received by Pershing, Park Avenue, and any other service provider, will affect the interest rate paid in your deposit account(s). Other than applicable fee imposed by Park Avenue on your account (including fees charged on your Pershing, LLC IRAs) there will be no additional charges, fees, or commissions imposed on your account with respect to the DIDV Bank Deposit Sweep. In order to illustrate the effect of the interest retained by Pershing, Park Avenue and the administrator of the program please consider the following example. If the DIDV sweep is earning a gross interest rate yield of 2% and Park Avenue, Pershing, and the administrator retains 1.65% for administration, then the client rate would be .35%. The receipt of this fee creates an incentive for Park Avenue to select DIDV as the default cash sweep vehicle for the clients who do not select a Money Market Sweep vehicle or have an account which is automatically defaulted to DIDV, as it will result in additional compensation to Park Avenue. In addition, Park Avenue’s discretionary authority in determining its share of the fee creates a conflict of interest due to Park Avenue’s receipt of the fee, which in turn, negatively impacts the interest rate yield client deposits will receive. As disclosed in the Cash Management Sweep Program section, the overflow Money Market Sweep products pay 36 PAS017976 (4/2026)  a distribution to Park Avenue which will not be credited to your account. Park Avenue IARs do not receive any portion of the distribution fee and therefore do not have a conflict in recommending a Cash Management Sweep product which pays a distribution. You are encouraged to speak to your IAR regarding the Cash Management Sweep Program vehicle used for your account. Payments from Mutual Funds Park Avenue receives Rule 12b-1 fees based on client investments in certain mutual funds. Rule 12b-1 fees are annual marketing or distribution fees on a mutual fund. The 12b-1 fee is considered an operational expense and, as such, is included in a fund's expense ratio. Except for 12b-1 fees generated by mutual funds associated with the Cash Management Sweep Program, Park Avenue Proprietary Program accounts will be rebated any 12b-1 fees generated by mutual fund investments within accounts. IAR Additional Compensation Paid by Park Avenue IARs who have a certain level of client assets invested in Park Avenue Proprietary Program accounts will, at the discretion of Park Avenue, receive additional compensation payments from Park Avenue. The receipt of these payments does not impact your Total Client Fee, however, it will incentivize these IARs to recommend a Park Avenue Proprietary Program account to you rather than a Third-Party Investment Advisory Program or other wealth management solution program that would not result in the payment of additional compensation to the IAR based on a level or total amount of client assets within such program. In addition, the calculation of these additional compensation payments will differ between Park Avenue Proprietary Programs resulting in differing amounts of payments to the IAR depending on the invested assets per Park Avenue Proprietary Program. This differential will incentivize IARs to recommend one Park Avenue Proprietary Program over another Park Avenue Proprietary Program. Therefore, the IARs and Park Avenue have a conflict of interest given their financial incentive to recommend that you participate in the Park Avenue Proprietary Programs and services that provide them with the highest rate and amount of overall compensation and benefits, and increase your assets under management in those programs, rather than other available programs and services that result in their receipt of lower or no additional compensation and benefits such as Third-Party Investment Advisory Programs for which IARs do not receive certain additional benefits. Further, Park Avenue and IARs have a conflict of interest as a result of their financial incentive to recommend the Park Avenue Proprietary Programs for which they can negotiate and receive the highest or relatively higher compensation. We address these conflicts of interest by disclosing them to you and requiring that there be a review of your account and transactions at account opening and periodically to determine whether they are appropriate and remain appropriate and in your best interest in light of your investment objectives, financial circumstances, and other characteristics. Guardian Club Credits Certain IARs may receive “Club Credits” for the recommendation of Park Avenue Proprietary Programs, Third- Party Investment Advisory Programs or Financial Planning/Consulting. These “Club Credits” are based upon sales production and count towards the attainment of various GLIC club memberships. Attainment of various club memberships may entitle IARs to attend GLIC-sponsored conferences. Park Avenue Securities VIP Program Certain IARs will qualify to receive service and financial support, as described in more detail below, based upon their overall sales production. The top 100 Park Avenue sales agents qualify for the VIP program. The qualifications to achieve VIP status are based upon total sales production or Gross Dealer Concession (“GDC”). GDC is the revenue generated via agent sales of brokerage products (i.e., stocks, bonds, mutual funds) and advisory services (i.e., Proprietary Programs, Third Party Investment Advisory Programs and Financial Planning/Consulting). The attainment of this VIP status entitles an IAR to receive a dedicated support person called a Relationship Manager, full or partial waiver of state registration fees and Park Avenue affiliation fees, and “Select Rewards Points.” The “Select Rewards Points” can be used to cover the cost of client account 37 PAS017976 (4/2026)  maintenance fees, termination fees, and/or service fees such as fed wire or overnight check fee. The decision to cover certain client costs is at the discretion of your Park Avenue IAR and not all clients will receive this benefit. Park Avenue Securities Pinnacle Council IARs are also eligible to qualify for a club award program called Pinnacle Council. To qualify for Pinnacle Council, an agent must be in the top 20 for total sales production based on the prior year GDC. The benefits of this club award include attendance at an annual recognition conference with paid travel accommodations (i.e., flight and hotel) and meals for the PAS Pinnacle Council qualifier and one guest. Park Avenue Securities Peak Council IARs are also eligible to qualify for a club award program called Peak Council. To qualify for Peak Council, an agent must be in the top 40 (21-40) for total sales production based on the prior year GDC. The benefits of this club award include attendance at an annual recognition conference with paid travel accommodations (i.e., flight and hotel) and meals for the PAS Peak Council qualifier and one guest. These programs could create a conflict of interest by an IAR recommending certain products in attempt to qualify for these additional clubs and awards. Transitional Assistance Program (TAP) Park Avenue may offer some recruits the opportunity to obtain bonuses and loans that are dependent upon meeting sales targets. These transition assistance loans may also be forgiven based on years of service with Park Avenue, or its affiliates, assets under management, the amount of production with Park Avenue or its affiliates or the number of clients brought over to Park Avenue. This practice creates a conflict of interest as it provides a financial incentive for an RR or IAR to recommend that a client engage Park Avenue for advisory or brokerage services, and to recommend additional products from Park Avenue or its affiliates. Moreover, some recruits may obtain “early asset bonuses” if they transfer certain percentages of assets to our Firm If an RR or IAR has received a transition loan, they are incentivized to encourage the transfer of your account to our Firm so that bonuses can be earned. This conflict is especially acute as your IAR approaches his or her milestone date. The Park Avenue Transition Team will work with an RR or IAR to ensure a successful transition by providing everything from a customized transition plan, tailored training, account opening and account transfer support. The level of support and service received is dependent upon the RR or IARs trailing twelve-month GDC with their prior firm. In addition, if the prior firm does not clear through Pershing, Pershing will reimburse transfer and termination fees up to $125.00 to each client account. Transition assistance presents a conflict of interest because of the incentive to affiliate with and recommend Park Avenue to clients. Private Client Group At their discretion, Park Avenue IARs may identify certain clients based on the amount of assets in either or both the Park Avenue Proprietary Investment Advisory Programs or Park Avenue broker-dealer accounts for participation in the Private Client Group program. Private Client Group clients will receive certain benefits which are not available to clients who are not selected for the program. These benefits include but are not limited to access to educational and exclusive private events, discount programs unrelated to services or products offered by Park Avenue as a broker- dealer/registered investment adviser, and specialized Park Avenue services. Many of the services offered by the Private Client Group are also available to clients who are not in the program. Park Avenue IARs have an incentive to select certain clients who have more assets with Park Avenue over other 38 PAS017976 (4/2026)  clients who do not have as many assets with Park Avenue. This creates a conflict of interest for Park Avenue and its IARs and incentives clients to maintain a certain level of assets at Park Avenue as well as increase their assets in attempt to qualify for these benefits and services which would generate higher advisory or broker-dealer transactional fees. Not all clients who meet the asset thresholds for membership will be offered invitations to the Private Client Group as invitation is at discretion of the Park Avenue IAR. Payments Related to Park Avenue Educational/Practice Management Conferences iCapital *First Trust Inland Capital Certain product sponsors and vendors pay Park Avenue a fee ranging from $40,000 to $172,000 to participate in Park Avenue sponsored educational/practice management conferences for Park Avenue IARs. In 2026, Park Avenue anticipates it will receive fees from the following:  BlackRock  State Street Global Advisors  Clark Capital  City National Rochdale  Halo   Capital Group/American Funds   Fidelity   Allianz  BNY Mellon  Brighthouse  Jackson  Lincoln  Nationwide  Prudential  Transamerica *First trust will pay Park Avenue the greater of $100,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. See section Revenue Sharing Payments for a description of revenue sharing. Other Compensation (Park Avenue Proprietary & Third-Party Advisory Programs) Third-Party Advisor Payment Arrangements Park Avenue receives payments from SEI, Orion, and AssetMark as compensation for marketing and administrative services as follows:  SEI pays Park Avenue a flat annual fee. The fee for 2026 is $548,000.  Orion pays Park Avenue a flat annual fee for training and educating Park Avenue IARs. The fee for 2026 is $320,000.  AssetMark pays Park Avenue a flat annual fee. The fee for 2026 is $1,000,000. o OBS, who is owned by AssetMark, pays Park Avenue a flat annual fee. The fee for 2026 is $88,000. You should also be aware that marketing, administrative or educational activities paid for with these payments by these sponsors and vendors lead to greater exposure of their products and services with Park Avenue IARs. Therefore, these payments create an incentive, or lead to a greater likelihood, for Park Avenue or its IARs to recommend a product of these sponsors and vendors over the products or services of a firm which does not pay Park Avenue a fee. Revenue Sharing Payments Certain product sponsors pay Park Avenue additional compensation in the form of revenue sharing. These 39 PAS017976 (4/2026)  revenue sharing payments are calculated as an annual percentage of the amount of assets held by Park Avenue customers within sponsor products. Park Avenue may receive compensation of up to 25 basis points (“bps”) on these assets. For example, if you hold a $10,000 position with a sponsor that provides Park Avenue a 25bps payment, Park Avenue will receive $25 from that sponsor. **First Trust The following product sponsors provide Park Avenue revenue sharing payments:  Open VC., Inc.  CION Ares Management  Hamilton Lane  The Carlyle Group  Janus Henderson  HPS  Pimco (Alternative Funds Only)   Allianz  Brighthouse Life Ins.  Equitable  Jackson National  Lincoln Financial  Nationwide  Prudential  Transamerica ***Redbrick  *HPS will pay Park Avenue the greater of $200,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. **First trust will pay Park Avenue the greater of $100,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. ***Redbrick will pay Park Avenue 25 basis points on new sales rather than assets held by Park Avenue customers when Park Avenue customers purchase Redbrick products. Receipt of revenue sharing payments creates a conflict of interest as Park Avenue is incentivized to sell you or recommend you hold investments that provide Park Avenue with such payments rather than investments that do not. In addition, as the payments differ by product sponsor, Park Avenue is incentivized to sell you or recommend you hold investments that provide a higher revenue sharing payment rate than investments that pay Park Avenue a lower revenue sharing payment rate. This conflict of interest is mitigated by the fact that IARs do not receive this firm-paid additional revenue sharing compensation from the product sponsors that provide Park Avenue these revenue sharing payments, and that the firm maintains reasonable policies and procedures to help ensure recommendations are in your best interest. Third Party Payments For some investments you purchase based on our recommendation, we receive payments from a third-party that are in addition to the advisory fee payments described in this document. For example, certain mutual fund issuers make ongoing payments based on invested assets (and not just new investments), such as 12b-1 fees, shareholder servicing fees or trail compensation. These third-party payments are described in further detail in the prospectus or offering materials for the investment, which will be made available to you in connection with any purchase. Third-party payments incentivize us and your IAR to sell you or recommend you hold investments that bring about such payments rather than investments that do not or result in comparatively lower payments. To mitigate this conflict and as discussed more within this Brochure, Park Avenue credits back to clients invested in Park Avenue Proprietary Program Accounts mutual fund 12b-1 and other service fees it would otherwise receive from mutual fund products, except those generated by the Cash Management Sweep Program. 40 PAS017976 (4/2026)  Other IAR Conflicts The individual office managers/supervisors are paid based on the performance of the branches or regions they supervise. Our managers and supervisors oversee the sales and marketing activities of our Firm. The compensation of our managers and supervisors is tied to the production levels of branches or regions over which they have managerial or supervisory responsibility. The tying of managers’ and supervisors’ compensation to the production of the branches or regions they supervise incentivizes them to spend more time on increasing production levels in a given branch or region than on their supervisory responsibilities. Some of our IARs receive additional training and support from certain Strategist and Third Party Investment Advisers (“Managers”). Certain Managers and their affiliates provide some of our IARs or their branches with more training and administrative support services than others. If your IAR receives this additional training and support, his or her use of these Managers’ higher level of training and administrative support services incentivizes your IAR to recommend Managers that provide such training and services over issuers that do not. Some of our IARs receive compensation in the form of non-cash compensation or other gifts from vendors or product sponsors to assist with, and defray the expenses associated with educational seminars and client events held by the IAR or a branch office. At times, the amount of compensation provided to a IAR or branch may be dependent on volume of business that individual or branch has attained. IARs may also receive business entertainment from vendors or product sponsors with whom they interact or are authorized to do business. Entertainment engagement may be based on the amount of business placed with the vendors or product sponsors and may incentivize the IAR to place business with that vendor or product sponsor. IARs who are also representatives of the Firm’s parent company, Guardian Life Insurance Company of America, receive employee benefits (i.e., health and pension benefits) that are subsidized by Guardian if the IAR reaches certain sales targets. This subsidization program creates a conflict of interest as it encourages more sales that result in your Financial Professional meeting these sales targets to obtain additional subsidies. Some IARs have outside business activities that compete for their time or may influence their recommendations. If your IAR engages in any outside business activities, these activities can incentivize your IAR to spend more time on the outside business activity rather than his or her advisory relationship with you. In addition, if the outside business activity provides your IAR a higher rate of compensation, your IAR can be incentivized to recommend the outside business activity rather than a brokerage or advisory service offered by Park Avenue. You may research any outside business activities your IAR may have on FINRA’s BrokerCheck website at https://brokercheck.finra.org/. Certain IARs may enter into loans or other lending arrangements in order to expand their own business or purchase other books of business. When IARs enter into these lending arrangements the debt incurred can otherwise impact the IAR’s overall compensation received throughout any particular time-period. The amount of debt incurred and these lending scenarios could influence the manner in which the IAR attempts to earn additional transactional-based commissions when acting in their capacity as a registered representative of Park Avenue (commissions paid for the recommendation and sale of securities products) or investment advisory fees when acting in their capacity as an IAR (investment advisory fees for the ongoing advice provided to you) in order to meet their own personal debt obligations which may also indirectly influence their advice and recommendations made to you as their client. Financial Information Park Avenue does not have any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients. 41 PAS017976 (4/2026) 

Park Avenue Securities LLC 10 Hudson Yards, New York, NY 10001 Phone: 888-600-4667 Web: https://www.parkavenuesecurities.com/ April 23, 2026 Park Avenue SMA Select℠ and UMA Select℠, Park Avenue Strategist Select℠ and Strategist Select Plus℠, Quantitative Innovations℠ and Foundations℠ Wrap Fee Program Brochure This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of Park Avenue Securities LLC (“PAS”). If you have any questions about the contents of this Brochure or would like to obtain a free copy of this Brochure, please contact us at (888) 600-4667 or visit https://www.parkavenuesecurities.com/. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about PAS is also available on the SEC’s website at https://adviserinfo.sec.gov/. PAS is a registered investment adviser and conducts its business under marketing name Park Avenue® Wealth Management. Registration as an investment adviser does not imply a certain level of skill or training PAS017975 (4/26)  2. Material Changes Park Avenue Securities, LLC. (“PAS”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”) conducting business under marketing name Park Avenue® Wealth Management (“Park Avenue”, the “Firm”, “we”, “our” or “us”). Pursuant to SEC rules, this item summarizes the specific material changes, if any, that have been made to this Form ADV Strategist Wrap Fee Program disclosure brochure since the last annual update of this Brochure on March 19, 2025. When required or appropriate, we will also provide clients interim summary updates of material changes to this Brochure. You are strongly encouraged to read this Brochure in detail and contact your investment adviser representative (“IAR”) with any questions. Clients may ask for a copy of our current Brochure, which includes all material changes since the previous Brochure, or a summary of material changes to the previous Brochure at any time, without charge, by contacting us at (888) 600-4667 or via Contact Us link at https://www.parkavenuesecurities.com/. Clients may also obtain a copy of this Brochure or a copy of any other of our Form ADV disclosure brochures by accessing and downloading them from our website at https://www.parkavenuesecurities.com/ under Form ADV Brochures. The following is a summary of material changes to this Brochure since the last annual update on March 19, 2025. April 23, 2026 Update Park Avenue Securities LLC begins operating under the marketing name Park Avenue® Wealth Management. Our legal name remains Park Avenue Securities LLC, and we will continue to be the registered investment adviser providing your advisory services. March 20, 2026 Update Item 9. Additional Information has been amended as follows:  Disclosure and descriptions of IAR conflicts related to outside business activities and IAR loan/lending arrangements are provided under section Other IAR Conflicts. December 31, 2025 Update Item 4. Services, Fees and Compensation has been amended as follows:  FoundationsSM and Quantitative InnovationsSM programs to be closed to new investors effective January 31, 2026. Item 6. Portfolio Manager Selection and Evaluation  Description of PAS Foundational Model Portfolios, where PAS’s capacity is as Investment Manager offered as asset allocation targets or sleeves in fulfilling UMA Select asset allocation models. Item 9. Additional Information has been amended as follows:  Additional information has been added related to new additional compensation paid by PAS to certain IARs.  Additional information has been added regarding third-party payments in the form of revenue sharing being paid  to PAS. Information has been added related to PAS’s parent company, The Guardian Life Insurance Company of America (“GLIC”), obtaining warrants from Hamilton Lane and Hamilton Lane’s management of a portfolio of GLIC’s general account. PAS017975 (4/2026) 2  March 19, 2025 Update Item 4. Services, Fees and Compensation has been amended as follows:  Additional disclosures and descriptions related to Householding for Annual Platform Fees.  Additional disclosures and descriptions related to program fees paid to PAS for the PAS Proprietary Programs and the Cash Management Sweep Program.  Additional disclosures and descriptions related to trading away practices.  Additional disclosures and descriptions of available accounts and relationships with PAS’ lending services, and PAS’ capacity as broker-dealer of record on all PAS Proprietary Program accounts. Item 6. Portfolio Manager Selection and Evaluation  Additional disclosures and descriptions of PAS’s order aggregation practices. Item 9. Additional Information  Additional disclosure and descriptions related to client referrals and other compensation.  Additional language regarding PAS being deemed to have custody of certain client funds. PAS017975 (4/2026) 3  3. Table of Contents Section: Page: 1. Cover Page ............................................................................................................................................................. 1 2. Material Changes .................................................................................................................................................... 2 3. Table of Contents .................................................................................................................................................... 4 4. Services, Fees and Compensation ......................................................................................................................... 5 5. Account Requirements and Types of Clients ........................................................................................................ 30 6. Portfolio Manager Selection and Evaluation ......................................................................................................... 30 7. Client Information Provided to Portfolio Managers ................................................................................................ 37 8. Client Contact with Portfolio Managers ................................................................................................................. 37 9. Additional Information............................................................................................................................................ 37 PAS017975 (4/2026) 4  4. Services, Fees and Compensation Services Park Avenue Securities LLC (“PAS”), doing business under the marketing name Park Avenue® Wealth Management (“Park Avenue”, the “Firm”, “we”, “our” or “us”), is a dually registered broker-dealer and investment adviser that sponsors the following wrap fee programs: Park Avenue Separately Managed Account Select℠ (“SMA Select”), Park Avenue Unified Managed Account Select℠ (“UMA Select”), Park Avenue Strategist Select℠ (“Strategist Select”), Park Avenue Strategist Select Plus℠ (“Strategist Select Plus”), Foundations℠ and Quantitative Innovations℠, (together the “Programs”). In addition, we sponsor the Park Avenue Signature Portfolio℠ wrap fee program and the VestWise™ wrap fee program, which is an automated or digital (i.e., internet/web-based) investment advisory solution. Information about Park Avenue Signature Portfolio℠ and VestWise™ is available within separate brochures. You can request a copy of those brochures by asking your Park Avenue Investment Advisor Representative (“IAR”) or by calling our Home Office directly at (888) 600-4667. Wrap fee programs bundle together several service providers: an investment adviser, a broker-dealer, a clearing firm, and a custodian, and offer most of these services for a single Total Client Fee. There are no individual ticket charges assessed to the client for trades within a wrap fee program. Some clients prefer to have the various services "packaged" together within a wrap fee program; others prefer to select their own providers for the various services needed to manage their investment portfolios. Similarly, some clients prefer a fee structure that converts trading costs into an asset-based fee calculated on the same basis as the Total Client Fee; others prefer trading costs to be assessed on a per trade basis. Depending on a number of factors, such as the number of transactions, number of shares, and nature of the securities transactions in an advisory account, the overall fees and charges borne by the client over time could be more or less than what these fees and charges would be if the same services were provided on a separate basis. Certain of our IARs market their practices using marketing names that differ from the name under which we primarily conduct our advisory business. In these circumstances, clients should be aware that all investment advisory services described herein are provided by IARs through and on our behalf, not the marketing names that IARs use to market their practices. Understanding your Relationship with Park Avenue We are subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and as a registered investment adviser, we, along with our IARs, have a fiduciary duty to you. This generally means that Park Avenue and our IARs will act in your best interest when providing investment advice under the Advisers Act and will disclose or avoid material conflicts of interest. Throughout the various sections of this Brochure we have identified conflicts of interest within specific sections that are otherwise describing the services we provide or the fees or compensation we or our IARs receive. Within the advisory programs described in this Brochure, we provide services as an investment adviser under the Advisers Act. In providing investment advice, your Park Avenue IAR can select from different products and programs. This includes advisory programs described in this brochure and other advisory programs described in our Firm Brochure. The majority of our IARs may act in their capacity as a registered representative of Park Avenue providing securities recommendations in a Park Avenue 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 Park Avenue. There are IARs associated with us who are not licensed as a registered representative. These individuals may not provide securities recommendations in Park Avenue brokerage accounts and will only offer investment advisory services described within this brochure and other advisory programs described in our Firm and other Wrap Fee Brochures. For more information about the IAR providing advisory services, you should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time you engage the IAR. 5 PAS017975 (4/2026)  You should discuss with your IAR the benefits and costs associated with the different advisory programs available at Park Avenue 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 IARs ongoing obligations when acting as an IAR versus a registered representative. Our IARs assist clients in pursuing their financial goals by providing personalized financial planning services and investment solutions. Any information you receive from us or our IARs relating to tax considerations affecting your financial arrangements or transactions is not intended to be tax advice and you should not rely upon it as tax advice. Neither we nor our IARs provide tax, legal, or accounting advice. AVAILABLE ACCOUNTS AND RELATIONSHIP TYPES When you choose to purchase products and services through us and work with our financial professionals, you have the option of investing through a transaction-based account, such as a brokerage account, a fee-based investment advisory account, or both. It is important for you to understand the services you will receive, the fees, costs, and expenses you will pay, and conflicts of interest of ours and of your financial professional in connection with each of these different types of accounts and relationships with us and your financial professional. The services, fees, costs, expenses, and conflicts of interest are summarized below and described in much greater detail in our Form CRS, Regulation Best Interest (“Reg BI”) Disclosure Document and Forms ADV, Part 2A, as applicable, which are available on our website at https://www.parkavenuesecurities.com/. In addition, if considering investing into a Third-Party Investment Advisory Program, you are encouraged to review the Third- Party Investment Adviser’s Form ADV Part 2 which will contain important information such as the program fees and expenses and any conflicts of interest of the Third-Party Investment Adviser which may exist. Transaction-Based Account, Such as a Brokerage Account As a broker-dealer, we offer 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, we may offer general, impersonal investment advice in the form of publications and other services. We will not be deemed to be providing investment advisory services unless it has entered into a contract with the client for that purpose. With a transaction-based account, such as a brokerage account, you will pay commissions and other charges (such as sales loads on mutual funds and other securities and investment products) at the time of each transaction, such as the purchase or sale of a mutual fund, stock, bond, option, Alternative Investments (“AI”), or other security or investment product. These commissions and other charges are Park Avenue’s and your Park Avenue financial professional’s primary source of compensation for the transaction-based advice your Park Avenue financial professional provides when recommending such transactions. When serving as your broker, your Park Avenue financial professional can make recommendations and provide guidance to you in selecting securities, other investment products, and services. Your Park Avenue financial professional may also provide investment education and research services, which are incidental to the brokerage services Park Avenue provides. A transaction-based account can potentially be more appropriate for you than a fee-based investment advisory account if you do not want ongoing investment advice on assets held in your account, or ongoing management of your account, and instead want only periodic or on-demand advice and recommendations specific to the purchase and sale of securities and other investment products. Additionally, this type of account can potentially result in lower costs for you if you expect to trade on an infrequent or occasional basis. When Park Avenue and your Park Avenue financial professional make securities and investment strategy recommendations to you as broker-dealer for your transaction-based account, such as a brokerage account, Park Avenue and your Park Avenue financial professional will be acting in their broker-dealer capacities for such account and are required to act in your best interest, without placing their financial or other interests ahead of your interests. You should be aware that Park Avenue and Park Avenue financial professionals are subject to various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your 6 PAS017975 (4/2026)  transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles Park Avenue and your Park Avenue financial professional plays in a transaction, Park Avenue’s and your Park Avenue financial professional’s compensation arrangements, and Park Avenue’s financial and other arrangements with custodians, clearing firms, and other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in our Form CRS and Reg BI Disclosure Document, as well in the other important client disclosures available on our website, https://www.parkavenuesecurities.com/. An advisory account may not be appropriate for low trade volume activity, if you have a long term buy-and-hold investment strategy, or if you direct Park Avenue 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 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. For additional information on our broker-dealer services and transaction-based account offerings, please see our Form CRS and Reg BI Disclosure Document, which are available on our website at www.parkavenuesecurities.com. Our Form CRS and Reg BI Disclosure Document may also be requested by contacting our Home Office at (888) 600-4667 or via the Contact Us link at https://www.parkavenuesecurities.com/. For detailed information regarding the commissions, trading/execution fees, and brokerage service charges that Park Avenue establishes, controls, and charges clients when serving as a broker-dealer of record for transaction-based accounts held with Pershing, LLC (“Pershing”) as our clearing firm and custodian, please see our Fee and Commission Schedule for Accounts with Pershing (the “Client Fee Schedule”) which is provided to you at account opening, will change over time, and can be found on our website at www.parkavenuesecurities. Before consenting to any broker-dealer relationship with us or a our financial professionals, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation we and our financial professionals will receive, and Park Avenue’s and our financial professionals’ conflicts of interest. After reviewing these disclosures, please address any questions you may have with your Park Avenue financial professional. Fee-Based Investment Advisory Account A fee-based investment advisory account, sometimes called a “managed account,” can potentially be more appropriate for you than a transaction-based account, such as a brokerage account, if you want ongoing investment advice and management of your account. Park Avenue offers a number of different investment advisory account programs and acts as the sponsor and broker-dealer in connection with some of those different investment advisory account programs. With a fee-based investment advisory account, you will pay an ongoing investment advisory fee based on the value of the assets held in your account in exchange for ongoing investment advice and management of your account and related services. This asset-based fee is Park Avenue’s and your IAR’s primary source of compensation related to the servicing of investment advisory accounts. 7 PAS017975 (4/2026)  The Park Avenue investment advisory accounts that are currently offered to new clients charge an “all-inclusive’ bundled fee based on the value of the assets in your account. This bundled fee usually includes a portfolio management fee, transaction, trading, and execution costs, and investment advice and is sometimes referred to as a “wrap fee.” However, this bundled fee does not include costs associated with transactions that are executed at broker-dealers other than the one at which your account is held. Transactions executed at broker-dealers other than the one at which your account is held are sometimes called “step-out” trades and are described further below. Fees vary depending on which Park Avenue advisory program accounts you use. Investment advisory account fees are billed either in arrears (i.e., following the completion of the applicable billing period) or in advance (i.e., at the beginning of the applicable billing period) depending on the advisory program you select, and your billing methodology (i.e., in arrears or in advance) will be specified, your Statement of Investment Selection (“SIS”) and Terms and Conditions (for Park Avenue Proprietary Program Accounts, other than VestWise), the VestWise Investment Advisory Agreement, or the account opening documentation of the Third-Party Investment Advisor Program Accounts (collectively, the “Client Agreement”), or other account opening documentation. Fee charges are specified in your Client Agreement or other account-opening documentation, based on the assets held within your account for services including, but not limited to, ongoing investment advice, investment selection and recommendations, asset allocation, execution of transactions (depending on the program you are in), custody of securities, and account reporting services. Please see your Client Agreement and other account-opening documentation for additional information. After reviewing these documents, please address any questions you have with your IAR. For all Park Avenue Proprietary Program Accounts other than VestWise, our advisory fees are generally negotiable. The Park Avenue Portfolio Select Program charges separately for asset management services, ongoing investment advice, and transaction costs. In this Program, you will be charged for any transaction, trading, and execution fees, costs, and expenses that applicable to trades and other transaction occurring within your account, as described in your account-opening documentation, in addition to your asset-based advisory fees (unless your IAR has agreed to incur such charges and expenses specific to your Park Avenue Portfolio Select Program account). Applicable transaction, trading, execution, and other fees, costs, and expenses are described in detail in the applicable Client Agreement, SIS, transaction, trading, execution, and brokerage service fee schedules, other account-opening documentation, and Form ADV, Part 2A. When Park Avenue and your Park Avenue financial professional serve as investment adviser for your fee-based account, Park Avenue and your Park Avenue financial professional will be acting in their investment advisory capacities for such account and are fiduciaries, without placing their financial or other interests ahead of your interests. Additionally, when Park Avenue and your Park Avenue financial professional provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA, Park Avenue and your Park Avenue financial professional are fiduciaries within the meaning of Title I of ERISA and the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”), as applicable, which are laws governing retirement accounts. You should be aware that Park Avenue and Park Avenue financial professionals are subject to various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles Park Avenue and your Park Avenue financial professional play in a transaction, Park Avenue’s and your Park Avenue financial professional’s compensation arrangements, and Park Avenue’s financial and other arrangements with custodians, clearing firms, and other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in our Form CRS and Reg BI Disclosure Document, as well as in the other important client disclosures available on our website, www.parkavenuesecurities.com. 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. 8 PAS017975 (4/2026)  You should periodically discuss the various investment advisory program options with your IAR. Park Avenue IARs are compensated for servicing your Park Avenue investment advisory account 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 Park Avenue, which has a lower fee structure. This compensation paid to Park Avenue and Park Avenue’s IARs for Park Avenue Programs may be more than what the IAR would receive if you pay separately for investment advice, brokerage, and other services. Under Park Avenue Proprietary Programs, clients must establish an account through Park Avenue with Pershing LLC (“Pershing”). Pershing acts as the clearing firm and custodian for client assets within Park Avenue Proprietary Programs. Accordingly, all trading activity under Park Avenue 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. In addition, for all Park Avenue Proprietary Programs, Park Avenue is serving as the broker-dealer of record. By signing the SIS and Client Agreement, client authorizes and directs Park Avenue and the IAR to trade through Pershing, the applicable custodian and clearing firm. When Park Avenue acts in the capacity of the broker-dealer on your account, it receives additional compensation which it would not otherwise receive if another firm acted in the capacity of the broker-dealer on your account. Park Avenue’s receipt of additional compensation in its capacity as the broker-dealer on your account creates a conflict of interest for Park Avenue because Park Avenue has a financial incentive to, among other things, recommend itself as the broker-dealer of record and Pershing as the custodian for your account (rather than other available broker-dealers and custodians). For additional details regarding the conflicts of interest that Park Avenue has in connection with the various revenue streams it receives as your broker-dealer, please see Item 9, Additional Information, below. Park Avenue addresses these conflicts of interest by disclosing them to you; providing you with the Client Fee Schedule, which discloses the amount and rate of transaction, trading, execution, and brokerage services charges you will incur for your Park Avenue Proprietary Program accounts for which Park Avenue serves as the broker-dealer of record, the services you receive, and the securities and other investment products you purchase, hold, and sell in your account; not sharing any transaction, trading, execution, or brokerage service charges with the IARs that recommend products, share classes, transactions, strategies, or services for your account; and by requiring that there be a review of your account and transactions at account opening and periodically to determine whether they are suitable and in your best interest in light of your investment objectives, financial circumstances, and other characteristics. Pershing handles the delivery and receipt of securities purchased or sold on behalf of Park Avenue 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. For additional information on our investment advisory programs and services, please see our Form CRS and Forms ADV, Part 2A, which are available on our website at www.parkavenuesecurities.com, and through the SEC’s website at www.adviserinfo.sec.gov. Our Form CRS and Forms ADV, Part 2A may also be requested by contacting us at (888) 600-4667. Before consenting to any investment advisory relationship with us or our financial professionals, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation we and our financial professionals will receive, and conflicts of interest of ours and of our financial professionals. After reviewing these disclosures, please address any questions you may have with your financial professional. Rollovers and Fiduciary Acknowledgement When Park Avenue and its IARs provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA and 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, Park Avenue and its IARs are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not necessarily mean Park Avenue and its IARs are acting as fiduciaries for purposes of other applicable laws. This acknowledgement of fiduciary status does 9 PAS017975 (4/2026)  not confer contractual rights or obligations on you, Park Avenue, or the IARs. With respect to rollover transactions, certain portions of this 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 Park Avenue and its IARs, (ii) the fiduciary acknowledgement above, and (iii) the description of the material conflicts of interest under which Park Avenue and your IARs are operating. Rollovers Park Avenue and your IAR get paid when you engage in a rollover transaction. Park Avenue can recommend that you rollover assets from your workplace retirement plan or from an existing IRA into an IRA account with Park Avenue. When you engage in a rollover to an IRA, Park Avenue 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 Park Avenue and your IAR to make a rollover recommendation. Transferring an Existing Account to Park Avenue 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, the previously described charges. 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 Park Avenue 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. Investing in a Park Avenue Program To invest in a Park Avenue Program, you must establish an account through Park Avenue with Pershing, which clears trades and acts as custodian for your assets. Accordingly, all trading activity in connection with the Park Avenue Programs will be processed through your 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 your behalf, receives, and distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender offers, and redemptions. Pershing sends statements of all activity in clients’ accounts no less than quarterly. If you choose to invest your assets in a Program account, you will sign a client agreement, which consists of the Statement of Investment Selection and Terms and Conditions (the “Client Agreement”). The Client Agreement and other account opening documentation will detail all of the important terms and conditions pertaining to your account, including the management fee and termination provisions. You are encouraged to read all of the terms of the Client Agreement and other account opening documentation. Pursuant to the Client Agreement, you direct Park Avenue to invest your funds in the account in accordance with your Statement of Investment Selection and the strategy chosen by you. It should be noted that the securities utilized to implement the strategic asset allocation policy will depend on the specific advisory program selected by the client and their IAR. Park Avenue believes investors are best served by constructing well diversified portfolios that are consistent with their risk tolerance and investment objectives. A Park Avenue IAR will assist you in selecting the Program as well as 10 PAS017975 (4/2026)  the Investment Manager/Strategist suited to your investment objectives and Investor Risk Rating, as reflected by your client questionnaire and Statement of Investment Selection. The Investor Risk Rating is calculated based upon your answers to the client questionnaire (“Client Questionnaire”) and is used to help map to a risk-based strategic asset allocation strategy. The base strategic asset allocation strategy will be outlined within your Statement of Investment Selection. The base strategic asset allocation policies are designed around exposures to broad asset classes such as stocks and bonds. 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. Additional information about the Investor Risk Rating and its impact on your IAR’s recommendations is below. You may impose any reasonable restrictions or modify any existing restrictions in a reasonable manner on the management of your accounts. Your information is not shared with any mutual fund or ETF sponsors. Your Investor Risk Rating is the level of risk you are willing to take with your account. During the account opening process, your IAR will use the Investor Risk Rating to recommend an asset allocation model that will have a risk level up to but not exceeding your Investor Risk Ratings. There is no guarantee that the objectives of any portfolio will be realized. In addition, a client may lose money by having their assets managed in accordance with any portfolio or strategy offered through the Programs. The 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 and to determine whether you wish to impose any reasonable restrictions on the management of your account. Additionally, you are required to notify Park Avenue or your IAR of any material changes to your financial situation or investment objectives. For all Park Avenue Proprietary Programs, 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 Park Avenue Proprietary Program account and as you update or amend it from time to time. To assist you in managing your account assets, Park Avenue will provide you with:  Periodic performance reports showing the performance of your Park Avenue 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 Park Avenue Proprietary Program account; however, your IAR, Investment Manager, and/or Strategist 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. Alternatively, for consolidated reporting purposes and convenience, certain securities may be held in your Park Avenue Proprietary Program account and classified as Unsupervised Assets. These may include securities transferred into your Park Avenue 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. In these cases, Park Avenue and its IARs will not serve in an investment advisory capacity with respect Unsupervised Assets, Park Avenue and its IARs will not provide investment advisory services or oversight of the Unsupervised Assets, and the Unsupervised Assets will be excluded from the calculation of the Park Avenue Proprietary Program account’s advisory fee and performance and excluded from periodic performance reports for your Park Avenue Proprietary Program account. While Unsupervised Assets are not included in the calculation of Park Avenue Proprietary Program account advisory fees, client’s Unsupervised Assets are subject to all other applicable fees as described in the transaction, trading, execution, and brokerage service fee schedules and other documentation applicable to their Park Avenue Proprietary Program account, including but not limited to, annual custody and valuation fees. Your account can be managed in a tax-sensitive manner; however, neither Park Avenue 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. Wrap fee program portfolio managers may employ “trading away” practices, in which they use a broker other than 11 PAS017975 (4/2026)  Park Avenue 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. Envestnet Asset Management, Inc. Park Avenue has contracted with Envestnet Asset Management, Inc. (“Envestnet”), an SEC registered investment adviser, to provide a technology structure for Park Avenue and its clients to efficiently connect with third-party asset managers and Park Avenue, as an asset manager (not considered a “third-party asset manager”) in the Strategist Select Plus and UMA Select Programs, each referred to as either an Investment Managers or Strategists, to act in some Programs as co-adviser to clients, and to provide various administrative services and investment management services to clients electing Park Avenue Proprietary Programs. In Programs offered with third-party Investment Managers or Strategists, Envestnet provides ongoing investment management services on a discretionary basis administering the Investment Manager or Strategist-developed model portfolios and taking directions from the third- party 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 Investment Manager), mutual funds, and Exchange-Traded Funds (“ETFs”) that may be available within certain of these 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. Program Descriptions Park Avenue Separately Managed Account Select℠ (SMA Select) The SMA Select Program is a discretionary investment advisory program sponsored by Park Avenue that provides clients with access to the investment strategies of third-party Investment Managers that have been retained by Envestnet. Park Avenue will not act as Investment Manager within the SMA Select Program. 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 providing overlay management of the investment models through the performance of administrative and trading services. Based upon your investment objectives and Investor Risk Rating, your IAR will recommend Investment Manager(s) to fulfill the risk/return strategy. An SMA Select Program account will contain one Investment Managers’ strategies held in a separate custodial account. By executing a Statement of Investment Selection (“SIS”), you grant Envestnet the authority to buy and sell securities and investments for the SMA Select account and to perform rebalancing or other such discretionary authorities you agree upon. Envestnet shall be authorized to delegate the investment discretion described above to the Investment Manager who may trade the securities themselves and not through Envestnet. Each Investment Manager is responsible for selecting the securities for investment in the investment strategy of such Investment Manager, including the share class if the investment strategy contains mutual funds. You also grant Park Avenue authority to open multiple custodial accounts based upon the initial account application for each Investment Manager strategy you select. You can impose any reasonable restrictions on the management of your account. Envestnet and/or Park Avenue may remove an Investment Manager from the list of approved Investment Managers at its discretion, at which point you shall be notified and asked to move those account assets to a similar but approved Investment Manager. Park Avenue may, at its sole discretion and upon prior written notice, convert your SMA Select Program account assets or a portion of those assets to a brokerage account, under the same name and title, if your SMA Select Program account assets remain with an unapproved Investment Manager. Park Avenue Unified Managed Account Select℠ (UMA Select) The UMA Select Program is a discretionary investment advisory program sponsored by Park Avenue that provides 12 PAS017975 (4/2026)  clients with access to the investment strategies of both third-party Investment Managers and Park Avenue as an Investment Manager. Third-party Investment Managers are retained by Envestnet. A UMA Select Program account will contain one or multiple Investment Manager portfolio strategies, may also contain individual securities such as mutual funds and/or ETFs to fill model portfolio allocations, and will be held in one single custodial account. 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 a variety of investment vehicles to fulfill your asset allocation targets based on the risk/return strategy. You will complete the UMA Select Program account by selecting which Investment Manager strategies and/or individual security(s) to populate within each asset allocation sleeve. Third-Party Investment Managers in UMA Select Envestnet acts as the overlay manager and administers the implementation of the model portfolios provided and maintained by the individual third-party Investment Manager(s) selected (an “Investment Model”) by you. Your IAR can 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 SIS, 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 third- party Investment Manager. Park Avenue as Investment Manager in UMA Select When elected, Park Avenue, in its capacity as Investment Manager, will manage and administer the Investment Model(s). Your IAR can 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 SIS, you grant Park Avenue the authority to buy and sell securities and investments for the account pursuant to the agreed upon Investment Model and perform rebalancing or other such discretionary authorities you agree upon. To learn more about Park Avenue’s investment strategy in its capacity as an Investment Manager within the UMA Select Program, please see section 6, Portfolio Manager Selection and Evaluation. Park Avenue has an ongoing responsibility to advise you regarding the appropriateness of the Investment Model(s) and the Investment Manager you selected by taking into account your objectives, risk tolerance and assets. The Investment Manager is responsible for selecting the securities for client investment, including the share class if the investment is mutual funds. Your IAR may provide investment advice to you on a non-discretionary basis only, subject to your approval, in a manner consistent with your investment objectives. You have the ability to impose any reasonable restrictions on the management of your account by requesting them through the SIS. Clients may impose new, or change any existing, investment restrictions at any time by contacting their IAR. There are no transaction fees charged to you in the UMA Select Program. Envestnet and/or Park Avenue may remove an Investment Manager from the list of approved Investment Managers at its discretion at which point you shall be notified and asked to move those account assets to a similar but approved Investment Manager. Park Avenue may, at its sole discretion and upon prior written notice, convert your UMA Select Program account assets or a portion of those assets to a brokerage account, under the same name and title, if your UMA Select Program Account assets remain with an unapproved Investment Manager. Park Avenue Strategist Select℠ and Park Avenue Strategist Select Plus℠ The Park Avenue Strategist Select and Park Avenue Strategist Select Plus programs are discretionary investment 13 PAS017975 (4/2026)  advisory programs sponsored by Park Avenue. The Strategist Select and Strategist Select Plus programs provide clients with access to third-party investment advisory firms referred to as Strategists that have been retained by Envestnet. Within the Strategist Select Plus program, clients are also provided access to Park Avenue, who is not retained by Envestnet or a third-party, as the investment advisory firm or Strategist. These programs offer single asset allocation portfolios created and managed by the Strategist. The portfolios created and maintained by the applicable Strategist are held in a single account and offer various asset allocation portfolios that invest in a variety of investment vehicles within the Strategist Select and Strategist Select Plus Programs. The Strategist allocates the portfolio across investment asset classes to create a blend that fits your investment objectives and Investor Risk Rating. Park Avenue may periodically provide investment advice to you, including recommendations related to the management of your assets by your selected Strategist, subject to approval by you, in a manner consistent with your investment objectives. The investment advice may include recommending a different portfolio with your selected Strategist or recommending a new Strategist. You can impose any reasonable restrictions or modify any existing restrictions on the management of your account. Third-Party Strategists 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. You grant Envestnet discretionary authority to invest, reinvest, and otherwise rebalance Program assets at their discretion. To give Park Avenue and Envestnet the requisite authority to perform the foregoing functions, you grant discretionary authority to Park Avenue solely for the purpose of allowing Park Avenue to delegate such authority to Envestnet for the management and administration of your account(s), and further grant to Envestnet discretionary authority, consistent with the investment strategy selected, to buy, sell, exchange, convert, or otherwise trade in securities, without prior consultation. Park Avenue Capacity as Strategist in the Strategist Select Plus Program Park Avenue provides management and maintenance of the investment models by performing administrative and trading services, such as directing the rebalance of the portfolios invested in the models. You grant Park Avenue discretionary authority to invest, reinvest, and otherwise rebalance Program assets at Park Avenue’ discretion. To give Park Avenue the requisite authority to perform the foregoing functions, you grant discretionary authority to Park Avenue for the management and administration of your account(s), and further grant Park Avenue discretionary authority, consistent with the investment strategy selected, to buy, sell, exchange, convert, or otherwise trade in securities, without prior consultation. To learn more about Park Avenue’s investment strategy in its capacity as a Strategist within the Strategist Select Plus Program, please see section 6, Portfolio Manager Selection and Evaluation. Park Avenue acting as Investment Manager and/or Strategist in the UMA Select and Strategist Select Plus programs creates a conflict of interest as Park Avenue will pay Envestnet a reduced manager fee cost of .0375% (of assets under management in these Programs) when the Park Avenue acts in this capacity. This reduced manager fee rate creates a conflict of interest for Park Avenue in providing an incentive for Park Avenue to offer and recommend the Park Avenue as Investment Manager and/or Strategist to clients over other third-party Strategists or Investment Managers in which the Envestnet manager fee cost to Park Avenue would be higher. The reduced manager fee paid to Envestnet does not impact Park Avenue IAR compensation or share of the Total Client Fee. In addition, when selecting a third-party Investment Manager or Strategist, the wrap fee paid by you has a manager fee component which is paid to the third-party Investment Manager or Strategist for the management of your account. When Park Avenue acts as Investment Manager or Strategist, the manager fee component of your wrap fee does not exist. This creates an incentive for Park Avenue and its IARs to recommend Park Avenue as an Investment Manager or Strategist rather than a third-party Investment Manager or Strategist in order to retain a larger portion of the Total Client Fee. Foundations and Quantitative Innovations 14 PAS017975 (4/2026)  The Foundations and Quantitative Innovations Programs are discretionary investment advisory programs sponsored by Park Avenue that provide clients with access to model portfolios managed by Integrated Capital Management, Inc. (“iCM” or “Strategist”), a third-party asset manager that has been retained by Envestnet. Envestnet provides overlay management of the iCM investment models by performing administrative and trading services, such as directing the rebalance of the portfolios invested in the models. By executing the SIS, you grant Envestnet the discretionary authority to invest, reinvest, and otherwise rebalance Program 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 will adjust 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. 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 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 Portfolio Solutions, LLC. 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. Park Avenue 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. 15 PAS017975 (4/2026)   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 Park Avenue IAR ranges from 50bps to 175bps, a portion of which is retained by Park Avenue. The fee does not include any recordkeeping or individual participant fees, all of 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. ERISA Section 408(b)(2) Disclosure to Responsible Fiduciaries of ERISA-Covered Qualified Retirement Plans The federal law that regulates the administration and operation of retirement and other benefit plans, called the Employee Retirement Income Security Act of 1974 or ERISA, requires “fiduciaries” of ERISA-covered plans (“Plans”) to act solely in the interest, and for the exclusive benefit, of plan participants and beneficiaries. As part of this obligation, the “administrator” of each plan, or another responsible fiduciary named by the plan document, must make informed decisions in selecting plan services and investments. Regulations adopted by the U.S. Department of Labor (“DOL”), called the “section 408(b)(2) regulations,” require service providers to ERISA- covered retirement plans to describe in writing information about their services and compensation (“Disclosure”). This Disclosure is provided in connection with the section 408(b)(2) regulations and is intended to assist you, as the responsible fiduciary of your Plan (“you”), in reviewing the services and compensation of Park Avenue and your IAR. Services we provide to your Plan. Advisory Services: Proprietary Advisory Program Together with your IAR, Park Avenue provides advisory services to you and to your Plan as described in our Statement of Investment Selection, Terms and Conditions, Advisory Account Application, and this Brochure (together, the “Investment Advisory Agreement”) relating to your Plan. Please review those documents. Pershing LLC (“Pershing”) provides custody and clearing services in connection with your advisory account and therefore acts as a subcontractor for Park Avenue. Please review the Pershing Subcontractor Compensation Disclosure provided at account opening for information related to Pershing’s compensation for providing these subcontracted clearing and custody services. If you do not have copies of any of the documents mentioned in this paragraph, please contact your IAR or our Home Office directly at 888-600-4667. Park Avenue acknowledges and agrees that, to the extent the advisory services provided to your Plan may include recommendations made by Park Avenue or your Park Avenue IAR with respect to investments that involve “investment advice” as defined under regulations issued under ERISA, we will be a “fiduciary” for ERISA purposes. Please note that Park Avenue does not and cannot provide legal, accounting, or tax advice to you or to the Plan. You are responsible to maintain the Plan in compliance with requirements applicable to tax-qualified plans under the Internal Revenue Code including, where applicable, receipt of a favorable determination letter, and Park Avenue does not have any responsibility for such matters. Park Avenue does not accept any responsibility for the administration of your Plan, including (without limitation) the timely transmission of required contributions, filing required governmental reports, preparing, or providing notices and communications to your Plan’s participants as required by applicable law and regulation, or notifying you that any such notices or communications are required. You should seek the advice of the appropriate legal and other advisors with respect to these and other matters that might arise relating to the operation and administration of the Plan. Our Compensation for Services The fees charged to your Plan for providing services are as described by either the Investment Advisory Agreement or the Third-Party Investment Advisory Agreement, whichever is applicable, relating to your Plan. We may pay between 35% and 85.5% of the Adviser Fee received in connection with the services provided for your account to your IAR. If you have questions about the compensation that is paid to Park Avenue and the IAR, please ask your 16 PAS017975 (4/2026)  IAR or contact our Home Office at 888-600-4667. Other Matters If your Plan is a participant-directed Plan, your Plan’s record-keeper and/or the investment provider that offers the investment platform through which your Plan’s investments are processed, is required to provide to you information to comply with DOL regulations that require the delivery of information to your Plan’s participants about the Plan’s designated investment alternatives. If requested, your IAR may assist you in coordinating with the recordkeeper and/or investment provider to obtain these materials. Your investment providers are responsible for ensuring that these materials are complete and accurate, and Park Avenue does not make any representation as to the completeness and accuracy of these materials. In providing services to your Plan, Park Avenue relies on information provided by you and, if there is any material change in information pertaining to the Plan, you must promptly notify Park Avenue in writing and provide relevant updated information. You are responsible for the exercise of proxy voting and other shareholder rights pertaining to investments held by the Plan. In addition, neither Park Avenue nor your IAR may provide any investment or other advice with respect to assets of the Plan that may be invested in stock issued by the plan sponsor and/or a self- directed brokerage option that permits participants the opportunity to allocate some or all of their participant accounts to other investments, or with respect to continuing such investments as a part of the Plan. All investments fluctuate in value and the value of the investments, when sold, may be greater or lesser than the original cost. Park Avenue does not and cannot warrant or guarantee any level of performance by any of the investments or that any investment will be profitable over time. The Plan and its participants are assuming the market risk involved in the investment of Plan assets. Past investment performance does not guarantee any level of future investment performance. Park Avenue provides advisory services for other clients and may give those clients advice and perform duties (including those with similar retirement plan arrangements), which differ from advice given, or in the timing and nature of action taken, with respect to your Plan. Park Avenue has no obligation to advise you or the Plan in the same manner as we may advise any other clients of Park Avenue. In addition, if Park Avenue learns confidential information in providing services to another client, Park Avenue cannot divulge any confidential information to you or act upon such confidential information in providing services to you and your Plan. Some IARs engage in outside business activities that Park Avenue does not supervise, such as (without limitation) providing retirement plan consulting, administration, recordkeeping, or similar services, with respect to retirement plans. Park Avenue does not endorse or recommend any IAR or any other person to provide services to you or to the Plan that are not within the scope of services described by this Disclosure and the Investment Advisory Agreement with you relating to your Plan, and Park Avenue will not supervise any IAR with respect to any such outside business activities. Therefore, if you engage your IAR to provide services other than the services described by this Disclosure and the Investment Advisory Agreement, it will be your responsibility to determine whether the services are appropriate for your Plan and to monitor the services. If you have any questions relating to this Disclosure, please contact your IAR or our Home Office directly at 888-600-4667. Program Fees Fees for the Park Avenue Programs are negotiable by mutual agreement between you and Park Avenue. Subject to negotiation and upon approval of Park Avenue, the maximum annual Total Client Fee is 3%. Fees do not include underlying expense ratios of any mutual funds and/or ETFs within your Park Avenue Program account. Please refer to the Statement of Investment Selection within the Proposal as well as the Investment Manager’s or Strategist’s ADV Part 2A for the specific Investment Manager and Strategist fees, which are encompassed in the overall client fee. Fees do not include underlying expense ratios of any mutual funds and/or ETFs selected by an Investment Manager or Strategist. These expense ratios may be found in the Model Portfolio Fact Sheet contained within the Proposal. In addition, IRA and certain Employer Sponsored Qualified Plan accounts will be assessed a $125 termination fee upon account termination. 17 PAS017975 (4/2026)  The Total Client Fee is based on the average daily balance of assets in a client’s account during the previous calendar quarter (or if the account is opened mid-quarter on a pro rata-basis) and is payable in advance for the following quarter and specified in the Client Agreement or other account opening documentation. You will pay one total fee, for the services provided in the program you have selected. The services include the brokerage and advisory services provided by Park Avenue and your IAR, the technology related services provided by Envestnet, the advisory related services provided by Envestnet, the advisory services provided by any Sub- Managers and SMA Sub- Managers (as applicable), the brokerage services involved in purchasing and selling the securities in your account, and the custodial and clearing services provided by Pershing. Your fee is separated into different components, which vary depending on the program you have selected:  An Adviser Fee for the advisory services provided by your IAR which currently ranges from .50% to 1.75% of assets under management.  A Platform Fee, which is paid to Park Avenue, as the sponsor for Park Avenue Programs, and for the technology related services and/or the advisory related services provided by Park Avenue and Envestnet, and the brokerage services involved in purchasing and selling the securities in your account. Please see section Annual Platform Fee – Park Avenue Proprietary Program Accounts for additional information.  A Manager Fee for the advisory services provided by Strategists and Investment Managers (as applicable) which ranges from .0% to .65% of assets under management. The Total Client Fee is located in your Statement of Investment Selection. The fee is calculated at the end of each quarter and is debited from the account on the 10th day of the month (or the next business day if the 10th day is a non-business day), of the following quarter. If you choose a standard fee schedule rather than a negotiated fee, and your assets exceed a fee breakpoint or fall below a fee breakpoint, your Total Client Fee will be adjusted to the appropriate fee schedule in the subsequent quarter. IARs have an incentive to select a manager with a lower manager fee to enable them to charge a higher Adviser Fee without increasing your Total Client Fee. Similarly, advisors have an incentive to negotiate their Adviser Fee to a higher level when the platform portion of the fee decreases so your Total Client Fee remains level rather than decreasing at certain breakpoints. If cash or cash-equivalent funds in your account are not sufficient to pay the fee, or any of the other fees charged in connection with your account, investments in your account may be liquidated in order to pay the outstanding fees. If your account is managed for only a portion of the quarter, the fee will be prorated accordingly. The Total Client Fee does not include costs or charges associated with liquidation of a client’s account and related charges, including but not limited to, express postage and handling charges, returned check charges, wire or transfer fees, transfer taxes or exchange fees, fees for paper statements and paper confirmations or other fees mandated by law, or non-brokerage related fees such as Individual Retirement Account (“IRA”) trustee or custodian fees and tax qualified retirement plan account fees, each of which is charged separately. These related charges are collected by Pershing; however, Park Avenue marks up the noted charges by as much as 150% and retains the markup. For example, to process a Federal Funds Wire, Pershing charges Park Avenue $10, you will be charged $25 (Pershing collects $10, Park Avenue collects $15). The markup on these charges helps defray our costs associated with maintaining and servicing client accounts. The additional compensation due to the markup presents a conflict of interest because Park Avenue receives a financial benefit when it provides services in connection with maintaining and servicing your account. However, because your IAR does not share in these other account fees, your IAR does not have a financial incentive to recommend certain transactions or recommend that Park Avenue provide such additional services. A full listing of charges is listed in the current Client Fee Schedule which is provided to you at account opening, will change over time, and can be found on our website at https://www.parkavenuesecurities.com/, or may be obtained by calling us at (888)-600-4667. Upon termination of your account, you will receive a pro-rata refund representing the period from terminated date to the end of the quarter. No refunds are made in the case of a partial withdrawal from the account. 18 PAS017975 (4/2026)  Step-Out Trading Transactions executed at broker-dealers other than the one at which a client’s account is held are sometimes called “step-out” trades or “trade-away” practices. An Investment Manager or Strategist that has the discretion to execute step-out trades with broker-dealers other than Pershing may or may not incur additional transaction, trading, or execution fees that the client will pay as a result of such step-out trades. Additional transaction, trading, or execution fees resulting from step-out trades will increase the client’s cost and negatively impact investment performance. However, a step-out trade can potentially allow the Investment Manager or Strategist to achieve better price execution. In cases where an asset-based fee that includes the cost of advisory, brokerage, and custodial services (i.e., a “wrap fee”) is assessed, the asset-based fee does not cover charges resulting from step-out trades effected by an Investment Manager or Strategist with broker-dealers apart from Pershing. Investment Managers and Strategists are generally free to consider other broker-dealers’ trading capabilities versus Pershing’s trading capabilities as part of their duty to seek best execution and obligations as investment advisers. Investment Managers and Strategist may decide to step-out for a variety of reasons, including to obtain an optimal combination of price and service for the client or to satisfy the Investment Manager’s or Strategist’s best execution obligation. Investment Managers and Strategists have the discretion to utilize step-out trades in circumstances including, but not limited to, those involving equity securities, fixed income securities, derivatives (e.g., options), thinly-traded securities, illiquid securities, and ETFs. A step-out trade occurs in some instances when an Investment Manager or Strategist purchases equity securities, fixed income securities, derivatives (e.g., options), thinly-traded securities, illiquid securities, ETFs, or other securities from a different broker-dealer or the broker-dealer selling the securities to obtain a more favorable price or because the particular security is not available through Pershing. In other instances, a step-out trade occurs when an Investment Manager or Strategist executes a single trade for multiple clients by aggregating orders into a single “block.” A “block” trade can potentially provide the client with a better overall price and/or return because a single order can potentially result in better execution versus placing multiple separate orders. When an Investment Manager or Strategist executes a block order, that Investment Manager or Strategist is seeking to obtain best execution and best price. Aggregating transactions into a single trade can potentially afford the Investment Manager or Strategist more control over the execution of the trade, including potentially avoiding an adverse effect on the price of the security that could result from effecting a series of separate, successive, and/or competing small trades with multiple broker-dealers or clearing firms. Park Avenue Proprietary Program Total Client Fees do not cover any fees, costs, or expenses resulting from step- out trades effected with, or through, broker-dealers or clearing firms other than Pershing. They also do not cover any mark-ups or mark-downs (i.e., adjustments to your purchase or sale price above or below the current market price of the applicable security) by any such other broker-dealers or clearing firms. As such, clients are responsible for any such additional transaction, trading, and execution fees, costs and expenses in addition to the applicable Park Avenue Proprietary Program fees. Additional costs resulting from step-out trades typically are included in the net price of the securities traded and typically are not reflected as separately identifiable charges on your trade confirmations or account statements. It is expected that Investment Managers or Strategists would typically consider trades executed through Pershing to be without a commission or retail mark-ups or mark-downs when comparing the cost of trading securities with other broker-dealers. Park Avenue would expect such a comparison by an Investment Manager or Strategist to generally result in a decision to execute most trades through Pershing. However, Investment Managers and Strategists from time to time believe they are able to obtain better execution utilizing step-out trades. A general description of the additional costs related to step-out trades can be found on our website at www.parkavenuesecurites.com. If you have any questions regarding this information or step-out trading in your account and related costs, please contact your IAR. Annual Platform Fee – Park Avenue Proprietary Program Accounts The annual Platform Fee is a component of the Total Client Fee as described in your Statement of Investment Selection. The annual Platform Fee ranges in the aggregate from .05% to .30% of assets under management with a minimum annual fee of $90.00 per household, which will result in an annual fee percentage above .30% for the 19 PAS017975 (4/2026)  Platform Fee if a client’s household assets under management fall below a certain threshold. Customers enrolled in the PMC Private Wealth Consulting Service will be charged an additional fee ranging in the aggregate from .10% to .15% of assets under management. Should your account’s balance during a quarter be below the point at which at least $22.50 in Platform Fees, on average, are generated, your client fee shall be increased incrementally to satisfy the minimum. Using the example from above, if an account with a balance of $50,000 during a quarter generated a Platform Fee of $24.00, the $22.50 minimum quarterly fee would have been satisfied and no additional expense would be incurred. However, if an account with a balance of $35,000 during a quarter generated a Platform Fee of $22.20, the $22.50 minimum quarterly fee would not have been satisfied, resulting in the incremental increase of your client fee to make up for the additional $0.30. On average, account balances greater than $42,000 will not see any impact from this minimum fee. For accounts with balances less than this amount, the Platform Fee portion of your Total Client Fee shall be increased incrementally to satisfy the minimum quarterly Platform Fee. This may cause your Total Client Fee percentage to be greater than the percentage indicated on the SIS, may fluctuate from quarter-to-quarter, and is dependent on the value of your account’s assets during the prior quarter. Fluctuations in the account value during some quarters may cause the annual Platform Fee to be higher or lower than if the Platform Fee were calculated annually on the average account value because of the possible annual minimum Platform fee being assessed in a particular quarter or the possible Annual Platform fee breakpoints that may be achieved by a client account. Householding for Annual Platform Fee Park Avenue shall allow householding for multiple Park Avenue Proprietary Program accounts, other than VestWise. Park Avenue policy in determining client accounts that qualify as a household generally defines “household” as Park Avenue Proprietary Program accounts, other than VestWise, of the same account owner, spouses, domestic partners, parents, and children and will consider the total assets held across the full relationship versus each account individually when determining the minimum annual platform fee applicable to each individual account. You are responsible for identifying these accounts and working with your Park Avenue IAR to include them in the correct household for billing purposes. In certain circumstances, Park Avenue may, in its sole discretion, permit Park Avenue Proprietary Program accounts falling outside of the criteria listed above to be grouped as a household. To the extent your Park Avenue Proprietary Program account is subject to householding discounts for applicable Park Avenue Proprietary Program account fee components, the Total Client Fee you incur will in certain circumstances be lower than the Total Client Fee reflected in the fee table of your SIS. Fees are negotiated with each client based upon, among other things, the size and complexity of each client’s circumstances. Each IAR will negotiate with each client to determine the fees the client will be charged, therefore, fees vary among IARs and clients and some IARs charge higher fees than other IARs for similar or identical services. The fees charged by each entity providing services to the Park Avenue Proprietary Programs vary based on the securities and other investment products used, the size of the client’s account and/or household, and other factors. Current Annual Platform Fee[1] Advisory Account Balance Future Annual Platform Fee (As of Oct. 1, 2021) Adjustment to Annual Platform Fee to Reach $90 Minimum Family Relationship None $55 each (Total =$110) $55 each (Total = $110) 2 separate accounts, $25,000 each (Total = $50,000) $35,000 $77 $90 +$13 to meet the minimum Accounts or Family Relationships with $35,000 in aggregate assets [1] Your individual account platform fee may differ from this example; please contact your IAR if you would like more information For Individual Retirement Accounts (“IRAs”) being added to a household it is the client’s responsibility to consider 20 PAS017975 (4/2026)  the balances and activities of that account in a household and determine if it’s appropriate to household such account. A client should contact their legal or tax advisor to understand any possible unanticipated tax consequences of householding such accounts. If a client determines that they wish to exclude an IRA account from a billing group, the client is required to contact Park Avenue or their financial advisor to request that the account not be included in the household. For the Foundations and Quantitative Innovations programs the following fee schedule applies with breakpoints available based on total assets under management for the account. Foundations and Quantitative Innovations Fees Assets Under Management $0 - $499,999.99 $500,000.00 - $999,999.99 $1,000,000.00 - $1,999,999.99 $2,000,000.00 – over Maximum Client Fee 2.15% 2.10% 2.05% 2.00% Envestnet Tax-Overlay Management Services If selected by you, Envestnet will also provide tax overlay management services to accounts invested in the UMA Select, Strategist Select, and Strategist Select Plus programs. The tax overlay and management services seek to consider tax implications that may detract from your after-tax returns. The end goal of tax overlay management services is to improve the after-tax return for you while staying as consistent as possible with the risk/return characteristics provided by the model portfolios. Park Avenue or Envestnet does not provide tax planning advice or services. You should consult your accountant or tax advisor if you have question related to your tax situation. The typical additional fee for overlay management (which is charged on the total assets of your account) is listed in the table below: Account Assets Overlay Service Fee – Park Avenue UMA Select* First $10,000,000 Next $15,000,000 Over $25,000,000 .10% .08% .05% *Investors choosing PMC Private Wealth Consulting Services as manager are not subject to the Overlay Service Fees. Account Assets Overlay Service Fee – Park Avenue Strategist Select and Strategist Select Plus .08% with a minimum yearly fee of $40 Envestnet Impact-Overlay Management Services If selected by you, Envestnet will also provide impact overlay management services to accounts invested in the Park Avenue UMA Select program. The impact overlay services seek to reflect a Client’s own personal values by excluding investments linked to companies that derive revenues from controversial business activities (e.g., negative environmental impacts) or have a history of engaging in certain bad acts ( (e.g., human rights violations, corruption) while staying as consistent as possible with the risk/return characteristics provided by the model portfolios. If you select Impact-Overlay Services, your account’s composition and performance may vary significantly from those of accounts without an overlay. You should review the Envestnet Form ADV for additional and potential limitations related to the service. The typical additional fee for Impact Overlay management (which is charged on the total assets of your account) is .10%. The selection of these services reflects your personal values and desires to invest in a way that reflects such values alone and is not based on any recommendation or personal values of your IAR. 21 PAS017975 (4/2026)  PMC Private Wealth Consulting Services Envestnet and Park Avenue have entered into an agreement for Envestnet to provide Park Avenue with a fully outsourced portfolio design and implementation assistance for large UMA Select client accounts (which are greater than $1 million in household assets). Envestnet will provide the initial custom case consulting services along with ongoing portfolio management responsibilities as described below. (a) Initial Scope of Services –  Discussion to understand IAR or client biases towards investment allocation techniques.  Consultation with IAR and client to understand required return, risk tolerance, unique investment objectives and circumstances.  Current portfolio analysis across asset allocation and manager selection.  Portfolio recommendations based on Envestnet | PMC’s asset allocation and manager research output, with  the ability to incorporate client specific tax and IMPACT (i.e., social)considerations. In-person (for a $10 million or greater client or prospective client) or online assistance for positioning the proposal recommendations. (b) Ongoing Scope of Services –  Annual changes to portfolio level asset allocation.  Ongoing investment manager selection based on Envestnet | PMC’s Investment Manager Research. PMC Private Wealth Consulting Services Fees First $5,000,000 Next $5,000,000 Over $10,000,000 .15% .12% .10% Mutual Funds, Close Ends Funds and ETFs in Proprietary Advisory Programs In addition to the Total Client Fee, you pay the fees and expenses of the mutual funds, closed-end funds and ETFs (mutual funds, closed-end funds and ETFs collectively, “Fund(s)”) in which your account is invested. Fund fees and expenses are charged directly to the pool of assets the Fund invests in and are reflected in each Fund’s net asset value. These fees and expenses are an additional cost to you and are not included in the fee amount in your account statements. Each Fund expense ratio (the total amount of fees and expenses charged by the Fund) is stated in its prospectus. The expense ratio generally reflects the costs incurred by shareholders during the Fund’s most recent fiscal reporting period. Current and future expenses may differ from those stated in the prospectus. You do not pay any sales charges for purchases of Funds in the programs described in this Brochure. However, some Funds may charge, and not waive, a redemption fee on certain transaction activity in accordance with their prospectuses. Please refer to the applicable prospectus for more information. If you have authorized prospectus redirection to Park Avenue in a discretionary Proprietary Program, you may contact your IAR or Park Avenue to review or obtain a copy of the prospectus for Funds used within the Park Avenue Proprietary Programs. You should be aware that, in addition to the Total Client Fee paid by you for advisory services under a Program, each investment company (i.e., mutual fund) in the Program also has its own separate investment management fees and other expenses. These mutual funds may include assets managed by Park Avenue Institutional Advisers LLC (“PAIA”), an affiliate of Park Avenue, as a sub-adviser to certain mutual funds offered by Victory Capital. Further, certain mutual funds with a front-end sales charge may be purchased in a client’s account at net asset value (“NAV”) without a sales charge to a client (“NAV” Funds”). Certain mutual funds available through the Park Avenue Proprietary Programs make payments to broker-dealers, including Park Avenue, with respect to sales of fund shares pursuant to Rule 12b-1 under the Investment Company Act of 1940 (“Rule 12b-1 Service/Distribution Fees”) or 22 PAS017975 (4/2026)  otherwise as administrative service fees. These fees are described in the prospectus for the respective mutual fund. Such payments are made from mutual fund assets and have the effect of reducing fund performance. Park Avenue does not negotiate these payments, which are made solely at the discretion of the fund. Park Avenue credits any Rule 12b-1 Service/Distribution Fees it receives to client accounts (with the exception of certain money market mutual funds and FDIC sweep vehicles). Park Avenue shall not be responsible for any misstatement or omission or for any loss attributable to such misstatement or omission contained in any Fund prospectus, fact sheet or any other disclosure document provided to us for distribution to you. Mutual Fund Share Class Selection The following is applicable to Park Avenue Proprietary Programs, exclusive of VestWise™, mutual fund portfolios managed by a third-party Strategist or third-party Investment manager, and funds used within the Cash Management Sweep Program. investor eligibility requirements prescribed by a mutual fund company; When negotiating and discussing your Total Client Fee, you should understand that mutual fund companies offer a variety of share classes with different expense levels. These expense levels, known as expense ratios, are fees and expenses charged by the mutual fund company and that investors will pay to purchase, hold, and sell shares of a mutual fund. You should not assume that you will always be invested in the share class with the lowest expense ratio for a mutual fund due to the following factors:   Park Avenue’s mutual fund share class selection processes. An investor who holds a more expensive share class of a mutual fund will pay higher fees over time and earn lower investment returns than an investor who holds a less expensive share class of the same mutual fund. When evaluating the reasonability of fees, you should consider not just the fees that you pay for investment advisory services through Park Avenue, but also the additional fees and expenses charged by the mutual fund companies in your account. For detailed descriptions of the components of a fund’s expense ratio by share class, please refer to the mutual fund prospectus. In addition, an overview of mutual funds share classes is available within the Park Avenue Mutual Fund Disclosure document located at www.parkavenuesecurities.com/legal/mutual-disclosure. As a matter of practice, Park Avenue will not invest clients into share classes containing sales charges and distribution fees such as 12b-1 fees. After determining the share classes that the Programs are eligible to purchase, pursuant to each fund’s prospectus, we will further evaluate each of these share classes and aim to select the lowest cost available share class for which the majority of the programs’ clients are eligible to purchase. This results in Park Avenue excluding certain share classes with the lowest expense ratios if the majority of clients are not eligible to purchase, such as certain Retirement share classes. Moreover, while we avoid using share classes that charge a Distribution Fee, such as a 12b-1 fee, as part of our Programs, if a Distribution Fee bearing share class is transferred into a client account, the fees are credited to client accounts monthly, as applicable, until the share class is converted pursuant to Park Avenue’s share class conversion process. Please read the section below for additional details related to share class conversions. In some instances, among the various share classes issued by a mutual fund company, a fund company may offer share classes that include a fee referred to as a Sub-Transfer Agent Fee (“Sub-TA Fee”) and share classes that do not contain this fee. Sub-TA Fees are paid by the mutual fund company to a third-party provider to subsidize certain services otherwise done by the mutual fund company, such as processing daily transactions, maintenance of account balances, mailing of prospectuses, etc. The Sub-TA Fee increases the total expense ratio of a fund. The amount of a Sub-TA Fee may differ by mutual fund company. Details related to the cost of a Sub-TA Fee are described within 23 PAS017975 (4/2026)  fund prospectuses. As matter of practice, in these instances, Park Avenue will select the share class containing the Sub-TA Fee for use within the Programs. This means that Park Avenue may not select the lowest cost share class for which the client is eligible even if there is a less costly share class that does not charge Sub-TA Fees. The Sub-TA Fee compensates Pershing, LLC (Park Avenue’s custodian) for sub-accounting, recordkeeping, and related services at the individual account level. Pershing, LLC passes along a surcharge to Park Avenue for any mutual fund that is part of a Park Avenue advisory Program which does not contain a Sub- TA Fee. Park Avenue’s practice of selecting a share class that contains a Sub-TA Fee when a share class of the same fund without a Sub- TA Fee is available, causes a conflict of interest as Park Avenue has a financial interest in selecting the Sub-TA bearing share class to avoid the Pershing, LLC surcharge. In the Park Avenue Portfolio Select, Park Avenue UMA Select and Park Avenue Signature Portfolio programs, your IAR can make mutual fund recommendations as part of your overall asset allocation. The mutual funds made available for recommendation and selection by your IAR in these programs will only be those with which Park Avenue has a selling agreement and those that have been deemed appropriate for these programs by Park Avenue. You should not assume that you will be invested in the share class with the lowest expense ratio for a mutual fund in the Park Avenue Portfolio Select, Park Avenue UMA Select and Park Avenue Signature Portfolio programs. Share Class Conversions. At least annually, Park Avenue will review the mutual fund share classes held within the Park Avenue Portfolio Select and Park Avenue Signature Portfolio programs. Mutual funds recommended by IARs in the UMA Select program will also be reviewed. If a lower cost share class is found to be available in these programs, pursuant to the funds’ eligibility requirements and Park Avenue’s share class selection processes, Park Avenue will process a conversion to a lower cost share class. Therefore, you may hold a higher cost share class of a mutual fund in these circumstances for up to twelve months before Park Avenue converts your investment to a lower cost share class. Until the conversion is implemented, we will continue to retain shares of the less favorable class for your account. Park Avenue will only convert share classes to a lower cost share class. If you are already invested in a share class that is lower in cost than what is available in these programs, as described above, you will retain your investment and will not be converted to a higher cost share class. Park Avenue SMA Select and UMA Select, Park Avenue Strategist Select and Strategist Select Plus, and Quantitative Innovations and Foundations Investment Manager Mutual Fund Share Class Selection Park Avenue IARs may also recommend the use of third-party Strategists or third-party Investment Managers within the above referenced Programs who may use mutual funds as part of an asset allocation for your account. Each Strategist or Investment Manager has their own policy regarding mutual fund share class selection and they are responsible for the mutual fund share classes chosen. Park Avenue cannot require an Investment Manager or Strategist to use the lowest cost share class available. Park Avenue also reviews a Strategist/Investment Manager’s mutual fund share class selection as part of Park Avenue’s ongoing due diligence process to determine the continued use of such Strategist/Investment Manager. Please refer to the applicable Strategist or Investment Manager’s Form ADV Part 2A or Wrap Fee Program disclosure included in your account opening documents or at www.adviserinfo.sec.gov for information regarding their mutual fund share class selection. You should not assume that you will be invested in the share class with the lowest expense ratio for a mutual fund in the Park Avenue SMA Select, Park Avenue UMA Select, Park Avenue Strategist Select, Park Avenue Strategist Select Plus, and Park Avenue Quantitative Innovations and Foundations programs. Cash Management Sweep Program A Cash Management Sweep Program (“Sweep Program”) is a service Park Avenue makes available to clients which allows clients to automatically transfer free credit balances to either a money market fund product (the “Money Market Sweep”) or an account at a bank whose deposits are insured by the Federal Deposit Insurance Corporation (“Bank Sweep”). Park Avenue Proprietary Program Accounts (“Accounts”) are eligible to participate in the Sweep Program. The Park Avenue Sweep Program is comprised of a Bank Sweep product, which all clients shall be 24 PAS017975 (4/2026)  defaulted to at account opening, as well as specific money market funds which serve as overflow funds for accounts whose Bank Sweep product balance exceeds certain Federal Deposit Insurance (“FDIC”) limits. At the time you open your Account, you shall be defaulted to one of two Bank Sweeps. All Accounts, except for IRA and Retirement Plan Accounts, will be defaulted to the Dreyfus Insured Deposits Program (DIDV). The default DIDV Bank Sweep product is an FDIC insured multi-bank deposit sweep program. Additionally, balances in DIDV within the same account which are in excess of the $2.5 million FDIC insured limit will be automatically redirected to the Dreyfus Government Money Fund (DGUXX). IRA and Retirement Plan Accounts will default to DIDM—a design of the Dreyfus Insured deposit Program specifically for IRA/Retirement Accounts. Any balances within the same IRA/Retirement Plan Account over the $2.5 million in FDIC coverage will be diverted to the Dreyfus Government Money Fund (DGVXX). When depositing into either the default DIDV or DIDM Dreyfus Insured Deposit Programs, you will receive a Disclosure Statement and Terms and Conditions of the program you are defaulted into. Amongst other items, the Disclosure Statement and Terms and Conditions detail various conflicts of interest associated with the Dreyfus Insured Deposit Program you are participating in, how interest rates are determined, and risks associated with the program. In addition, the Disclosure Statement and Terms and Conditions will provide a description of the DGUXX or DGVXX Dreyfus Money Fund associated with your Sweep Program. You are encouraged to carefully read and understand the Disclosure Statement and Terms and Conditions. The Disclosure Statement and Terms and Conditions is readily available on the Park Avenue Cash Management webpage at https://www.parkavenuesecurities.com/cash-management, by contacting your IAR, or by contacting our Home Office at 888-600-4667. In addition, if invested into either DGUXX or DGVXX Dreyfus Money Funds, you will receive a prospectus of the fund you are invested into. Park Avenue has a conflict of interest by offering the DIDV Bank Sweep and the DGUXX Money Market Sweep Programs. Park Avenue receives a significant economic benefit when cash balances are swept into these Sweep Programs, rather than being reinvested in other investment funds or securities. For the DIDV Bank Sweep, Park Avenue receives a share in the earned income based on the amount of assets placed within the Bank Sweep. Park Avenue also receives a distribution from the DGUXX Money Market Sweeps used for overflow balances pursuant to the Fully Disclosed Clearing Agreement with its clearing firm, Pershing, LLC. The income earned from the DIDV Bank Sweep and the distribution received from the DGUXX Money Market Sweep, both of which are generated from, and paid by client deposits, are in addition to the Total Client Fee paid by clients to Park Avenue, related to investing in Park Avenue Proprietary Program Accounts. This conflict gives us a financial incentive to (i) select the DIDV and DGUXX Sweep Programs as the default Sweep Programs for all Proprietary Program Accounts other than IRA and Retirement Plan Accounts, rather than other Sweep Programs that are available that pay Park Avenue relatively lower or no revenue; (ii) recommend or advise clients to increase their deposits within the DIDV and DGUXX Sweep Programs; (iii) recommend or advise clients to invest in Proprietary Program Accounts that default into the DIDV and DGUXX Sweep Programs rather than accounts held directly with Third-Party Investment Advisory Programs; and (iv) recommend a Sweep Program option based on the compensation we receive instead of your needs. As a result, if you are invested in a Sweep Program option that pays Park Avenue a fee, the cost to you may be more than if you are invested in a Sweep Program that does not pay Park Avenue a fee. You may choose to opt out of the Sweep program by contacting your IAR. For additional information regarding payments received by Park Avenue regarding the DIDV Bank Sweep and Money Market alternative option, please review Item 9, Additional Information, specifically Dreyfus Insured Deposits Program. For more information on the Bank Sweep and Money Market overflow options as well as current yields and available bank lists please go to the following pages: https://www.parkavenuesecurities.com/cash-management and http://www.pershing.com/rates. Please note that Park Avenue does not offer all of the sweep options listed on the Pershing website. 25 PAS017975 (4/2026)  Assets held in any of the Sweep Programs will be included in the calculation of the client’s Total Client Fee, (i.e., they are considered “billable assets”). Your Account may require a certain amount of cash to remain in the Sweep Program to cover for certain costs associated with your Account. Different Sweep Program vehicles will have different rates of return, may pay Park Avenue a distribution fee, have different costs, and have different terms and conditions, such as FDIC insurance or SIPC protection, depending on the sweep vehicle. If the rate of return received from Sweep Programs fall below that of your Total Client Fee, you will experience a net negative overall return with respect to your Sweep Program deposits. The sweep vehicle is reflected on your account opening documents and on your statements. The selection of a more expensive share class of a Money Market Fund will negatively impact your overall investment returns. Sweep Program vehicles are not intended for use as a long-term investment option and are best used for short periods of time. You may be able to earn a higher yield through a different investment, and you should consult with your IAR about the available sweep options. Federal Deposit Insurance Corporation insured bank deposits are not protected by Securities Investor Protection Corporation. Although a money market mutual fund seeks to preserve the value of your investment at $1 per share, it may be possible to lose money by investing in a money market mutual fund. Shares of a money market mutual fund or the balance of a bank deposit product held in your account may be liquidated upon request with the proceeds credited to your account. Please see the money market fund’s prospectus or the bank deposit product’s disclosure document or contact your financial professional for additional information. Pursuant to SEC Rule 10b-10b(1) confirmations are not sent for purchases into money market mutual funds processed on the Sweep Program. Over any given period, the interest rates on cash balances in the Bank Sweep product may be lower than the rate of return on money market vehicles which are not FDIC insured or on bank account deposits offered outside the Sweep Program. If any sweep vehicles designated within the Sweep Program becomes unavailable at any time for any reason, Park Avenue will select an alternative in its discretion provided Park Avenue gives you 30 days advance written notice of such change and you do not object. In this event, the free credit balances in your Account will be placed into the alternative Sweep Program option. As noted earlier, all accounts will be automatically invested in a Bank Sweep vehicle. However, Park Avenue realizes an economic benefit from the DIDV Bank Sweep by sharing in the earned income based on the amount of assets placed within the Bank Sweep. For Accounts which hold a sweep vehicle charging a distribution fee retained by Park Avenue, Park Avenue does not share the distribution fee with your IAR. Therefore, your IAR does not have a financial incentive to recommend a Sweep Program option based on whether it pays a distribution fee or not. For additional information on money market funds and FDIC-Insured Deposit Sweeps, including applicable distribution fees, please see the fund prospectuses which are available on the following pages: https://www.parkavenuesecurities.com/cash-management and http://www.pershing.com/rates. Lending Services Offered to Park Avenue Proprietary Program Clients Non-Purpose Loan Program You may apply for a non-purpose loan from Pershing LLC through the Park Avenue Non-Purpose Loan Program using an eligible securities account as collateral. These eligible securities accounts may include one or more of your Park Avenue Proprietary Program accounts. In order for Park Avenue 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 Park Avenue on the loan value in addition to the Total Client Fees charged in the Park Avenue Proprietary Program account being used 26 PAS017975 (4/2026)  as collateral. Park Avenue 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 Park Avenue Proprietary Program accounts. In order for Park Avenue 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 Park Avenue on the loan value in addition to any Program advisory fees charged in the Park Avenue Proprietary Program account being used as collateral. Park Avenue 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 Park Avenue 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, Park Avenue and your IAR continue to earn fees on the full account value. Park Avenue will also receive a portion of the loan interest when you participate in the Pershing Non-Purpose and / or the Tri-State SBLOC Loan Programs. Furthermore, there are conflicts of interest associated with the various lending programs as Park Avenue 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 Park Avenue 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 Park Avenue 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 Tri-State, 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. 27 PAS017975 (4/2026)  The decision to use 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;   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 non-purpose loan in a Program account if the performance of your account does not exceed the interest expense being charged on the loan. Due to the fact your Park Avenue 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 Park Avenue, 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 Park Avenue, 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. Park Avenue 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 Park Avenue nor its IARs will act as an investment adviser to you with respect to the liquidation of securities held in a Park Avenue Proprietary Program account to meet a loan demand. Those liquidations will be executed in Park Avenue’ 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 a creditor Park Avenue 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 Park Avenue’ 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%. Park Avenue 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 28 PAS017975 (4/2026)  the point where they no longer meet the minimum equity requirements for the margin loan, there will be a margin call. When this happens, Park Avenue 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 Park Avenue or Pershing, at their discretion, to liquidate 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 Park Avenue 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 Park Avenue has a financial incentive to recommend or maintain a margin loan. This compensation is retained by Park Avenue 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. 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 501c(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, Park Avenue 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 Park Avenue IAR to manage contributed assets in accounts held at Pershing. These accounts will be invested in either the Park Avenue Strategist Select Program or Strategist Select Plus Program. Park Avenue and the IAR will receive the Adviser Fee from accounts invested these Program as described within the Statement of Investment Selection. 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 Park Avenue IAR will not act in the capacity of Authorized Representative on the account and neither Park Avenue 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 Adviser Fees to the IAR over the option with no compensation. Tax Harvesting Subject to meeting minimum balance requirements, you may direct Park Avenue to employ a tax harvesting strategy 29 PAS017975 (4/2026)  in managing taxable accounts. This means that, once the tax harvesting threshold is met, Park Avenue will sell securities in your account at a gain or loss to offset potential capital gains, although the type and amount of capital gains will not be monitored by Park Avenue for this purpose. By authorizing tax harvesting, Park Avenue will sell one or more securities in the account and will hold proceeds in cash to avoid the 30-day wash rule. Once 30 days have passed, the funds will be reinvested in the model. Within the Park Avenue SMA Select/UMA Select and Strategist Select/Strategist Select Plus programs, the Investment Manager or Strategist may select another ETF not substantially comparable to the security harvested to replace the securities that have been purchased or sold in your account. You should consult with your professional tax advisors or review the Internal Revenue Service (“IRS”) website at www.irs.gov regarding the consequences of tax harvesting in light of your particular circumstances and its impact on your tax return. If your IAR recommends a tax harvesting strategy for your account, that advice is not intended as tax advice. Neither Park Avenue nor your IAR represent that any particular tax results will be obtained. You are responsible for monitoring any accounts in your household, or accounts for which you maintain control (at Park Avenue or with another firm) to ensure that transactions in the same security or a substantially similar security do not create a “wash sale.” A wash sale is the sale at a loss and repurchase of the same security, or substantially similar security, within 30 days. If a wash-sale transaction occurs, the IRS may disallow or defer the loss for current tax reporting purposes. More specifically, the wash-sale period for any sale at a loss consists of 61 days: the day of the sale, the 30 days before the sale, and the 30 days after the sale (these are calendar days, not trading days). The wash-sale rule postpones losses on a sale if replacement shares are bought around the same time. The effectiveness of the tax harvesting strategy to reduce your tax liability will depend on your entire tax and investment profile, investments (e.g., taxable, or non-taxable) or holding period (e.g., short-term, or long-term). 5. Account Requirements and Types of Clients Park Avenue provides investment advisory services to individuals, high net worth individuals, pension and profit- sharing plans, charitable organizations, and corporations. Accounts that fall below the minimum balance are subject to closure by Park Avenue or the Strategist (as applicable), in its sole discretion. The programs’ minimum initial investment requirements are as follows: Park Avenue UMA Select – $10,000. Actual minimum may exceed $10,000 as certain investment strategies may have higher minimum requirements which Park Avenue cannot waive. You should speak to your IAR regarding minimum investment requirements and refer to the Investment Manager or Strategist Form ADV brochure for more information. Park Avenue SMA Select – Subject to individual Investment Manager Account minimum. Strategist Select and Strategist Select Plus – Subject to individual Strategist account minimums with the lowest minimum at $10,000. Strategists reserve the right to reject an account below their stated minimum. Strategist minimums are indicated in the Model Portfolio Fact Sheet located within your Proposal. Foundations/Quantitative Innovations - $10,000. Clients will be notified of any changes in Program account minimums. The minimums for the Programs may be modified or waived by Park Avenue on a case-by-case basis. 6. Portfolio Manager Selection and Evaluation Park Avenue IARs are responsible for assisting clients in the selection of advisory Programs based on clients’ investment objectives and Investor Risk Rating. Park Avenue IARs are also responsible for assisting you in the selection of a Strategist/Investment Manager (which includes the Quantitative Innovations and Foundations programs where iCM is considered to be a Strategist on the Envestnet platform), based on your investment 30 PAS017975 (4/2026)  objectives and Investor Risk Rating. Envestnet is compensated by Strategists and Investment Managers on an ongoing basis once they have been approved to be on the platform. This poses a conflict of interest. Park Avenue utilizes an available list of Investment Managers/Strategists and investment strategies which are eligible for the programs. The available list of third-party Investment Managers and strategies are based on a list provided by PMC, a subsidiary of Envestnet. All third-party Investment Managers on the Envestnet platform are required to complete a PMC based annual compliance questionnaire which includes a full review on the following elements:  Compliance program(s), code of ethics, investigations and reviews by regulators, material changes to the programs, ADV review, proxy voting procedures, personnel changes, trading practices, and material trading errors. The performance of the investment vehicles offered through the Quantitative Innovations, Foundations, Strategist Select/Strategist Select Plus, Park Avenue SMA Select and UMA Select Programs are determined based upon standard performance calculations used in the industry. Performance data is calculated by Envestnet and sent to clients by Park Avenue. Performance Based Fees and Side by Side Management Park Avenue does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Methods of Analysis, Investment Strategies and Risk of Loss Your IAR will assist you in selecting an Investment Manager/Strategy or Strategist. When making a recommendation, your IAR will discuss with you various factors including, but not limited to, your personal financial preferences, fees charged by the Investment Manager/Strategist, information on the Investment Manager/Strategist, including their performance, and account minimum requirement. You are ultimately responsible for deciding which Investment Manager(s) to choose. When appropriate, your IAR may also assist you with determining whether an existing Strategist or Investment Manager should be replaced. As described in this section, Park Avenue offers an approved list of Investment Managers and Strategists, both third- party Investment Managers and Strategist and Park Avenue as an Investment Manager and/or Strategist, which provide a variety of investment strategies and corresponding risk levels. You should understand that all investments involve risk (the amount of which may vary significantly), that investment performance can never be predicted or guaranteed and that the value of your account will fluctuate due to market conditions and other factors. Park Avenue as Investment Manager and/or Strategist within the UMA Select and Strategist Select Plus Programs As previously stated, Park Avenue may act as Investment Manager within the UMA Select program and as Strategist within the Strategist Select Plus program. In these capacities, Park Avenue offers the PAS Select Portfolios within the both the UMA Select and Strategist Select Plus programs and the PAS Foundational Model Portfolios within the UMA Select program. PAS Select Portfolios PAS Select Portfolios offers seven investment models with allocations across investment asset classes to create an asset allocation blend that may meet your investment objectives and Investor Risk Rating. PAS Select Portfolios are offered as asset allocation targets or sleeves in fulfilling UMA Select asset allocation models. For the Strategist Select Plus program, a single PAS Select Portfolio will be elected by you to fulfill your account allocation. Park Avenue has entered into an agreement with BNY Mellon Securities Corporation (BNY) for BNY to act as the 31 PAS017975 (4/2026)  model provider for PAS Select Portfolios. In its capacity as Model Provider, BNY will provide Park Avenue with non- discretionary investment advice in relation to the recommendation of the investment model securities. The BNY investment process that supports the management of PAS Select Portfolios (the “Models”) incorporates both strategic asset allocation (SAA) and tactical asset allocation (TAA) to align the Models with their stated investment objectives. SAA establishes long-term target weightings for investment asset classes based on factors such as expected return and risk. The SAA serves as the foundation for portfolio construction, ensuring diversification and alignment with stated investment objectives for the Models. TAA is also employed to make short- term adjustments to the Models’ asset allocation in response to changing market conditions. The TAA process is guided by a systematic framework that evaluates key market indicators, including investor sentiment, liquidity conditions, and valuation metrics. Based on this analysis, adjustments may be made to portfolio exposures, such as increasing cash allocations during periods of heightened risk or increasing equity positions when market conditions are expected to be constructive for stocks. Portfolio construction for the Models is the process of selecting and weighting underlying investment vehicles (mutual funds and exchange-traded funds) based on the Models’ investment objectives, risk tolerances and the prevailing market conditions. Investment vehicle selection is conducted by BNY, which identifies proprietary and third-party mutual funds, and ETFs that meet BNY’s selection criteria. BNY is required to allocate to investment vehicles included on Park Avenue’s investment product research list (PAS Select List) per the investment guidelines. Eligible investment vehicles for the Models are evaluated based on factors including management team experience, adherence to the stated investment process, historical performance, and risk management practices. Due diligence on the underlying investment vehicles is conducted regularly to monitor consistency and suitability across varying market environments. The underlying investment vehicles exhibiting signs of deterioration in the previously referenced factors are subject to further review for potential replacement. BNY, in acting in their capacity as a Model Provider to PAS Select Portfolios, will select certain affiliated mutual funds (BNY Mellon Funds) as part of the model construction recommendations to Park Avenue. This will result in BNY and its affiliates generally receiving significantly higher fees from BNY Mellon Funds than BNY would otherwise receive in utilizing other unaffiliated third-party mutual funds in the PAS Select Portfolios. PAS Foundational Model Portfolios PAS Foundational Model Portfolios offers five investment models with allocations across investment asset classes to create an asset allocation blend that may meet your investment objectives and Investor Risk Rating. PAS Foundational Model Portfolios are offered as asset allocation targets or sleeves in fulfilling UMA Select asset allocation models. For the Strategist Select Plus program, a single PAS Foundational Model Portfolio will be elected by you to fulfill your account allocation. Park Avenue has entered into an agreement with Janus Henderson Investors US LLC (JHI) for JHI to act as the model provider for PAS Foundational Model Portfolios. In its capacity as Model Provider, JHI will provide Park Avenue with non-discretionary investment advice in relation to the recommendation of the investment model securities. The JHI investment process that supports the management of PAS Foundational Model Portfolios (the “Models”) incorporates both strategic asset allocation (SAA) and tactical asset allocation (TAA) to align the Models with their stated investment objectives. SAA establishes long-term target weightings for investment asset classes based on factors such as expected return and risk. The SAA serves as the foundation for portfolio construction, ensuring diversification and alignment with stated investment objectives for the Models. TAA is also employed to make short- term adjustments to the Models’ asset allocation in response to changing market conditions. Portfolio construction for the Models is the process of selecting and weighting underlying investment vehicles (exchange-traded funds) based on the Models’ investment objectives, risk tolerances and the prevailing market conditions. Investment vehicle selection is conducted by JHI, which identifies proprietary and third-party ETFs that meet JHI’s selection criteria. Eligible investment vehicles for the Models are evaluated based on factors including 32 PAS017975 (4/2026)  management team experience, adherence to the stated investment process, historical performance, and risk management practices. Due diligence on the underlying investment vehicles is conducted regularly to monitor consistency and suitability across varying market environments. The underlying investment vehicles exhibiting signs of deterioration in the previously referenced factors are subject to further review for potential replacement. JHI, in acting in their capacity as a Model Provider to PAS Foundational Model Portfolios, will select certain affiliated funds (Janus Funds) as part of the model construction recommendations to Park Avenue. This will result in JHI and its affiliates generally receiving significantly higher fees from JHI ETFs than JHI would otherwise receive in utilizing other unaffiliated third-party funds in the PAS Foundational Model Portfolios. JHI provides Park Avenue compensation in the form of revenue sharing payments. These payments are calculated as an annual percentage of the amount of assets held by Park Avenue customers within JHI ETFs held within UMA Select, other Park Avenue Proprietary accounts, and Park Avenue Brokerage accounts. Park Avenue will receive revenue share compensation of 12 basis points (“bps”) on these assets. For example, if you hold a $10,000 JHI ETF, Park Avenue will receive $12 (plus revenue on earnings) from JHI per year. The receipt of these payments creates a conflict of interest as Park Avenue is incentivized to select JHI ETF in its PAS Foundational Model Portfolios (and other portfolios or strategies for which Park Avenue may be acting as a discretionary manager) as a result of receiving these revenue share payments rather than other investments or fund products that do not pay such revenue share payments. Further, as PAS Foundational Model Portfolios will select JHI ETFs as part of the model construction recommendations to Park Avenue, which provide revenue sharing payments, Park Avenue is incentivized recommend you hold PAS Foundational Model Portfolios rather than other UMA Select models that do not hold JHI ETFs, due to these payments. This conflict of interest is mitigated by the fact that IARs do not receive any additional compensation for recommending PAS Foundational Models with JHI ETFs than they would in recommending other models that would not pay such revenue sharing. In addition, Park Avenue maintains reasonable policies and due diligence procedures that evaluate the types of investments or funds utilized to make up the PAS Foundational Model Portfolios and also has reasonable policies and procedures to help ensure IAR recommendations and advice are in made in your best interest. Investing in securities involves risk of loss that clients should be prepared to bear. Clients may experience loss in the value of their account due to market fluctuations. There is no guarantee that a client’s investment objectives will be achieved by participating in any of the Programs described in this brochure. Prior to investing, clients should carefully read a copy of the current prospectus for each security, where a prospectus is available, or other offering documents associated with the particular investment. The prospectus or offering documents contain information regarding the fees, expenses, investment objectives, investment techniques, and risks of each particular investment. The investment returns on a client account will vary and there is no guarantee of positive results or protection against loss. No warranties or representations are made by Park Avenue or IARs concerning the benefits of participating in the Programs described in this brochure. Park Avenue and IARs do not provide legal or tax advice. Clients with tax or legal questions should seek a qualified independent expert. Depending on the types of securities you invest in, you may be subject to the following investment risks including, but not limited to: Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market risks. Credit Risk: also known as default risk, is the possibility that a bond issuer will not pay interest as scheduled or repay 33 PAS017975 (4/2026)  the principal at maturity. Credit risk may also be a problem with insurance companies that sell annuity contracts, where your ability to collect the interest and income you expect is dependent on the claims-paying ability of the issuing insurance company. Sociopolitical Risk: The possibility that instability or unrest in one or more regions of the world will affect investment markets. Terrorist attacks, war and pandemics are examples of events, whether actual or anticipated, that impact investor attitudes toward the market in general and result in system wide fluctuations in stock prices. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on discoveries of oil and then refining it, a lengthy process, before they can generate a profit. These companies carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of loss if the company is unable to meet the terms of its loan obligations. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Liquidity Risk: When consistent with a client’s investment objectives, guidelines, restrictions and risk tolerances, client portfolios may be invested in illiquid securities, subject to applicable investment standards. Investing in an illiquid (i.e., difficult to trade) security may restrict the ability to dispose of investments in a timely fashion or at an advantageous price, which may limit the ability to take full advantage of market opportunities. Accounts may hold securities which are partnerships. Some partnerships are relatively liquid and may be either exchange listed or traded over the counter. However, most partnership securities are often illiquid and are subject to significantly less regulation than public investments. Fixed Income Risks: Portfolios that invest in bonds and other fixed income securities are subject to certain risks, including but not limited to, interest rate risk, credit risk, prepayment risk and market risk, which could reduce the yield that an investor receives from his or her portfolio. Foreign and Emerging Markets Risk: Investments in securities of foreign and emerging markets issuers involve different investment risks than those affecting obligations of U.S. issuers. Public information may be limited with respect to foreign and emerging markets issuers, and they may not be subject to uniform accounting, auditing and financial standards and requirements comparable to those applicable to U.S. companies. Additional risks include future political and economic developments, the possibility that a foreign jurisdiction might impose or charge withholding taxes on income payable with respect to foreign and emerging markets securities, and the possible adoption of foreign governmental restrictions such as exchange controls. In addition, foreign currency exchange rates may affect the value of securities in the portfolio. High-yield Bond Risk: Investments in high-yielding, non-investment grade bonds involve higher risk than investment grade bonds. Adverse conditions may affect the issuer’s ability to make timely interest and principal payments on these securities. Structured Products Risk: These products often involve a significant amount of risk and should only be offered to clients who have carefully read and considered the product’s offering documents, as their structure may be based on derivatives or other types of securities, which may be volatile. Structured products are intended to be “buy and hold” investments and are not liquid instruments. 34 PAS017975 (4/2026)  Interval Fund Risk: Investors investing in interval funds are subject to certain risks, including but not limited to fund shares not being listed on a public exchange, the lack of secondary markets, liquidity being provided only through repurchase offers by the fund on a schedule stated within the product prospectus (i.e. quarterly offers), no guarantee that an investor will be able to sell all the shares that the investor desires to sell during repurchase offer periods. Investors should consider these investments to be of limited liquidity. In addition, investing in interval funds may be speculative and involves a high degree of risk, inclusive of the risks associated with leverage. Investors should carefully read the fund’s prospectus prior to investing in an interval fund. Derivatives Risk: Derivatives are securities whose price is dependent upon or derived from one or more underlying assets. The derivative itself is a contract between two or more parties. Its value is determined by fluctuations in the underlying asset. Derivatives may involve significant risks and are not suitable for everyone. Derivatives trading can be speculative in nature and carry substantial risk of loss, including the loss of principal. Small/Mid Cap Risk: Stocks of small or mid-sized, emerging companies may have less liquidity than those of larger, established companies and may be subject to greater price volatility and risk than the overall stock market. Diversification Risk: Investments that are concentrated in one or few industries or sectors may involve more risk than more diversified investments, including the potential for greater volatility. Security Selection and Asset Allocation Risk: Securities selected from a particular asset class (e.g., stocks, bonds, money market instruments) may experience unusual market volatility or may not perform as expected. An asset allocation program does not guarantee achievement of a client’s investment objective nor protect against loss. ETF Risk: ETFs are subject to the following risks:(i) the market price of an ETF’s shares may trade above or below the net asset value; (ii) there may be an inactive trading market for an ETF; (iii) the ETF may employ an investment strategy that utilizes high leverage ratios; (iv) trading of an ETF’s shares may be halted, delisted, or suspended on the listing exchange; and (v) the ETF may fail to achieve close correlation with the index that it tracks. Real Estate Risk: Investment in real estate and real estate related assets is subject to the risk of adverse changes in national, state, or local real estate conditions (resulting from, for example, oversupply of or reduced demand for space and changes in market rental rates); obsolescence of properties; changes in the availability, cost, and terms of mortgage funds; and the impact of tax, environmental and other laws. Directed Brokerage Clients in the Programs must establish an account through Park Avenue with Pershing, which clears trades and acts as custodian for clients’ assets under the Programs. Accordingly, all trading activity in connection with the Programs will be processed through clients’ accounts with Pershing. Pershing acts in the capacity of a clearing firm and performs centralized custody, bookkeeping and execution functions. Pershing handles the delivery and receipt of securities purchased or sold on behalf of Park Avenue’s clients who are part of the Programs, receives and distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender offers, and redemptions. Not all investment advisory firms will require their clients to direct brokerage. By directing brokerage, Park Avenue may be unable to achieve most favorable execution of your transactions, and this practice may cost you more money. Best Execution Investment advisers are obligated to provide “best execution” of customer orders where the adviser has the responsibility to select broker-dealers to execute client trades. “Best execution” refers to using reasonable diligence to seek to obtain the best price to buy or sell a security under prevailing market conditions. Park Avenue does not select other broker-dealers for processing of client transactions. Park Avenue must transmit all trades to Pershing for execution. Park Avenue’s objective in executing client trades is to obtain the most favorable execution and to aggregate and allocate trades fairly and equitably across all its clients. Park Avenue has adopted policies and procedures that are designed so that trading practices do not unfairly or systematically favor one client, group, or 35 PAS017975 (4/2026)  strategy over another. Park Avenue regularly receives reports from Pershing which contain information regarding the trade order execution experience of Pershing for all of its customers. Park Avenue undertakes an on-going review of its relationship with Pershing, including a quarterly review of trade order flows. Investment Managers in the SMA and UMA Select programs may not utilize Envestnet to facilitate certain trades within their strategies and consequently the use of these strategies may result in the additional trade-away fees that are not included in the Program fee, or that may be in addition to the Park Avenue wrap fee. Clients should consult with their IARs and review the Investment Manager’s Form ADV Part 2A for information related to any additional fees. Clients should carefully consider any additional trading costs the Client may incur before selecting an Investment Manager. Soft Dollars Soft dollars are defined as arrangements under which products or services other than the execution of securities transactions are obtained by an adviser from or through a broker-dealer in exchange for the direction of securities trades to the broker-dealer. Park Avenue does not have any soft dollar arrangements. Order Aggregation Park Avenue IARs generally manage their client’s accounts independently of one another based on each client’s specific needs and objectives, and transactions for each client account are often executed independently. Although each account is individually managed, Park Avenue may buy and sell the same securities for many advisory accounts simultaneously. In the Signature Portfolio Program, IARs will often aggregate the purchase or sale of multiple clients’ securities together to help facilitate best execution and provide each client with the same execution price. Aggregating multiple client orders together is particularly useful when Park Avenue or your IAR is utilizing model portfolio management strategies (multiple client accounts in the same model). IARs servicing accounts invested in the Signature Portfolio Program may determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, and the liquidity of the securities purchased or sold. If IARs do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. Park Avenue may aggregate transactions in the same security for many clients for whom Park Avenue has discretion to trade. If different prices are paid for securities in an aggregated transaction, each client in the transaction will receive the average price paid for the block of securities in the same aggregated transaction. If the client trade is aggregated with other client accounts and are executed at the same price, the client will receive the same price per unit. If we are not able to completely fill an aggregated transaction, we will normally allocate the filled portion of the transaction to our clients on a pro-rata basis. Park Avenue SMA and UMA Select Trade Allocations Some Investment Managers will not place Envestnet Strategies in the same trade rotation as their non-Envestnet models or proprietary accounts. If Envestnet determines that such trade rotation policy does not provide equitable investment performance between the models and is creating a disadvantage to the client, Envestnet may restrict the availability of the Investment Manager or impose additional requirements, as necessary. Certain trade orders are created by the Investment Manager and sent directly to the appropriate custodian according to their own trade rotation policies. If the Investment Manager directs Envestnet to allocate orders within each custodian, the partial fill will be allocated pro-rata among the individual Client accounts. Investment Managers may aggregate Client trades with their own directed trades or trades for other Clients. Please refer to each Investment Manager’s Form ADV and Envestnet’s ADV for any policies they may have regarding aggregation of trades. 36 PAS017975 (4/2026)  Voting Client Securities As a matter of firm policy and practice, Park Avenue generally does not vote proxies on behalf of advisory clients. Envestnet generally delegates proxy voting to the Sub-Managers to whom it allocates client assets. However, for Programs in which Envestnet is providing overlay management services, Envestnet is responsible for voting proxies relating to securities held by clients. Clients have the option of informing Envestnet that they wish to have the responsibility for receiving and voting proxies for any and all securities maintained in their portfolios. For additional information, refer to Envestnet Asset Management, Inc.’s Form ADV Part 2A. Clients investing in Models within the UMA Select and Strategist Select Plus programs where Park Avenue acts as Investment Manager and/or Strategist (PAS Select Portfolios and PAS Foundational Model Portfolios), retain the responsibility for receiving voting materials and voting for any and all securities maintained within the Models. 7. Client Information Provided to Portfolio Managers Investment Managers and Strategists will have access to your risk tolerance and any client-imposed restrictions on management of assets. Park Avenue and its IARs will have access to your (i) account opening documents, which include, among other things, your investment objective, risk tolerance and any client-imposed restrictions on management of assets; (ii) online access to the account; (iii) confirmations; (iv) account statements; and (v) each client’s quarterly performance reports. 8. Client Contact with Portfolio Managers There are no restrictions placed on clients’ ability to contact and consult with their Park Avenue IARs regarding the Programs. 9. Additional Information Disciplinary Information The following is a chronological summary of material disciplinary events relating to Park Avenue Securities, LLC. (“PAS”) and its management personnel in the last 10 years. 11/18/2016 – In connection with the misappropriation of funds from two customers by an unregistered sales assistant, FINRA censured and fined PAS $195,000 in its capacity as a broker-dealer for failing to enforce its written supervisory procedures regarding the monitoring of customer trades and for failing to establish and maintain a supervisory system reasonably designed to follow up on the performance of its supervisors with regard to monitoring trade executions, in violation of NASD Rules 3010(a), 3010(b) and FINRA Rule 2010. FINRA noted, PAS also failed to establish, maintain, and enforce a supervisory system reasonably designed to review and monitor the transmittal of funds from the accounts of its customers to third party accounts and outside entities, in violation of NASD Rules 3010, 3012(a)(2)(B)(i) and FINRA Rule 2010. 4/11/2018 – FINRA censured and fined PAS $300,000 in its capacity as a broker-dealer for failing to implement a supervisory system and written supervisory procedures reasonably designed to train and supervise Registered Representatives’ recommendations regarding the sale of multi-share class variable annuities, including L-Share contracts, to ensure their suitability. FINRA also found that PAS had no surveillance procedures to determine rates of variable annuity exchanges. FINRA found the foregoing to be in violation of NASD Rule 3010 and FINRA Rules 2330, 3110 and 2010. 3/11/2019 – PAS without admitting or denying the findings, consented to the entry of an Order Instituting Administrative and Cease and-Desist Proceedings (“Order”) by the U.S. Securities and Exchange Commission (“SEC”). Pursuant to the Order, the SEC found that from January 1, 2014 through October 31, 2018 certain PAS 37 PAS017975 (4/2026)  clients participating in proprietary advisory programs were invested in mutual fund share classes with higher costs (in the form of Rule 12b-1 fees) without adequately disclosing that lower-cost share classes (without Rule 12b-1 fees) of those funds were available. Specifically, PAS did not adequately disclose conflicts of interest related to its receipt of Rule 12b-1 fees, and the availability of mutual fund share classes that did not pay such fees. PAS consented to the entry of the Order that it violated Sections 206(2) and 207 of the Investment Advisers Act of 1940 and agreed to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 207. PAS agreed to pay disgorgement of $508,083 and prejudgment interest of $56,184 to affected clients. Additionally, as part of the Order, PAS has enhanced its disclosure regarding mutual fund share class selection, considered whether existing clients should be moved to a lower-cost share class, and updated its policies and procedures regarding mutual fund share class selection. 7/16/2019 – PAS without admitting or denying the findings, was censured by the Financial Industry Regulatory Authority (“FINRA”) in its capacity as a broker-dealer for failing to reasonably supervise the application of sales charge waivers for mutual fund purchases made by certain retirement plan and charitable organization customers. By failing to reasonably supervise such mutual fund sales to ensure that eligible purchasers received the benefit of applicable sales charge waivers, FINRA found that PAS violated NASD Conduct Rule 3010 (for misconduct before December 1, 2014), FINRA Rule 3110 (for misconduct on or after December 1, 2014 and FINRA Rule 2010. As part of this settlement, PAS agreed to pay restitution to eligible customers on the terms specified below, in the amount of $640,552 (i.e., the amount eligible customers were overcharged, inclusive of interest). PAS also agreed to ensure that waivers are appropriately applied to all future purchase transactions made by retirement plan and charitable organization customers. FINRA recognized the extraordinary cooperation of PAS for initiating an investigation prior to detection or intervention by FINRA to identify whether applicable customers received sales charge waivers, for promptly establishing a plan of remediation to customers and taking action to correct the violative conduct. 5/31/2023 – In connection with an undisclosed outside business activity of a PAS Registered Representative, PAS, without admitting or denying the findings, agreed to a Letter of Acceptance, Waiver, and Consent with FINRA for the purpose of settling alleged FINRA rule violations. PAS was censured and fined $30,000 by FINRA for violating FINRA Rule 3110 by failing to investigate red flags that the Representative was engaged in an undisclosed outside business activity, unapproved private securities transactions and FINRA Rule 2010. 9/24/2024 – PAS, without admitting to or denying the findings, was censured by the Financial Industry Regulatory Authority (“FINRA”) in its capacity as a broker-dealer for failing to reasonably supervise mutual fund share class recommendations to retirement plan customers, from January 2019 through July 2021. FINRA found that PAS’ supervisory system and WSPs were not reasonably designed to achieve compliance with FINRA Rule 2111 or the Care Obligation of Regulation Best Interest. As part of this settlement, FINRA issued a $125,000 fine. PAS paid restitution to eligible customers in 2022 in the amount of $91,344, which was the amount eligible customers were overcharged, inclusive of interest. Other Financial Industry Activities and Affiliations Park Avenue Securities, LLC (“PAS”), doing business under marketing name Park Avenue® Wealth Management, 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. PAS is an affiliate of The Guardian Insurance & Annuity Company, Inc. (“GIAC”), a Delaware insurance company. PAS is also an affiliate of Guardian Wealth Partners, LLC (“GWP”) and Park Avenue Institutional Advisers, LLC (“PAIA”), SEC registered investment advisers. GWP and PAIA are indirect wholly owned subsidiaries of GLIC. PAS or its IARs may recommend mutual funds whose investment adviser is a PAS affiliate, such as PAIA. PAIA is the sub-adviser to certain mutual funds offered by Victory Capital. Therefore, we have an incentive and conflict to recommend certain products which are managed by PAIA due to the additional compensation earned by such affiliate. In addition, PAS makes available alternative investment funds issued by Hamilton Lane Advisors, LLC (“Hamilton Lane”). PAS’ parent company, GLIC, has appointed Hamilton Lane to manage a portfolio of GLIC’s general account and in exchange has obtained warrants from 38 PAS017975 (4/2026)  Hamilton Lane. These warrants may be exercised in shares of Hamilton Lane, cash, or a combination of shares of Hamilton Lane and cash. While not considered a proprietary investment, the warrants issued by Hamiton Lane to GLIC creates a similar conflict. Many IARs of PAS are also agents of GLIC and GIAC and may sell a wide range of products issued by those entities, such as life insurance and variable annuities. IARs receive no additional compensation for recommending insurance products issued by affiliates or mutual funds managed by affiliates than they would if they recommend insurance products or mutual funds issued by or managed by non-affiliates. An IAR may have an incentive to recommend a particular Proprietary Investment Advisory Program or Third-Party Investment Advisory Program in favor of another because of the receipt of higher fees or non- cash benefits such as additional services which include marketing support and training provided by the sponsor of the Third-Party Advisory Program. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Park Avenue has adopted a code of ethics (“Code of Ethics”) for all supervised persons of the firm, which governs the ethical standards of conduct and securities trading by supervised persons. The Code of Ethics includes provisions relating to, among other things, a prohibition on trading on the basis of material non-public information or confidential information, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons of Park Avenue must acknowledge the terms of the Code of Ethics annually. Park Avenue will provide a copy of the Code of Ethics to any client or prospective client upon request. It is Park Avenue policy that the firm generally will not affect any principal or agency cross transactions for client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to an advisory client. Park Avenue may engage in principal transactions only in limited circumstances where it elects to buy “worthless securities” out of client accounts in order to facilitate the liquidation of such positions. Park Avenue also will not permit agency cross transactions between client accounts. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Review of Accounts At account opening, Park Avenue, through its IARs, gathers information from a client about that client’s financial situation, risk tolerance, investment objectives, and any reasonable restrictions that the client wishes to impose upon the management of the account. Each IAR periodically reviews reports and otherwise consults with the client and contacts the client to review the client’s financial situation and investment objectives. You should notify your IAR of any changes in your financial situation, risk tolerance, investment objectives or account restrictions. Park Avenue employs individuals who are registered with the Financial Industry Regulatory Authority (“FINRA”) as principals (the “Registered Principals”), who review all accounts for suitability. Accounts are reviewed by the Registered Principals prior to being opened. Park Avenue Proprietary Program accounts are monitored on an ongoing basis by Registered Principals. Park Avenue monitors and tracks all financial planning and consulting. All financial plans must be submitted to Park Avenue for review and approval prior to presentation to a client. If the plan or consultation is approved, the plan or consultations may be presented to the client. Park Avenue provides each client with a quarterly written performance report. Performance information is calculated for all portfolios custodied at Pershing. The quarterly analysis measures performance of the account by comparing 39 PAS017975 (4/2026)  such performance against relevant market indices. Custody Although Park Avenue’s Proprietary Program Account assets are held by a qualified custodian, Park Avenue is deemed to have custody of client funds because it has the ability to direct such custodians to deduct advisory fees from the client’s account and because some client accounts have standing letters of instruction (“SLOAs”) or other similar asset transfer authorization agreements which gives us the authority to transfer funds to a third-party. Client Referrals and Other Compensation Park Avenue and/or its IARs may receive compensation pursuant to promoter agreements for introducing clients to the Third-Party Investment Adviser and for providing certain ongoing services. This compensation is typically equal to a percentage of the investment advisory fee charged by that investment adviser. Because IARs receive compensation from these investment advisers for referring clients and because such compensation may differ depending on the individual agreement with each investment adviser, the IAR may have an incentive to recommend one of these Third-Party Investment Advisers over another with which Park Avenue has a less favorable compensation arrangement or alternative investment advisory programs. Full disclosure of all promoter arrangements, including Part 2 of Form ADV and a promoter’s disclosure statement, will be given to the client at the time of referral. Park Avenue has arrangements with a number of individuals (“Promoters”) under with the Promoters introduce potential advisory clients to Park Avenue in exchange for a referral fee. Whenever Park Avenue pays a referral fee, we require the prospective client to receive a copy of this Brochure and a separate disclosure statement that includes the following information: (1) the Promoter’s name and relationship with Park Avenue; (2) the fact that the Promoter is being paid a fee; (3) the amount of the fee; and (4) whether the fee paid to us by the client will be increased above our normal fees in order to compensate the Promoter. In general, the advisory fees paid to us by clients referred by Promoters are not increased because of a referral. Other Compensation and Conflicts We have an incentive to recommend the product or account type that results in additional fees and revenues for us. We can recommend that you invest through different account type arrangements, such as through a brokerage account, an account directly held with the issuer of the investment (or its transfer agent), or an advisory account. Depending on factors such as the type and level of services you require as well as the frequency of trading in your account, one of these account types may be more cost-effective for you than the others. In addition, we receive miscellaneous account and service fees and other compensation (which are in addition to advisory fees) in connection with brokerage accounts or advisory accounts that we do not receive with a directly held account. We can also recommend that you invest in products that have higher up-front compensation along with ongoing trail payments. The availability of different products and account types incentivizes us and our IARs to recommend the product or account type that results in additional fees and revenues for us and your IAR even though another type of account may be more cost-effective for you. How We Address Certain Compensation Related Conflicts of Interest  Park Avenue discloses potential conflicts of interest to clients through documents such as this disclosure document, disclosures on our website and other materials discussing the products and services offered.  Park Avenue credits 12b-1 fees and service fees from mutual funds, other than those associated with the Cash Management Sweep Program, and all FundVest® program fee payments to client accounts within Park Avenue Proprietary Programs.  Park Avenue IARs do not receive any portion of the payments Park Avenue receives under the agreement between Park Avenue and Pershing.  Park Avenue IARs do not receive any portion of the revenue received from mutual fund compensation arrangements, or mutual 12b-1 fees/service fees. Park Avenue does not include within these revenue sharing arrangements assets held within plans covered by Title I of ERISA, or a plan described in Section 4975€(1) of 40 PAS017975 (4/2026)  the Internal Revenue Code. Listed below are potential additional payments that Park Avenue may receive and the potential conflicts of interest they create. You should consider these potential conflicts of interest prior to investing in the Park Avenue Proprietary Programs as the receipt of such payments provides a financial incentive for Park Avenue to recommend Park Avenue Proprietary Programs over Third-Party Advisory Programs. Pershing Additional Payments Through an agreement with Pershing, Park Avenue earns the following payments from Pershing. These payments are not applicable to clients of Third-Party Advisory programs. 1) Park Avenue receives a recurring fixed payment from Pershing annually on the total dollar value of legacy assets transferred from Park Avenue’s previous custodian. 2) Park Avenue receives payments from Pershing on the total amount of assets in client accounts placed on the Pershing custodial platform annually, and for asset growth year over year, which shall also include assets of Park Avenue’s affiliate, Guardian Wealth Partners. This payment excludes the total dollar value of legacy assets transferred from Park Avenue’s previous custodian. The receipt of such payments from Pershing provides a financial incentive for Park Avenue to recommend Park Avenue Proprietary Programs over Third-Party Advisory Programs. 3) Park Avenue receives an annual fixed technology allowance credit in the amount of $200,000 for reasonable and documentable costs incurred by Park Avenue in association with the implementation of technology solutions provided by Pershing, its affiliates and/or other third party providers. 4) Park Avenue receives an annual discretionary fee allowance credit in the amount of $200,000 for Pershing related fees Park Avenue would like to absorb through this credit. 5) Park Avenue earns interest payments on non-purpose loans that have interest rates above the Federal Funds Rate +1.75%. For example, if the interest rate on a non-purpose loan is 5% and the Federal Funds is 3%, Park Avenue will earn .25% of what a client pays (5%-4.5%). The receipt of such payments provides a financial incentive for Park Avenue to recommend and approve non-purpose loans. 6) Pershing agrees to share certain service fees received by Pershing from mutual funds that participate in the FundVest® program. The FundVest® program is an open architecture platform of mutual funds and no- transaction fee mutual funds offered by Pershing. These mutual funds are offered within Park Avenue Proprietary programs. The percentage of service fees Pershing shares with Park Avenue is based on the level of assets held by Park Avenue clients within the FundVest® program and generally ranges between 50-55% of such services fees received by Pershing from participating mutual funds. Furthermore, Park Avenue addresses this conflict by crediting back all FundVest® program fee payments that it receives to clients invested in the Park Avenue Proprietary Programs. For additional details about Pershing’s mutual fund no-transaction-fee program, or a listing of funds that pay Pershing networking or omnibus fees, please refer to www.pershing.com/mutual_fund.htm. 7) Park Avenue has an incentive to have IARs recruited to us transfer their client accounts to Park Avenue because Pershing provides us with rebates for such account transfers. Pershing will reimburse us for out-of- pocket expenses associated with transfer and termination fees upon the successful onboarding of a newly hired IAR who transitions their client accounts from a financial services firm that does not clear through our clearing firm. Dreyfus Insured Deposits Program For the DIDV Bank Sweep each month, depository institutions pay a fee (“Deposit Fee”) equal to a percentage of the average daily deposit balance in your deposit account(s) at the banks participating in the program (“Program Banks”) to Park Avenue, Pershing, and a third-party administrator. The fee paid to Park Avenue will not exceed 600 basis points (6%) on an annualized basis over a rolling 12-month period. The combined fee paid to Park Avenue, Pershing, and the third-party administrator will not exceed 675 basis points (6.75%) on an annualized basis on the average daily balances held in these deposit accounts over a 12- month rolling period. Park Avenue has discretion in determining the size of the portion of the fee it receives. This directly negatively impacts the interest rate yield client deposits will receive. Park Avenue may waive any portion or the entirety of its share of the fee received from 41 PAS017975 (4/2026)  Program Banks. Your IAR will not receive any portion of the fees paid to Program Banks. The amount of fee received by Pershing, Park Avenue, and any other service provider, will affect the interest rate paid in your deposit account(s). Other than applicable fee imposed by Park Avenue on your account (including fees charged on your Pershing, LLC IRAs) there will be no additional charges, fees, or commissions imposed on your account with respect to the DIDV Bank Deposit Sweep. In order to illustrate the effect of the interest retained by Pershing, Park Avenue and the administrator of the program please consider the following example. If the DIDV sweep is earning a gross interest rate yield of 2% and Park Avenue, Pershing, and the administrator retains 1.65% for administration, then the client rate would be .35%. The receipt of this fee creates an incentive for Park Avenue to select DIDV as the default cash sweep vehicle for the clients who do not select a Money Market Sweep vehicle or have an account which is automatically defaulted to DIDV, as it will result in additional compensation to Park Avenue. In addition, Park Avenue’s discretionary authority in determining its share of the fee creates a conflict of interest due to Park Avenue’ receipt of the fee, which in turn, negatively impacts the interest rate yield client deposits will receive. As disclosed in the Cash Management Sweep Program section, the overflow Money Market Sweep products pay a distribution to Park Avenue which will not be credited to your account. Park Avenue IARs do not receive any portion of the distribution fee and therefore do not have a conflict in recommending a Cash Management Sweep product which pays a distribution. You are encouraged to speak to your IAR regarding the Cash Management Sweep Program vehicle used for your account. Payments from Mutual Funds  Park Avenue receives Rule 12b-1 fees based on client investments in certain mutual funds. Rule 12b-1 fees are annual marketing or distribution fees on a mutual fund. The 12b-1 fee is considered an operational expense and, as such, is included in a fund’s expense ratio Except for 12b-1 fees generated by mutual funds associated with the Cash Management Sweep Program, Park Avenue Proprietary Program accounts will be rebated any 12b-1 fees generated by mutual fund investments within accounts. IAR Additional Compensation Paid by Park Avenue IARs who have a certain level of client assets invested in Park Avenue Proprietary Program accounts will, at the discretion of Park Avenue, receive additional compensation payments from Park Avenue. The receipt of these payments does not impact your Total Client Fee, however, it will incentivize these IARs to recommend a Park Avenue Proprietary Program account to you rather than a Third-Party Investment Advisory Program or other wealth management solution program that would not result in the payment of additional compensation to the IAR based on a level or total amount of client assets within such program. In addition, the calculation of these additional compensation payments will differ between Park Avenue Proprietary Programs resulting in differing amounts of payments to the IAR depending on the invested assets per Park Avenue Proprietary Program. This differential will incentivize IARs to recommend one Park Avenue Proprietary Program over another Park Avenue Proprietary Program. Therefore, the IARs and Park Avenue have a conflict of interest given their financial incentive to recommend that you participate in the Park Avenue Proprietary Programs and services that provide them with the highest rate and amount of overall compensation and benefits, and increase your assets under management in those programs, rather than other available programs and services that result in their receipt of lower or no additional compensation and benefits such as Third-Party Investment Advisory Programs for which IARs do not receive certain additional benefits. Further, Park Avenue and IARs have a conflict of interest as a result of their financial incentive to recommend the Park Avenue Proprietary Programs for which they can negotiate and receive the highest or relatively higher compensation. We address these conflicts of interest by disclosing them to you and requiring that there be a review of your account and transactions at account opening and periodically to determine whether they are appropriate and remain appropriate and in your best interest in light of your investment objectives, financial circumstances, and other characteristics. 42 PAS017975 (4/2026)  Guardian Club Credits Certain IARs may receive “Club Credits” for the recommendation of Park Avenue Proprietary Programs, Third-Party Investment Advisory Programs or Financial Planning/Consulting. These “Club Credits” are based upon sales production and count towards the attainment of various GLIC club memberships. Attainment of various club memberships may entitle IARs to attend GLIC-sponsored conferences. Park Avenue Securities VIP Program Certain IARs will qualify to receive service and financial support, as described in more detail below, based upon their overall sales production. The top 100 Park Avenue sales agents qualify for the VIP program. The qualifications to achieve VIP status are based upon total sales production or Gross Dealer Concession (“GDC”). GDC is the revenue generated via agent sales of brokerage products (i.e., stocks, bonds, mutual funds) and advisory services (i.e., Proprietary Programs, Third Party Investment Advisory Programs and Financial Planning/Consulting). The attainment of this VIP status entitles an IAR to receive a dedicated support person called a Relationship Manager, full or partial waiver of state registration fees and Park Avenue affiliation fees, and “Select Rewards Points.” The “Select Rewards Points” can be used to cover the cost of client account maintenance fees, termination fees, and/or service fees such as fed wire or overnight check fee. The decision to cover certain client costs is at the discretion of your Park Avenue IAR and not all clients will receive this benefit. Park Avenue Securities Pinnacle Council IARs are also eligible to qualify for a club award program called Pinnacle Council. To qualify for Pinnacle Council, an agent must be in the top 20 for total sales production based on the prior year GDC. The benefits of this club award include attendance at an annual recognition conference with paid travel accommodations (i.e., flight and hotel) and meals for the PAS Pinnacle Council qualifier and one guest. These programs could create a conflict of interest by an IAR recommending certain products in attempt to qualify for these additional clubs and awards. Park Avenue Securities Peak Council IARs are also eligible to qualify for a club award program called Peak Council. To qualify for Peak Council, an agent must be in the top 40 (21-40) for total sales production based on the prior year GDC. The benefits of this club award include attendance at an annual recognition conference with paid travel accommodations (i.e., flight and hotel) and meals for the PAS Peak Council qualifier and one guest. These programs could create a conflict of interest by an IAR recommending certain products in attempt to qualify for these additional clubs and awards. Transitional Assistance Program (TAP) Park Avenue may offer some recruits the opportunity to obtain bonuses and loans that are dependent upon meeting sales targets. These transition assistance loans may also be forgiven based on years of service with Park Avenue, or its affiliates, assets under management, the amount of production with Park Avenue or its affiliates or the number of clients brought over to Park Avenue. This practice creates a conflict of interest as it provides a financial incentive for an RR or IAR to recommend that a client engage Park Avenue for advisory or brokerage services, and to recommend additional products from Park Avenue or its affiliates. Moreover, some recruits may obtain “early asset bonuses” if they transfer certain percentages of assets to our Firm. If an RR or IAR has received a transition loan, they are incentivized to encourage the transfer of your account to our Firm so that bonuses can be earned. This conflict is especially acute as your IAR approaches his or her milestone date. The Park Avenue Transition Team will work with an RR or IAR to ensure a successful transition by providing 43 PAS017975 (4/2026)  everything from a customized transition plan, tailored training, account opening and account transfer support. The level of support and service received is dependent upon the RR or IARs trailing twelve-month GDC with their prior firm. In addition, if the prior firm does not clear through Pershing, Pershing will reimburse transfer and termination fees up to $125.00 to each client account. Transitional assistance presents a conflict of interest because of the incentive to affiliate with and recommend Park Avenue to clients. Private Client Group At their discretion, Park Avenue IARs may identify certain clients based on the amount of assets in either or both the Park Avenue Proprietary Investment Advisory Programs or Park Avenue broker-dealer accounts for participation in the Private Client Group program. Private Client Group clients will receive certain benefits which are not available to clients who are not selected for the program. These benefits include but are not limited to access to educational and exclusive private events, discount programs unrelated to services or products offered by Park Avenue as a broker- dealer/registered investment adviser, and specialized Park Avenue services. Many of the services offered by the Private Client Group are also available to clients who are not in the program. Park Avenue IARs have an incentive to select certain clients who have more assets with Park Avenue over other clients who do not have as many assets with Park Avenue. This creates a conflict of interest for Park Avenue and its IARs and incentives clients to maintain a certain level of assets at Park Avenue as well as increase their assets in attempt to qualify for these benefits and services which would generate higher advisory or broker-dealer transactional fees. Not all clients who meet the asset thresholds for membership will be offered invitations to the Private Client Group as invitation is at discretion of the Park Avenue IAR. Payments Related to Park Avenue Educational/Practice Management Conferences iCapital *First Trust Inland Capital Certain product sponsors and vendors pay Park Avenue a fee ranging from $40,000 to $172,000 to participate in Park Avenue sponsored educational/practice management conferences for Park Avenue IARs. In 2026, Park Avenue anticipates it will receive fees from the following:  BlackRock  State Street Global Advisors  Clark Capital  City National Rochdale  Halo   Capital Group/American Funds   Fidelity   Allianz  BNY Mellon  Brighthouse  Jackson  Lincoln  Nationwide  Prudential  Transamerica *First trust will pay Park Avenue the greater of $100,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. See section Revenue Sharing Payments for a description of revenue sharing. Other Compensation (Park Avenue Proprietary & Third-Party Advisory Programs) 44 PAS017975 (4/2026)  Third-Party Advisor Payment Arrangements Park Avenue receives payments from SEI, Orion, and AssetMark as compensation for marketing and administrative services as follows:  SEI pays Park Avenue a flat annual fee. The fee for 2026 is $548,000.  Orion pays Park Avenue a flat annual fee for training and educating Park Avenue IARs. The fee for 2026 is $320,000.  AssetMark pays Park Avenue a flat annual fee. The fee for 2026 is $1,000,000. o OBS, who is owned by AssetMark, pays Park Avenue a flat annual fee. The fee for 2026 is $88,000. You should also be aware that marketing or educational activities paid for with these payments by these sponsors and vendors lead to greater exposure of their products and services with Park Avenue IARs. Therefore, these payments may create an incentive, or lead to a greater likelihood, for Park Avenue or its IARs to recommend a product of these sponsors and vendors over the products or services of a firm which does not pay Park Avenue a fee. Revenue Sharing Payments Certain product sponsors pay Park Avenue additional compensation in the form of revenue sharing. These revenue sharing payments are calculated as an annual percentage of the amount of assets held by Park Avenue customers within sponsor products. Park Avenue may receive compensation of up to 25 basis points (“bps”) on these assets. For example, if you hold a $10,000 position with a sponsor that provides Park Avenue a 25bps payment, Park Avenue will receive $25 from that sponsor. *HPS **First Trust The following product sponsors provide Park Avenue revenue sharing payments:  Open VC., Inc.  CION Ares Management  Hamilton Lane  The Carlyle Group  Janus Henderson   Pimco (Alternative Funds Only)   Allianz  Brighthouse Life Ins.  Equitable  Jackson National  Lincoln Financial  Nationwide  Prudential  Transamerica ***Redbrick  *HPS will pay Park Avenue the greater of $200,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. **First trust will pay Park Avenue the greater of $100,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. ***Redbrick will pay Park Avenue 25 basis points on new sales rather than assets held by Park Avenue customers when Park Avenue customers purchase Redbrick products. Receipt of revenue sharing payments creates a conflict of interest as Park Avenue is incentivized to sell you or recommend you hold investments that provide Park Avenue with such payments rather than investments that do not. In addition, as the payments differ by product sponsor, Park Avenue is incentivized to sell you 45 PAS017975 (4/2026)  or recommend you hold investments that provide a higher revenue sharing payment rate than investments that pay Park Avenue a lower revenue sharing payment rate. This conflict of interest is mitigated by the fact that IARs do not receive this firm-paid additional revenue sharing compensation from the product sponsors that provide Park Avenue these revenue sharing payments, and that the firm maintains reasonable policies and procedures to help ensure recommendations are in your best interest. Third Party Payments For some investments you purchase based on our recommendation, we receive payments from a third- party that are in addition to the advisory fee payments described in this document. For example, certain mutual fund issuers make ongoing payments based on invested assets (and not just new investments), such as 12b-1 fees, shareholder servicing fees or trail compensation. These third-party payments are described in further detail in the prospectus or offering materials for the investment, which will be made available to you in connection with any purchase. These third-party payments incentivize us and your IAR to sell you or recommend you hold investments that bring about such payments rather than investments that do not or result in comparatively lower payments. To mitigate this conflict and as discussed more within this Brochure, Park Avenue credits back to clients invested in Park Avenue Proprietary Program Accounts mutual fund 12b-1 and other service fees it would otherwise receive from mutual fund products, except those generated by the Cash Management Sweep Program. There may be instances where the portfolio managers our IARs recommend periodically pay us based on the total amount of customer assets we direct to them. These payments are sometimes called “revenue sharing” payments and incentivize us to recommend you hold investments that entail such payments rather than investments that do not entail these payments or entail comparatively lower payments. Some third-party portfolio managers may also make payments to us to cover the costs associated with certain educational conferences or training seminars we host for our IARs and to be allowed to present their products during such conferences and seminars. These payments are typically for fixed amounts and are not tied to total sales or customer assets. Even so, these payments incentivize us to recommend you hold investments by these managers that make these flat payments rather than managers that do not make these payments or make comparatively lower payments. Other IAR Conflicts The individual office managers/supervisors are paid based on the performance of the branches or regions they supervise. Our managers and supervisors oversee the sales and marketing activities of our Firm. The compensation of our managers and supervisors is tied to the production levels of branches or regions over which they have managerial or supervisory responsibility. The tying of managers’ and supervisors’ compensation to the production of the branches or regions they supervise incentivizes them to spend more time on increasing production levels in each branch or region than on their supervisory responsibilities. Some of our IARs receive additional training and support from certain Strategist and Third Party Investment Advisers (“Managers”). Certain Managers and their affiliates provide some of our IARs or their branches with more training and administrative support services than others. If your IAR receives this additional training and support, his or her use of these Managers’ higher level of training and administrative support services incentivizes your IAR to recommend Managers that provide such training and services over issuers that do not. Some of our IARs receive compensation in the form of non-cash compensation or other gifts from vendors or product sponsors to assist with, and defray the expenses associated with educational seminars and client events held by the IAR or a branch office. At times, the amount of compensation provided to a IAR or branch may be dependent on volume of business that individual or branch has attained. IARs may also receive business entertainment from vendors or product sponsors with whom they interact or are authorized to do business. Entertainment engagement may be based on the amount of business placed with the vendors or product sponsors and may incentivize the IAR to place business with that vendor or product sponsor. IARs who are also representatives of the Firm’s parent company, Guardian Life Insurance Company of America, receive employee benefits (i.e., health and pension benefits) that are subsidized by Guardian if the IAR reaches 46 PAS017975 (4/2026)  certain sales targets. This subsidization program creates a conflict of interest as it encourages more sales that result in your Financial Professional meeting these sales targets to obtain additional subsidies. Some IARs have outside business activities that compete for their time or may influence their recommendations. If your IAR engages in any outside business activities, these activities can incentivize your IAR to spend more time on the outside business activity rather than his or her advisory relationship with you. In addition, if the outside business activity provides your IAR a higher rate of compensation, your IAR can be incentivized to recommend the outside business activity rather than a brokerage or advisory service offered by Park Avenue. You may research any outside business activities your IAR may have on FINRA’s BrokerCheck website at https://brokercheck.finra.org/. Certain IARs may enter into loans or other lending arrangements in order to expand their own business or purchase other books of business. When IARs enter into these lending arrangements the debt incurred can otherwise impact the IAR’s overall compensation received throughout any particular time-period. The amount of debt incurred and these lending scenarios could influence the manner in which the IAR attempts to earn additional transactional-based commissions when acting in their capacity as a registered representative of Park Avenue (commissions paid for the recommendation and sale of securities products) or investment advisory fees when acting in their capacity as an IAR (investment advisory fees for the ongoing advice provided to you) in order to meet their own personal debt obligations which may also indirectly influence their advice and recommendations made to you as their client. Financial Information Park Avenue does not have any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients. 47 PAS017975 (4/2026) 

Park Avenue Securities LLC 10 Hudson Yards, New York, NY 10001 Phone: 888-600-4667 Web: www.ParkAvenueSecurities.com April 23, 2026 Firm Brochure This firm brochure (“Brochure”) provides information about the qualifications and business practices of Park Avenue Securities LLC (“PAS”). If you have any questions about the contents of this Brochure or would like to obtain a free copy of this Brochure, please contact us at (888) 600-4667 or visit https://www.parkavenuesecurities.com/. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about PAS is also available on the SEC’s website at www.adviserinfo.sec.gov. PAS is a registered investment adviser and conducts its business under marketing name Park Avenue® Wealth Management. Registration as an investment adviser does not imply a certain level of skill or training. PAS017974 (4/26)  2. Material Changes Park Avenue Securities, LLC. (“PAS”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”) conducting business under marketing name Park Avenue® Wealth Management (“Park Avenue”, the “Firm”, “we”, “our” or “us”). Pursuant to SEC rules, this item summarizes the specific material changes, if any, that have been made to this Form ADV disclosure brochure (“Firm Brochure”) since the last annual update of the Firm Brochure on March 19, 2025. When required or appropriate, we will also provide clients interim summary updates of material changes to this Firm Brochure. You are strongly encouraged to read this Firm Brochure in detail and contact your investment adviser representative (“IAR”) with any questions. Clients may ask for a copy of our current Firm Brochure, which includes all material changes since the previous Firm Brochure, or a summary of material changes to the previous Firm Brochure at any time, without charge, by contacting us at (888) 600-4667 or via the Contact Us link at https://www.parkavenuesecurities.com/. Clients may also obtain a copy of this Firm Brochure or a copy of any other of our Form ADV disclosure brochures by accessing and downloading them from our website at https://www.parkavenuesecurities.com/ under Form ADV Brochures. The following is a summary of material changes to this Firm Brochure since the last annual update on March 19, 2025. April 23, 2026 Update Park Avenue Securities LLC begins operating under the marketing name Park Avenue® Wealth Management. Our legal name remains Park Avenue Securities LLC, and we will continue to be the registered investment adviser providing your advisory services. March 20, 2026 Update Item 14. Client Referrals and Other Compensation  Disclosure and descriptions of IAR conflicts related to outside business activities and IAR loan/lending arrangements are provided under section Other IAR Conflicts. December 31, 2025 Update Item 4. Advisory Business  FoundationsSM and Quantitative InnovationsSM programs to be closed to new investors effective January 31,  2026. Information has been added related to PAS’s parent company, The Guardian Life Insurance Company of America (“GLIC”), obtaining warrants from Hamilton Lane and Hamilton Lane’s management of a portfolio of GLIC’s general account. Item 14. Client Referrals and Other Compensation  Additional information has been added related to new additional compensation paid by PAS to certain IARs.  Additional information has been added regarding third-party payments in the form of revenue sharing being paid to PAS. 2 (4/2026)  3. Table of Contents Section: Page: 1. Cover Page… ....................................................................................................................................................... 1 2. Material Changes ................................................................................................................................................. 2 3. Table of Contents ................................................................................................................................................. 4 4. Advisory Business ................................................................................................................................................ 5 5. Fees and Compensation .................................................................................................................................... 35 6. Performance-Based Fees and Side-By-Side Management. .............................................................................. 46 7. Types of Clients and Account Requirements ..................................................................................................... 46 8. Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................... 47 9. Disciplinary Information ...................................................................................................................................... 52 10. Other Financial Industry Activities and Affiliations ............................................................................................. 53 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................................... 53 12. Brokerage Practices ........................................................................................................................................... 54 13. Review of Accounts ............................................................................................................................................ 55 14. Client Referrals and Other Compensation ......................................................................................................... 56 15. Custody .............................................................................................................................................................. 64 16. Investment Discretion ......................................................................................................................................... 65 17. Voting Client Securities ...................................................................................................................................... 66 18. Financial Information .......................................................................................................................................... 66 19. Report of Independent Registered Public Accounting Firm. ............................................................................... 67 20. Statement of Financial Condition ....................................................................................................................... 68 21. Notes to Statement of Financial Condition ......................................................................................................... 69 4 (4/2026)  4. Advisory Business Firm Description Park Avenue Securities LLC (“PAS”), doing business under the marketing name Park Avenue® Wealth Management (“Park Avenue”, the “Firm”, “we”, “our” or “us”), 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 Park Avenue. Types of Advisory Services Offered We offer a wide variety of investment advisory programs and services, including proprietary investment advisory programs (each, a “Park Avenue 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. Certain of our IARs market their practices using marketing names that differ from the name under which we primarily conducts our advisory business. In these circumstances, clients should be aware that all investment advisory services described herein are provided by IARs through and on our behalf, not the marketing names that IARs use to market their practices. Understanding your Relationship with Park Avenue We are subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and as a registered investment adviser, we, along with our IARs, have a fiduciary duty to you. This generally means that Park Avenue and our 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, we have identified conflicts of interest within specific sections that are otherwise describing the services we provide or the fees or compensation we or our IARs receive. Within the advisory programs described in this Brochure, we provide services as an investment adviser under the Advisers Act. In providing investment advice, your Park Avenue IAR can select from different products and programs. This includes advisory programs described in this brochure and other advisory programs described in our Wrap Fee Brochures. The majority of our IARs may act in their capacity as a registered representative of Park Avenue providing securities recommendations in a Park Avenue 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 Park Avenue. There are IARs associated with us who are not licensed as a registered representative. These individuals may not provide securities recommendations in Park Avenue brokerage accounts and will only offer investment advisory services described within this brochure and other advisory programs described in our Wrap Fee Brochures. For more information about the IAR providing advisory services, you should refer to the Brochure Supplement for the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time you engage the IAR. You should discuss with your IAR the benefits and costs associated with the different advisory programs available at Park Avenue as well as what relationship may be best for you. This should include a discussion about the 5 (4/2026)  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. Our IARs assist clients in pursuing their financial goals by providing personalized financial planning services and investment solutions. Any information you receive from us or our IARs relating to tax considerations affecting your financial arrangements or transactions is not intended to be tax advice and you should not rely upon it as tax advice. Neither we nor our IARs provide tax, legal, or accounting advice. AVAILABLE ACCOUNTS AND RELATIONSHIP TYPES When you choose to purchase products and services through us and work with our financial professionals, you have the option of investing through a transaction-based account, such as a brokerage account, a fee-based investment advisory account, or both. It is important for you to understand the services you will receive, the fees, costs, and expenses you will pay, and conflicts of interest of ours and your financial professional in connection with each of these different types of accounts and relationships with us and your financial professional. The services, fees, costs, expenses, and conflicts of interest are summarized below and described in much greater detail in our Form CRS, Regulation Best Interest (“Reg BI”) Disclosure Document and Forms ADV, Part 2A, as applicable, which are available on our website at https://www.parkavenuesecurities.com/. In addition, if considering investing into a Third-Party Investment Advisory Program, you are encouraged to review the Third-Party Investment Adviser’s Form ADV Part 2 which will contain important information such as the program fees and expenses and any conflicts of interest of the Third-Party Investment Adviser which may exist. Transaction-Based Account, Such as a Brokerage Account As a broker-dealer, we offer 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, we may offer general, impersonal investment advice in the form of publications and other services. We will not be deemed to be providing investment advisory services unless it has entered into a contract with the client for that purpose. With a transaction-based account, such as a brokerage account, you will pay commissions and other charges (such as sales loads on mutual funds and other securities and investment products) at the time of each transaction, such as the purchase or sale of a mutual fund, stock, bond, option, Alternative Investments (“AI”), or other security or investment product. These commissions and other charges are Park Avenue’s and your Park Avenue financial professional’s primary source of compensation for the transaction-based advice your Park Avenue financial professional provides when recommending such transactions. When serving as your broker, your Park Avenue financial professional can make recommendations and provide guidance to you in selecting securities, other investment products, and services. Your Park Avenue financial professional may also provide investment education and research services, which are incidental to the brokerage services Park Avenue provides. A transaction-based account can potentially be more appropriate for you than a fee-based investment advisory account if you do not want ongoing investment advice on assets held in your account, or ongoing management of your account, and instead want only periodic or on- demand advice and recommendations specific to the purchase and sale of securities and other investment products. Additionally, this type of account can potentially result in lower costs for you if you expect to trade on an infrequent or occasional basis. When Park Avenue and your Park Avenue financial professional make securities and investment strategy recommendations to you as broker-dealer for your transaction-based account, such as a brokerage account, Park Avenue and your Park Avenue financial professional will be acting in their broker-dealer capacities for such account and are required to act in your best interest, without placing their financial or other interests ahead of your interests. You should be aware that Park Avenue and Park Avenue financial professionals are subject to various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles Park Avenue and your Park Avenue financial professional play in a transaction, Park Avenue’s and your Park Avenue financial 6 (4/2026)  professional’s compensation arrangements, and Park Avenue’s financial and other arrangements with custodians, clearing firms, and other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in our Form CRS and Reg BI Disclosure Document, as well in the other important client disclosures available on our website, https://www.parkavenuesecurities.com/. An advisory account may not be appropriate for low volume trading activity, if you have a long term buy-and- hold investment strategy. 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 execute on your investment decisions;  You plan to buy only a few securities and follow a buy-and-hold strategy over a longtime 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. For additional information on our broker-dealer services and transaction-based account offerings, please see our Form CRS and Reg BI Disclosure Document, which are available on our website at www.parkavenuesecurities.com. Our Form CRS and Reg BI Disclosure Document may also be requested by contacting our Home Office at (888) 600-4667 or via the Contact Us link at https://www.parkavenuesecurities.com/. For detailed information regarding the commissions, trading/execution fees, and brokerage service charges that Park Avenue establishes, controls, and charges clients when serving as a broker-dealer of record for transaction-based accounts held with Pershing, LLC (“Pershing”) as our clearing firm and custodian, please see our Fee and Commission Schedule for Accounts with Pershing (the “Client Fee Schedule”) which is provided to you at account opening, will change over time, and can be found on our website at www.parkavenuesecurities. Before consenting to any broker-dealer relationship with us or our financial professionals, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation we and our financial professionals will receive, and Park Avenue’s and our financial professionals’ conflicts of interest. After reviewing these disclosures, please address any questions you may have with your Park Avenue financial professional. Fee-Based Investment Advisory Account A fee-based investment advisory account, sometimes called a “managed account,” can potentially be more appropriate for you than a transaction-based account, such as a brokerage account, if you want ongoing investment advice and management of your account. Park Avenue offers a number of different investment advisory account programs and acts as the sponsor and broker-dealer in connection with some of those different investment advisory account programs. With a fee-based investment advisory account, you will pay an ongoing investment advisory fee based on the value of the assets held in your account in exchange for ongoing investment advice and management of your account and related services. This asset-based fee is Park Avenue’s and your IAR’s primary source of compensation related to the servicing of investment advisory accounts. The Park Avenue investment advisory accounts that are currently offered to new clients charge an “all-inclusive’ bundled fee based on the value of the assets in your account. This bundled fee usually includes a portfolio management fee, transaction, trading, and execution costs, and investment advice and is sometimes referred to as a “wrap fee.” However, this bundled fee does not include costs associated with transactions that are executed at broker-dealers other than the one at which your account is held. Transactions executed at broker-dealers other than the one at which your account is held are sometimes called “step-out” trades and are described further in [Items 5 and 12 below.] Fees vary depending on which Park Avenue advisory program accounts you use. 7 (4/2026)  Investment advisory account fees are billed either in arrears (i.e., following the completion of the applicable billing period) or in advance (i.e., at the beginning of the applicable billing period) depending on the advisory program you select, and your billing methodology (i.e., in arrears or in advance) will be specified, your Statement of Investment Selection (“SIS”) and Terms and Conditions (for Park Avenue Proprietary Program Accounts, other than VestWise), the VestWise Investment Advisory Agreement, or the account opening documentation of the Third- Party Investment Advisor Program Accounts (collectively, the “Client Agreement”), or other account opening documentation. Fee charges are specified in your Client Agreement or other account-opening documentation, based on the assets held within your account for services including, but not limited to, ongoing investment advice, investment selection and recommendations, asset allocation, execution of transactions (depending on the program you are in), custody of securities, and account reporting services. Please see your Client Agreement and other account-opening documentation for additional information. After reviewing these documents, please address any questions you have with your IAR. For all Park Avenue Proprietary Program Accounts other than VestWise, our advisory fees are generally negotiable. The Park Avenue Portfolio Select Program charges separately for asset management services, ongoing investment advice, and transaction costs. In this Program, you will be charged for any transaction, trading, and execution fees, costs, and expenses that applicable to trades and other transaction occurring within your account, as described in your account-opening documentation, in addition to your asset-based advisory fees (unless your IAR has agreed to incur such charges and expenses specific to your Park Avenue Portfolio Select Program account). Applicable transaction, trading, execution, and other fees, costs, and expenses are described in detail in the applicable Client Agreement, SIS, transaction, trading, execution, and brokerage service fee schedules, other account-opening documentation, and Form ADV, Part 2A. When Park Avenue and your Park Avenue financial professional serve as investment adviser for your fee-based account, Park Avenue and your Park Avenue financial professional will be acting in their investment advisory capacities for such account and are fiduciaries, without placing their financial or other interests ahead of your interests. Additionally, when Park Avenue and your Park Avenue financial professional provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA, Park Avenue and your Park Avenue financial professional are fiduciaries within the meaning of Title I of ERISA and the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”), as applicable, which are laws governing retirement accounts. You should be aware that Park Avenue and Park Avenue financial professionals are subject to various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles Park Avenue and your Park Avenue financial professional play in a transaction, Park Avenue’s and your Park Avenue financial professional’s compensation arrangements, and Park Avenue’s financial and other arrangements with custodians, clearing firms, and other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in our Form CRS and Reg BI Disclosure Document, as well as in the other important client disclosures available on our website, www.parkavenuesecurities.com. 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. You should periodically discuss the various investment advisory program options with your IAR. Park Avenue IARs are compensated for servicing your Park Avenue investment advisory accounts and providing investment advice for the Programs. The compensation paid to IARs for each of the Programs is generally comparable, except for VestWiseTM, our digital advisory program, which has a lower fee structure. The compensation paid to Park Avenue and Park Avenue’s IARs for Park Avenue Programs may be more than what Park Avenue and the IAR would receive if you pay separately for investment advice, brokerage, and other services. Under Park Avenue Proprietary Programs, clients must establish an account through Park Avenue with Pershing 8 (4/2026)  LLC (“Pershing”). Pershing acts as the clearing firm and custodian for client assets within Park Avenue Proprietary Programs. Accordingly, all trading activity under Park Avenue 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. In addition, for all Park Avenue Proprietary Programs, Park Avenue is serving as the broker-dealer of record. By signing the SIS and Client Agreement, client authorizes and directs Park Avenue and the IAR to trade through Pershing, the applicable custodian and clearing firm. When Park Avenue acts in the capacity of the broker-dealer on your account, it receives additional compensation which it would not otherwise receive if another firm acted in the capacity of the broker-dealer on your account. Park Avenue’s receipt of additional compensation in its capacity as the broker-dealer on your account creates a conflict of interest for Park Avenue because Park Avenue has a financial incentive to, among other things, recommend itself as the broker-dealer of record and Pershing as the custodian for your account (rather than other available broker-dealers and custodians). For additional details regarding the conflicts of interest that Park Avenue has in connection with the various revenue streams it receives as your broker-dealer, please see Item 5, Fees and Compensation, below. Park Avenue addresses these conflicts of interest by disclosing them to you; providing you with the Client Fee Schedule, which discloses the amount and rate of transaction, trading, execution, and brokerage services charges you will incur for your Park Avenue Proprietary Program accounts for which Park Avenue serves as the broker- dealer of record, the services you receive, and the securities and other investment products you purchase, hold, and sell in your account; not sharing any transaction, trading, execution, or brokerage service charges with the IARs that recommend products, share classes, transactions, strategies, or services for your account; and by requiring that there be a review of your account and transactions at account opening and periodically to determine whether they are suitable and in your best interest in light of your investment objectives, financial circumstances, and other characteristics. Pershing handles the delivery and receipt of securities purchased or sold on behalf of Park Avenue 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. For additional information on our investment advisory programs and services, please see our Form CRS and Forms ADV, Part 2A, which are available on our website at www.parkavenuesecurities.com, and through the SEC’s website at www.adviserinfo.sec.gov. Our Form CRS and Forms ADV, Part 2A may also be requested by contacting us at (888) 600-4667. Before consenting to any investment advisory relationship with us or our financial professionals, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation we and our financial professionals will receive, and conflicts of interest of ours and of our financial professionals. After reviewing these disclosures, please address any questions you may have with your financial professional. Rollovers and Fiduciary Acknowledgement When Park Avenue and its IARs provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA and 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, Park Avenue and its IARs are fiduciaries within the meaning of Title I of the ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not necessarily mean Park Avenue 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, Park Avenue, 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; information regarding the scope of services provided by Park Avenue and its IARs, (ii) the fiduciary acknowledgement above, and (iii) the description of the material conflicts of interest under which Park Avenue and your IARs are operating. Rollovers 9 (4/2026)  Park Avenue and your IAR get paid when you engage in a rollover transaction. Park Avenue can recommend that you rollover assets from your workplace retirement plan or from an existing IRA into an IRA account with Park Avenue. When you engage in a rollover to an IRA, Park Avenue 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 Park Avenue and your IAR to make a rollover recommendation. Transferring an Existing Account to Park Avenue 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 Park Avenue 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, our digital advisory program, 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 Park Avenue 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 Park Avenue Proprietary Program, you will sign a client agreement which consists of a Statement of Investment Selection and Terms and Conditions and/or the VestWise Investment Advisory Agreement (the “Client Agreement”). The Client Agreement and other account opening documentation 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 and other account opening documentation. 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 Park Avenue and the third- party investment adviser, as described below under “Third-Party Investment Advisory Programs.” Financial Planning and Consulting Certain IARs are authorized 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, 10 (4/2026)  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 and Consulting Agreement, which will detail all the important terms and conditions pertaining to the financial plan or consultation, including the fee. 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 Financial Planning or Consulting 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 Financial Planning and Consulting 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 us, 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 us, your IAR will receive additional compensation for any product purchases or additional investment advisory services in his or her role and capacity as either a registered representative for a transaction-based account, such as a brokerage account, or as investment advisory representative of a fee-based investment advisory account, please see Available Accounts and Relationship Types above for further information. Subscription Based Financial Planning Certain IARs are authorized by us to offer on-going financial planning services through our Subscription-Based Financial Planning Program. The subscription-based financial planning 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 subscription-based Financial Planning Agreement will renew annually unless you choose to terminate the subscription-based Financial Planning 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 Financial Planning 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. 11 (4/2026)  Core Services: Initial Consultation, including obtaining and organizing essential documents   Obtaining essential documents  Organizing documents  Cash Flow and Debt Planning Analysis  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 other transaction-based brokerage and investment advisory accounts. However, the advice provided within the Subscription-Based Financial Planning arrangement cannot solely be comprised of existing Park Avenue transaction-based brokerage and investment advisory 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, please see Available Accounts and Relationship Types above for further information. 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 owned by Park Avenue Financial Professionals that provides services to other Park Avenue 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 Park Avenue IAR. The services that Fiscalyze provides are not investment advice and consist of the following, all of which are offered through the Park Avenue 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 12 (4/2026)  Industry Benchmarking Analysis  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   An inventory of strategies which tracks progress over time. 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 Park Avenue, pursuant to which the General Agents supervise and may influence the Park Avenue 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 Park Avenue 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 Park Avenue IAR uses the Fiscalyze tool to provide financial consulting services to a client. Thus, in the event a Park Avenue 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 us to offer on-going subscription-based business financial consulting services utilizing Fiscalyze (“Subscription-Based Business Financial Consulting Program”). 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 Subscription-Based Business Financial Consulting agreement will renew automatically on an annual basis unless you choose to terminate the Subscription-Based Business Financial Consulting 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 Subscription-Based Business Financial Consulting 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 overtime 13 (4/2026)  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 overtime Fiscalyze Get Organized and Take Control Financial Consulting Certain IARs are authorized by us 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 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 a Get Organized and Take Control Financial Consulting Agreement. By signing the Get Organized and Take Control Financial Consulting 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 generally between $250 to $25,000. Corporate Financial Education Services Certain of our IARs can work with business clients to provide group financial education seminars for the employees of such businesses. 14 (4/2026)  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 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 Exit 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) Park Avenue may enter into an agreement with an employer sponsored qualified retirement plan to provide investment advisory services to the plan. Park Avenue, 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 Park Avenue 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 Park Avenue for more details regarding the specific services to be provided as well as the fees charged. Investment Option Recommendations – The Park Avenue 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 15 (4/2026)  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 may 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, typically, 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 – Park Avenue and its IAR will not exercise any discretion or authority regarding the plan sponsor's selection of the specific securities, mutual funds, institutional funds, or funds available through group annuity contracts or the mutual funds that may be eligible investment options under the qualified plan. Furthermore, neither the IAR nor Park Avenue 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 his or her 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, Park Avenue and its IARs must utilize the software and other tools provided by Envestnet Retirement Solutions, LLC (“ERS”). Park Avenue, its affiliates and IARs are not affiliated with or under common ownership, control, or operation with ERS. Park Avenue agreements with plan sponsors for plan investment advisory services do not include services provided by other Park Avenue 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 of our IARs may enter into joint work arrangements whereby such professionals refer plans to other of our 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 us 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 16 (4/2026)  the retirement plan fiduciary for use by its plan 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 retirement plan fiduciary. Retirement Plan Services (Non-Investment Advisory) We may enter into an agreement with an employer sponsored qualified retirement plan to provide certain non- investment advisory services to the plan. The Park Avenue 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 Park Avenue Proprietary Investment Advisory Programs We are the sponsor of the Park Avenue Proprietary Programs, investment advisory programs that provide clients access to individualized investment management services. We allow our IARs to offer the investment advisory services described herein to their clients and potential clients. Park Avenue Proprietary Programs offer a range of investment strategies, from conservative to ultra-aggressive growth. The following description applies to all Park Avenue Proprietary Programs other than VestWiseTM, the digital advisory program we offer. In considering the Park Avenue Proprietary Programs as investment advisory programs and solutions for a client, an IAR will analyze your individual financial situation and make recommendations as to an appropriate Park Avenue Proprietary Program based on your individual needs, investment objectives, financial circumstances, and other characteristics. Prior to funding a Park Avenue Proprietary Program account, your Park Avenue 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 17 (4/2026)  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 Park Avenue Proprietary Program, which may include investments from a wide array of investment options, including but not limited to, mutual funds, exchange-traded funds (“ETFs”), closed-end funds, equity securities, exchange-listed securities, over-the-counter securities, AIs, 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. Park Avenue Proprietary Programs include both discretionary and non-discretionary programs. In a discretionary program, we, your IAR (for Park Avenue Signature PortfolioSM) or the applicable third- party Strategist, Investment Manager, or overlay manager (in all other discretionary Park Avenue Proprietary Programs), manages your assets within the parameters of the program and model portfolio you select. Each discretionary Park Avenue Proprietary Program also allows either us, the applicable IAR, Strategist, Investment or Overlay Manager to place trades for your account at its discretion without requiring your prior approval. This gives either us, the applicable IAR, Strategist, Investment or Overlay Manager the authority to determine, without obtaining your specific consent, the securities 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 certain reasonable restrictions or modify any existing restrictions on the management of your account. The non-discretionary Park Avenue 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 Park Avenue Proprietary Programs, either Park Avenue 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 Park Avenue Proprietary Program account and as you update or amend it from time to time. To assist you in managing your account assets, Park Avenue will provide you with:  Periodic performance reports showing the performance of your Park Avenue 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 Park Avenue 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. Alternatively, for consolidated reporting purposes and convenience, certain securities may be held in Park Avenue Proprietary Program accounts and classified as Unsupervised Assets. These may include securities transferred into your Park Avenue 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. In these cases, Park Avenue and its IARs will not serve in an investment advisory capacity with respect Unsupervised Assets. Park Avenue and its IARs will not provide investment advisory services or oversight of the Unsupervised Assets, and the Unsupervised Assets will be excluded from the calculation of the Park Avenue Proprietary Program account’s advisory fee and performance. While Unsupervised Assets are not included in the calculation of Park Avenue Proprietary Program account advisory fees, client’s Unsupervised Assets are subject to all other applicable fees as described in the transaction, trading, execution, and brokerage service fee schedules and other documentation applicable to their Park Avenue Proprietary Program account, including but not limited to, annual custody and valuation fees. Unsupervised assets are not included in the periodic performance reports for your Park Avenue Proprietary Program account. 18 (4/2026)  Your account can be managed in a tax-sensitive manner; however, neither Park Avenue 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. We have contracted with Envestnet Asset Management, Inc. (“Envestnet”), an SEC registered investment adviser, to provide a technology structure for Park Avenue and its clients through Park Avenue Proprietary Programs other than VestWiseTM to efficiently connect with third-party asset managers and Park Avenue, as an asset manager (not considered a “third-party asset manager”) in the Strategist Select Plus and UMA Select Programs, each referred to as Investment Managers or Strategists, to act in some Programs as co-adviser to clients, and to provide various administrative services and investment management services to clients electing Park Avenue Proprietary Programs. In Programs offered with third-party Investment Managers or Strategists, 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 Investment Manager), mutual funds, and Exchange- Traded Funds (“ETFs”) that may be available within certain of the Park Avenue 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. For all Park Avenue Proprietary Programs, you have the ability to impose certain 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 Park Avenue Proprietary Programs: Park Avenue Portfolio SelectSM Program (Closed to New Investors)  The Park Avenue Portfolio SelectSM program is a non-discretionary program where your selected IAR advises and may recommend to you various investments from a wide array of investment options, including but not limited to, mutual funds, ETFs, closed-end funds, equity securities, exchange-listed securities, over-the-counter securities, AIs, 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 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 but not limited to, mutual funds, ETFs, closed-end funds, 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 Park Avenue 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 19 (4/2026)  without a recommendation from your IAR (client-initiated transactions). These client-initiated transactions are solely your responsibility. We will not be responsible for the performance of these client-initiated transactions; however, we 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, Park Avenue will take that asset into consideration: - as part of the overall account assets; - when Park Avenue gives you periodic asset allocation advice; - when Park Avenue values your account holdings; and - when Park Avenue provides analyses and reports on the account’s performance.  We may also recommend that you consider selling the asset if, and when we deem it appropriate. Park Avenue Portfolio Select Program assesses ticket charges to clients for the purchase and sale of certain securities in a client’s account. The ticket charges are retained by Park Avenue 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. Park Avenue Proprietary 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 all Park Avenue Proprietary Programs that are wrap fee programs (“Park Avenue Wrap Fee Programs”). Under the Park Avenue 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 Park Avenue and your IAR for investment advisory services. Park Avenue Wrap Fee Program portfolio managers may employ “trading away” practices, in which they use a broker other than us 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 Park Avenue Wrap Fee Program fee, sometimes you will pay an additional transaction fee for investments bought and sold outside the Park Avenue Wrap Fee Program. For more information regarding trade away practices, please go to www.parkavenuesecurities.com. Each of our Wrap Fee Programs are described in greater detail in a separate Form ADV, Part 2A – Appendix 1 (Wrap Fee Program Brochures) which describes in detail the investment options, services, related fees, costs, and conflicts of interest Park Avenue Wrap Fee Program which are available on our website at www.parkavenuesecurities.com and on the SEC’s website at www.adviserinfo.sec.gov. Our Wrap Fee Brochures and each of our other Forms ADV, Part 2A, may also be requested from your IAR or by contacting us at (800) 600- 4667 or at www.parkavenuesecurities.com. Below is a brief description of each Park Avenue Wrap Fee Program. FoundationsSM and Quantitative InnovationsSM Programs (Closed to New Investors) The Foundations and Quantitative Innovations programs are discretionary investment advisory programs we sponsor that provide clients with access to model portfolios managed by Integrated Capital Management, Inc. 20 (4/2026)  (“iCM”), a third-party investment manager that has been retained by 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 and 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 we sponsor 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. Within the Strategist Select Plus program, clients are also provided access to Park Avenue, who is not retained by Envestnet or a third-party, as the investment advisory firm or Strategist. Envestnet provides overlay management of investment models developed and maintained by third-party 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. Park Avenue Separately Managed Account SelectSM Program (SMA Select) The SMA Select Program is a discretionary investment advisory program we sponsor 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 we sponsor that provides clients with access to the investment strategies of both third-party Investment Managers and Park Avenue as an Investment Manager. Third-party Investment Managers are 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 securities such as 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 21 (4/2026)  allocation sleeve. You will complete the UMA Select Program account by selecting which Investment Manager strategies to populate within each asset allocation sleeve. An UMA Select Program account may contain one or multiple model portfolios provided and maintained by the individual Investment Manager(s) selected (an “Investment Model”) by you investing in different asset classes according to the selected portfolio allocation strategy. The UMA Select Program account may also contain mutual funds, ETFs, individual securities, 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. When utilizing a third-party Investment Manager, Envestnet acts as the overlay manager and administers the UMA Select Program by implementing the Investment Model provided and maintained by the individual third-party Investment Manager(s) selected by you. 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. When Park Avenue is selected as Investment Manager, Park Avenue manage and administer the Investment Model(s). By executing the Client Agreement, you grant us the authority to buy and sell securities and investments for the account and perform rebalancing or other such discretionary authorities you agree upon. When selecting Park Avenue as Investment Manager and utilizing Park Avenue Investment Models, by executing the Client Agreement, you grant us the authority to buy and sell securities and investments for the account and perform rebalancing or other such discretionary authorities you agree upon. 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 Park Avenue IAR you select. You authorize Park Avenue 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 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 Park Avenue IAR via a licensing agreement between Park Avenue and Envestnet. VestWiseTM VestWise™ is the branded name for our 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 us with the Model Portfolios for the VestWise program, which are periodically updated by Franklin Advisers acting in the role of a “Model Provider.” We acts as the sponsor and the discretionary investment manager for this program, which means we are 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, we use this discretion to make changes to the holdings within the account over time consistent with the selected Model Portfolio. 22 (4/2026)  The technology platform being utilized by us to provide the VestWise program is offered by AdvisorEngine, an affiliate of Franklin Advisors. We pay 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. Park Avenue 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 Park Avenue. Alternative Investments and Institutional Capital Network, Inc. Park Avenue 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 Park Avenue issue multiple share classes to investors. The share classes offered in Park Avenue advisory programs will contain no up-front sales charges or ongoing distribution and/or servicing fees payable to Park Avenue. 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 Park Avenue advisory programs require investors to qualify as a Qualified Purchaser, Qualified Client and/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 of our IARs are granted access to the iCapital platform whose alternative investments may only be recommended, purchased, and advised on in the Park Avenue Signature Portfolio and Portfolio Select programs. Park Avenue approved alternative investments which may be purchased, recommended, and advised on in the Park Avenue Signature Portfolio and Portfolio Select Programs include, but are not limited to, non-traded real estate investment trusts, Delaware Statutory Trusts, hedge funds, private equity, and private credit programs that may include non-traded Business Development Companies (collectively, “AIs”). Alternatively, certain AIs that are not available to be recommended, purchased, and advised on may only be held in Park Avenue Proprietary Program accounts as Unsupervised Asset. Clients should carefully consider the investment objectives, risks, costs, and expenses of an AI and particular AI share class before investing. This and other important information is available in each AI’s prospectus, private placement memorandum, or other offering documents, which can be obtained from your IAR. Clients should be aware that investing in AIs involves material risks, including liquidity risks, risks related to the difficulty in valuing certain AIs as a result of the assets in which they invest, risks related to the inability to obtain daily or otherwise current valuations for certain AIs, and other special risks, that clients could lose all or a portion of the AI investment. Additionally, clients should be aware that AI investments will in certain circumstances involve 23 (4/2026)  additional fees and expenses, including, but not limited to, fees imposed by AI platforms and investment vehicles through which Park Avenue makes certain AIs available to clients. Please see section 8. Methods of Analysis, Investment Strategies and Risk of Loss for common risks associated with investing in Alternative Investments. Park Avenue makes available alternative investment funds issued by Hamilton Lane Advisors, LLC (“Hamilton Lane”). Our parent company, The Guardian Life Insurance Company of America (“GLIC”), has appointed Hamilton Lane to manage a portfolio of GLIC’s general account and in exchange has obtained warrants from Hamilton Lane. These warrants may be exercised in shares of Hamilton Lane, cash, or a combination of shares of Hamilton Lane and cash. The warrants issued by Hamiton Lane to GLIC creates a conflict as customer investments into Hamiliton Lane funds will generate earnings and additional compensation for GLIC. Neither Park Avenue nor GLIC will share profits from GLIC’s compensation earned through the warrants issued by Hamilton Lane with your IAR therefore, your IAR does not have a financial incentive to recommend a Hamilton Lane product. 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, Park Avenue 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 Park Avenue 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. Park Avenue and the IAR will receive advisory fees from accounts invested in these Programs as described within the Statement of Investment Selection. 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 Park Avenue IAR will not act in the capacity of Authorized Representative on the account and neither Park Avenue 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 Park Avenue offers various Third-Party Investment Advisory Programs in which Park Avenue, 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 Park Avenue and the Third-Party Investment Adviser. Your IAR will provide you with the Third-Party Investment Adviser’s Form ADV Part 2, which 24 (4/2026)  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 Park Avenue all account opening documentation and information, including any reasonable investment restrictions requested by you. Park Avenue 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. Park Avenue 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. Park Avenue 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. The following is a list of Third-Party Investment Advisory Programs available through Park Avenue, where Park Avenue 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  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. 25 (4/2026)  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 Park Avenue offers are summarized below. Stonebridge Capital Management, Gould Asset Management, LLC, and Silvercrest Asset Management Group, LLC Third-Party Investment Advisory Programs are only offered through specific IARs of Park Avenue. 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 Park Avenue for investment by its clients, such as high net worth individuals, trusts, endowments and foundations, and institutions. Park Avenue 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 Park Avenue limited authority with respect to reallocations in your account based on changes made by SIMC to the asset allocation models. Park Avenue 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 Park Avenue, 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 Park Avenue 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 Park Avenue. 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, Park Avenue is responsible for gathering information about your current financial situation, risk tolerance, time horizon, and asset class preference. Park Avenue 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 Park Avenue to select from one of several asset allocation models developed by SEI, which may be composed of SEI mutual funds. SEI may provide Park Avenue 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 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. Park Avenue, SIMC and your IAR do not provide investment advisory services of any kind with regard to Client Direct Portfolios, do not charge an advisory 26 (4/2026)  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 Park Avenue 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 Park Avenue to implement the AssetMark Platform for Park Avenue clients. As part of its services, AssetMark provides account administration and has developed internet-based software, which provides Park Avenue 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 Park Avenue. In establishing your account, you may complete a questionnaire, or otherwise provide information to Park Avenue, to enable you and Park Avenue 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 Park Avenue 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 Park Avenue 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 Park Avenue for investment by its clients. To establish an account through the Matson Money Fund Platform, you enter into an investment management agreement with Matson and Park Avenue under which Matson is granted discretionary authority to invest your assets and Park Avenue acts as the soliciting adviser. Under the Matson Money Fund Platform, you respond to a client questionnaire that assesses your risk tolerance and investment 27 (4/2026)  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 Park Avenue 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. Park Avenue will continue to review the account for program suitability and your IAR will retain responsibility for an annual review of your account. This program is also available through Park Avenue Strategist SelectSM. Orion Portfolio Solutions, LLC 28 (4/2026)  Orion Portfolio Solutions, LLC (“Orion”) is the sponsor and adviser to the Orion Strategist Program (as defined below) which is offered through Park Avenue for investment by its clients. Through this program Orion provides a fee- based platform for Park Avenue 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 Park Avenue under which Orion is granted discretionary authority to invest your assets and Park Avenue 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 Park Avenue 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. Park Avenue 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 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 29 (4/2026)  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. Park Avenue 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 Park Avenue IAR ranges from 50bps to 175bps, a portion of which is retained by Park Avenue. 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 Park Avenue IARs may refer ultra-high net worth clients to BNY Mellon Wealth Management for Investment advisory services while also providing ongoing client advisory 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 Park Avenue and you govern the services the Park Avenue IAR will provide as it relates to the BNY Wealth Management program. The services your Park Avenue IAR will provide are:  Ongoing holistic advice and guidance across your overall investment portfolio;  Interviewing you prior to 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 Park Avenue IAR for more information on BNY Mellon’s respective investment advisory practices. Stonebridge Capital Management 30 (4/2026)  Certain Park Avenue 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 Managers 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 Park Avenue 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 Park Avenue 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. Lending Services Offered to Park Avenue Proprietary Program Clients Non-Purpose Loan Program You may apply for a non-purpose loan from Pershing LLC through the Non-Purpose Loan Program using an eligible securities account as collateral. These eligible securities accounts may include one or more of your Park Avenue Proprietary Program accounts. In order for Park Avenue 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 Park Avenue on the loan value in addition to any Program advisory fees charged in the Park Avenue Proprietary Program account being used as collateral. Park Avenue 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”) 31 (4/2026)  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 Park Avenue Proprietary Program accounts. In order for Park Avenue 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 Park Avenue on the loan value in addition to any Program advisory fees charged in the Park Avenue Proprietary Program account being used as collateral. Park Avenue 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 Park Avenue 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, Park Avenue and your IAR continue to earn fees on the full account value. Park Avenue 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 (offered by Park Avenue to Park Avenue clients) as Park Avenue 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 Park Avenue 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 Park Avenue 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 Park Avenue Proprietary Program account assets as collateral rests with you and should only be made if you understand: 32 (4/2026)  the risks of borrowing and the impact of the use of borrowed funds on advisory accounts;   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 Park Avenue 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 Park Avenue, 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 Park Avenue, 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. Park Avenue 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 Park Avenue nor its IARs will act as investment adviser to you with respect to the liquidation of securities held in a Park Avenue Proprietary Program account to meet a loan demand. Those liquidations will be executed in Park Avenue’s 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, Park Avenue 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 Park Avenue’s 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%. Park Avenue 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, Park Avenue 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 33 (4/2026)  request for additional cash or securities deposit could cause Park Avenue or Pershing, at their discretion, to liquidate 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 Park Avenue 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 Park Avenue has a financial incentive to recommend or maintain a margin loan. This compensation is retained by Park Avenue 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. 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 Park Avenue 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 Park Avenue 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, Park Avenue 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 34 (4/2026)  the application and disclosure information provided when applying for SBLOC services. Assets Under Management As of December 31, 2025, Park Avenue maintained $19,575,765,851 of Regulatory Assets Under Management of which, $17,636,074,218 were managed on a discretionary basis and $1,939,691,633 were managed on a non- discretionary basis. In its capacity as a solicitor or co-adviser, Park Avenue maintained assets under administration of $11,322,676,442. 5. Fees and Compensation Program Fees paid to Park Avenue for the Park Avenue Proprietary Programs are assessed on an annual percentage of the total market value of the client’s assets under management (including, but not limited to, all cash balances in the client’s account and all client balances in the products and accounts used as “cash sweep” vehicles, including but not limited to, Park Avenue’s Sweep Program (see Cash Management Sweep Program section below for further information) and may be individually negotiated by the client. In limited circumstances, a Park Avenue IAR may reduce the total amount of the IAR portion of the Total Client Fee charged to IAR family members and friends of associated persons of Park Avenue. At its discretion, Park Avenue pays a portion of the fee it receives to IARs. Fees earned by an IAR vary by Program. Therefore, an IAR has an incentive to recommend one Program over another. There is no guarantee that the Park Avenue investment advisory services offered will result in the client’s goals and objectives being met. Nor is there any guarantee of profit or protection from loss. The fees and expenses in connection with these advisory services may be higher than the cost of similar services offered through other financial firms or the fees associated with other financial services. Use of asset-based fee or “wrap fee” programs may result in the payment of fees by clients in excess of the combined total of separate advisory fees and brokerage commissions paid on an individual transaction basis. In investment advisory accounts, the Park Avenue IAR is not paid a sales commission or trail commission on the client assets maintained in those investment advisory accounts. Please note that a client may be able to purchase recommended no-load mutual funds outside of a Park Avenue Proprietary Program at little or no transaction cost and without the payment of advisory fees; however, the client will not receive the benefit of the investment advice and other services that Park Avenue and its IARs provide to clients participating in its advisory programs. In some cases, similar services are available from other sources or firms at lower fees and charges (which may have the effect of lowering the cost to the customer and/or increasing the return on the product). Park Avenue IARs may also provide advisory services to retail clients via other Park Avenue advisory Programs. VestWise, the digital advisory Proprietary Program offered by Park Avenue, which has a lower advisory fee structure, may be invested in securities that are comparable to client accounts that are invested in other Park Avenue advisory Programs. You should carefully review the description of each Program and the related fees and consider which Program may be more appropriate. If you want a description of all advisory Programs offered, please contact Park Avenue or, alternatively, you may go to www.parkavenuesecurities.com to view all of the Firm Brochures available for Park Avenue. Park Avenue is conscious of these potential conflicts. Overall, where we are providing fiduciary services, the goal of our policies and procedures is to act in the best interest of our clients, regardless of their strategy, fee arrangements or the influence of their owners or beneficiaries. Advisory and Transaction Fees The VestWise Program You will pay one advisory fee for the services provided in the VestWise program. The maximum annual fee for the VestWise program is 0.45% paid quarterly in arrears. The fee is calculated quarterly, using the average daily balance of the assets held in the Model Portfolio for your account for the completed quarter. 35 (4/2026)  The annual client advisory fee agreed upon by you and Park Avenue is indicated in the VestWise Investment Advisory Agreement. The advisory fee charged by Park Avenue does not include internal expenses charged by the ETFs in which account assets are invested. All internal expenses are fully disclosed in the respective ETF prospectuses. Park Avenue Proprietary Programs Other Than VestWise Other than the VestWise program, the advisory fee for a Park Avenue Proprietary Program is based on the average daily balance of assets in a client’s account during the previous calendar quarter and is payable in advance for the following quarter and specified in the Client Agreement or other account opening documentation. You will pay one advisory fee (“Total Client Fee”) for the services provided in the program you have selected. Your Total Client Fee is separated into different components, which vary depending on the program you have selected. The components of the Total Client Fee consist of the following:  An Adviser Fee for the current advisory services provided by your IAR which ranges from .50% to1.75% of assets under management.  A Platform Fee, which is paid to Park Avenue, as the sponsor of the Proprietary Programs, and for the technology related services and/or the advisory related services provided by Park Avenue and Envestnet, and the brokerage services involved in purchasing and selling the securities in your account. Please see section Annual Platform Fee – Park Avenue Proprietary Programs Other Than VestWise Accounts for additional information.  A Manager Fee for the advisory services provided by Strategists and Investment Managers (as applicable)which ranges from 0% to .65% of assets under management. The Total Client Fee is located in your Statement of Investment Selection. The fee is calculated at the end of each quarter and is debited from the account on the 10th day of the month (or the next business day if the 10th day is a non-business day), of the following quarter. If you choose a standard fee schedule rather than a negotiated fee, and your assets exceed a fee breakpoint or fall below a fee breakpoint, your Total Client Fee will be adjusted to the appropriate fee schedule in the subsequent quarter. IARs have an incentive to select a manager with a lower manager fee to enable them to charge a higher Adviser Fee without increasing your Total Client Fee. Similarly, advisors have an incentive to negotiate their Adviser Fee to a higher level when the platform portion of the fee decreases so your Total Client Fee remains level rather than decreasing at certain breakpoints. Upon termination of your account, you will receive a pro-rata refund representing the period from termination date to the end of the quarter. No refunds are made in the case of a partial withdrawal from the account. The standard Total Client Fee schedule for each program is set forth below. As broker-dealer of record for client accounts in Park Avenue Proprietary Programs, Park Avenue may charge clients for certain transactions as footnoted below. Park Avenue transaction charges cover both the underlying Pershing transaction charges as well as administrative services provided by Park Avenue in connection with the transactions. Each Park Avenue wrap fee Proprietary Program has its own Wrap Fee Brochure which describes in detail the services, fees, costs, expenses, and conflicts of interest investment options, services, and fees for each Proprietary Program. To obtain a Wrap Fee Brochure for one of these programs, please request the brochure from your IAR or call our Home Office at (800) 600-4667. The Brochures are also available on our website at www.parkavenuesecurities.com. Other Fees and Charges – Strategists or Investment Managers in the UMA/SMA Select or Strategist Select/Strategist Select Plus programs may execute trades in fixed income, thinly traded or illiquid securities. In order to obtain best execution and minimize market impact, these trades may be executed outside of Envestnet’s trading process in order to gain best execution and minimize market impact. In some instances, trades under these circumstances are executed by the Investment Manager or Strategist without any additional commission or 36 (4/2026)  markup or markdown. However, in other instances, the executing firm may impose a commission or a markup or markdown on the trade. If trades are placed with an executing firm that imposes a commission or equivalent fee on the trade, including a commission that may be imbedded in the price of the security, you will incur costs in addition to the wrap fee that is paid to Park Avenue. Fes schedule and charges specific to the Park Avenue Portfolio SelectSM Program Assets Under Management $ 0 - $499,999.99 $500,000.00 - $999,999.99 $1,000,000.00 - $1,999,999.99 $2,000,000.00 – over Maximum Client Fee 2.05% 2.00% 1.95% 1.90% In addition, other administrative charges may apply, including:  Ticket Charges: $10.00 per transaction  IRAs & Certain ERISA Plans: $125.00 termination fee. Annual Platform Fee - Park Avenue Proprietary Programs Other Than VestWise Accounts The annual Platform Fee is a component of the Total Client Fee as described in your Statement of Investment Selection. The annual Platform Fee ranges in the aggregate from .05% to .30% of assets under management with a minimum annual fee of $90.00 per household, which will result in an annual fee percentage above .30% for the Platform Fee if a client’s household assets under management in Park Avenue Proprietary Programs other than VestWise accounts fall below a certain threshold. Should your account’s balance during a quarter be below the point at which at least $22.50 in Platform Fees, on average, are generated, your client fee shall be increased incrementally to satisfy the minimum. Using the example from above, if an account with a balance of $50,000 during a quarter generated a Platform Fee of $24.00, the $22.50 minimum quarterly fee would have been satisfied and no additional expense would be incurred. However, if an account with a balance of $35,000 during a quarter generated a Platform Fee of $22.20, the $22.50 minimum quarterly fee would not have been satisfied, resulting in the incremental increase of your annual Platform Fee and therefore, Total Client fee, to make up for the additional $0.30. On average, account balances greater than $42,000 will not see any impact from this minimum annual Platform Fee. For accounts with balances less than this amount, the Platform Fee portion of your Total Client Fee shall be increased incrementally to satisfy the minimum quarterly Platform Fee. This may cause your Total Client Fee percentage to be greater than the percentage indicated on the SIS, may fluctuate from quarter-to- quarter, and is dependent on the value of your account’s assets during the prior quarter. Fluctuations in the account value during some quarters may cause the annual Platform Fee to be higher or lower than if the Platform Fee were calculated annually on the average account value because of the possible annual minimum Platform fee being assessed in a particular quarter or the possible Annual Platform fee breakpoints that may be achieved by a client account. Householding for Annual Platform Fee Park Avenue shall allow householding for multiple Park Avenue Proprietary Program accounts, other than VestWise. Park Avenue policy in determining client accounts that qualify as a household generally defines “household” as Park Avenue Proprietary Program accounts, other than VestWise, of the same account owner, spouses, domestic partners, parents, and children and will consider the total assets held across the full relationship versus each account individually when determining the minimum annual platform fee applicable to each individual account. You are responsible identifying these accounts and working with your Park Avenue IAR to include them in the correct household for billing purposes. In certain circumstances, Park Avenue may, in its sole discretion, permit Park Avenue Proprietary Program accounts falling outside of the criteria listed above to be grouped as a household. To the extent your Park Avenue Proprietary Program account is subject to householding discounts for applicable Park Avenue Proprietary Program account fee components, the Total Client Fee you incur 37 (4/2026)  will in certain circumstances be lower than the Total Client Fee reflected in the fee table of your SIS. Fees are negotiated with each client based upon, among other things, the size and complexity of each client’s circumstances. Each IAR will negotiate with each client to determine the fees the client will be charged, therefore, fees vary among IARs and clients and some IARs charge higher fees than other IARs for similar or identical services. The fees charged by each entity providing services to the Park Avenue Proprietary Programs vary based on the securities and other investment products used, the size of the client’s account and/or household, and other factors. Advisory Account Adjustment to Annual Platform Balance Current Annual Platform Fee* Future Annual Platform Fee (As of Oct. 1, 2021) Fee to Reach $90 Minimum Family Relationship $55 each (Total = $110) None $55 each (Total = $110) 2 separate accounts, $25,000 each (Total = $50,000) $35,000 $77 $90 + $13 to meet the minimum Accounts or Family Relationships with $35,000 in aggregate assets *Your individual account platform fee may differ from this example; please contact your IAR if you would like more information. For Individual Retirement Accounts (“IRAs”) being added to a household it is the client’s responsibility to consider the balances and activities of that account in a household and determine if it’s appropriate to household such account. A client should contact their legal or tax advisor to understand any possible unanticipated tax consequences of householding such accounts. If a client determines that they wish to exclude an IRA account from a billing group, the client is required to contact Park Avenue or their financial advisor to request that the account not be included in the household. Other Fees Applicable to All Park Avenue Proprietary Programs If cash or cash-equivalent funds in your account are not sufficient to pay the fee or any of the other fees charged in connection with your account or transactions for your account, investments in your account may be liquidated in order to pay the outstanding fees. If your account is managed for only a portion of the quarter, the fee will be prorated accordingly. Other than in Park Avenue Wrap Fee Programs, the total advisory fee for a Park Avenue Proprietary Program does not include costs or charges associated with liquidation of a client’s account or transaction charges for securities transactions. The total advisory fee also excludes other related charges, including but not limited to, express postage and handling charges, returned check charges, short-term mutual fund trading fees, fees listed in a mutual fund prospectus, Corestone Checking account fees, legal transfer fees, safekeeping fees, valuation fees, wire or transfer fees, transfer taxes or exchange fees, fees for paper statements and paper confirmations or other fees mandated by law, or non-brokerage related fees such as Individual Retirement Account (“IRA”) trustee or custodian fees and tax qualified retirement plan account fees, each of which is charged separately. These related charges are collected by Pershing; however, Park Avenue marks up the noted charges by as much as 150% and retains the markup. For example, to process a domestic overnight check, Pershing charges Park Avenue $12, you will be charged $15 (Pershing collects $12, Park Avenue collects $3). The markup on these charges helps defray our costs associated with maintaining and servicing client accounts. The additional compensation due to the markup presents a conflict of interest because Park Avenue receives a financial benefit when it provides services in connection with maintaining and servicing your account. However, because your IAR does not share in these other account fees, your IAR does not have a financial incentive to recommend certain transactions or recommend that Park Avenue provide such additional services. A full listing of charges is listed in the current Client Fee Schedule, which is provided to you at account opening, will change over time, and can be found on our website at www.parkavenuesecurities, or you may be obtained by calling our Home Office at (888)-600-4667. Step-Out Trading 38 (4/2026)  Transactions executed at broker-dealers other than the one at which a client’s account is held are sometimes called “step-out” trades or “trade-away” practices. An Investment Manager or Strategist that has the discretion to execute step-out trades with broker-dealers other than Pershing may or may not incur additional transaction, trading, or execution fees that the client will pay as a result of such step-out trades. Additional transaction, trading, or execution fees resulting from step-out trades will increase the client’s cost and negatively impact investment performance. However, a step-out trade can potentially allow the Investment Manager or Strategist to achieve better price execution. In cases where an asset-based fee that includes the cost of advisory, brokerage, and custodial services (i.e., a “wrap fee”) is assessed, the asset-based fee does not cover charges resulting from step- out trades effected by an Investment Manager or Strategist with broker-dealers apart from Pershing. Investment Managers and Strategists are generally free to consider other broker-dealers’ trading capabilities versus Pershing’s trading capabilities as part of their duty to seek best execution and obligations as investment advisers. Investment Managers and Strategist may decide to step-out for a variety of reasons, including to obtain an optimal combination of price and service for the client or to satisfy the Investment Manager’s or Strategist’s best execution obligation. Investment Managers and Strategists have the discretion to utilize step-out trades in circumstances including, but not limited to, those involving equity securities, fixed income securities, derivatives (e.g., options), thinly-traded securities, illiquid securities, and ETFs. A step-out trade occurs in some instances when an Investment Manager or Strategist purchases equity securities, fixed income securities, derivatives (e.g., options), thinly-traded securities, illiquid securities, ETFs, or other securities from a different broker-dealer or the broker-dealer selling the securities to obtain a more favorable price or because the particular security is not available through Pershing. In other instances, a step-out trade occurs when an Investment Manager or Strategist executes a single trade for multiple clients by aggregating orders into a single “block.” A “block” trade can potentially provide the client with a better overall price and/or return because a single order can potentially result in better execution versus placing multiple separate orders. When an Investment Manager or Strategist executes a block order, that Investment Manager or Strategist is seeking to obtain best execution and best price. Aggregating transactions into a single trade can potentially afford the Investment Manager or Strategist more control over the execution of the trade, including potentially avoiding an adverse effect on the price of the security that could result from effecting a series of separate, successive, and/or competing small trades with multiple broker-dealers or clearing firms. Park Avenue Proprietary Program Total Client Fees do not cover any fees, costs, or expenses resulting from step- out trades effected with, or through, broker-dealers or clearing firms other than Pershing. They also do not cover any mark-ups or mark-downs (i.e., adjustments to your purchase or sale price above or below the current market price of the applicable security) by any such other broker-dealers or clearing firms. As such, clients are responsible for any such additional transaction, trading, and execution fees, costs and expenses in addition to the applicable Park Avenue Proprietary Program fees. Additional costs resulting from step-out trades typically are included in the net price of the securities traded and typically are not reflected as separately identifiable charges on your trade confirmations or account statements. It is expected that Investment Managers or Strategists would typically consider trades executed through Pershing to be without a commission or retail mark-ups or mark-downs when comparing the cost of trading securities with other broker-dealers. Park Avenue would expect such a comparison by an Investment Manager or Strategist to generally result in a decision to execute most trades through Pershing. However, Investment Managers and Strategists from time to time believe they are able to obtain better execution utilizing step-out trades. A general description of the additional costs related to step-out trades can be found on our website at www.parkavenuesecurites.com. If you have any questions regarding this information or step-out trading in your account and related costs, please contact your IAR. Mutual Funds, Close End Funds and ETFs in Proprietary Advisory Programs In addition to the total advisory fee, you pay the fees and expenses of the mutual funds, closed-end funds and ETFs (mutual funds, closed-end funds and ETFs collectively, “Fund(s)” in which your account is invested. Fund fees and expenses are charged directly to the pool of assets the Fund invests in and are reflected in each Fund’s net asset value. These fees and expenses are an additional cost to you and are not included in the fee amount in your account statements. Each Fund expense ratio (the total amount of fees and expenses charged by the Fund) is 39 (4/2026)  stated in its prospectus. The expense ratio generally reflects the costs incurred by shareholders during the Fund’s most recent fiscal reporting period. Current and future expenses may differ from those stated in the prospectus. You do not pay any sales charges for purchases of Funds in the programs described in this Brochure. However, some Funds may charge, and not waive, a redemption fee on certain transaction activity in accordance with their prospectuses. Please refer to the applicable prospectus for more information. If you have authorized prospectus redirection to Park Avenue in a discretionary Proprietary Program, you may contact your IAR or Park Avenue to review or obtain a copy of the prospectus for Funds used within the Park Avenue Proprietary Programs. You should be aware that, in addition to the Total Client Fee paid by you for advisory services under a Park Avenue Proprietary Program, each investment company (i.e., mutual fund) in the program also has its own separate investment management fees and other expenses. These mutual funds may include assets managed by Park Avenue Institutional Advisers LLC (“PAIA”), an affiliate of Park Avenue, as a sub-adviser to certain mutual funds offered by Victory Capital. Further, certain “load” mutual funds may be purchased in a client’s account at net asset value (“NAV”) without a sales charge to a client (“NAV Funds”). Certain mutual funds available through the Park Avenue Proprietary Programs may make payments to broker-dealers, including Park Avenue, with respect to sales of mutual fund shares pursuant to Rule 12b-1 under the Investment Company Act of 1940 (“Rule 12b-1 Service/Distribution Fees”) or otherwise as administrative service fees. These fees are described in the prospectus for the respective mutual fund. Such payments are made from mutual fund assets and have the effect of reducing mutual fund performance. Park Avenue does not negotiate these payments, which are made solely at the discretion of the mutual fund. Park Avenue credits any Rule 12b-1 Service/Distribution Fees it may receive to client accounts (with the exception of certain money market mutual funds and FDIC sweep vehicles). Park Avenue shall not be responsible for any misstatement or omission or for any loss attributable to such misstatement or omission contained in any Fund prospectus, fact sheet or any other disclosure document provided to us for distribution to you. Mutual Fund Share Class Selection The following is applicable to Park Avenue Proprietary Programs, excluding VestWise™, mutual fund portfolios managed by a third-party Strategist or third-party Investment Manager, and funds used within the Cash Management Sweep Program. investor eligibility requirements prescribed by a mutual fund company; When negotiating and discussing your Total Client Fee, you should understand that mutual fund companies offer a variety of share classes with different expense levels. These expense levels, known as expense ratios, are fees and expenses charged by the mutual fund company and that investors will pay to purchase, hold, and sell shares of a mutual fund. You should not assume that you will be invested in the share class with the lowest expense ratio for a mutual fund due to the following factors:   Park Avenue’s mutual fund share class selection processes. An investor who holds a more expensive share class of a mutual fund will pay higher fees over time and earn lower investment returns than an investor who holds a less expensive share class of the same mutual fund. When evaluating the reasonability of fees, you should consider not just the fees that you pay for investment advisory services through Park Avenue, but also the additional fees and expenses charged by the mutual fund companies in your account. For detailed descriptions of the components of a fund’s expense ratio by share class, please refer to the mutual fund prospectus. In addition, an overview of mutual funds share classes is available within the Park Avenue Mutual Fund Disclosure document located at www.parkavenuesecurities.com/legal/mutual-disclosure. As a matter of practice, Park Avenue will not invest clients into share classes containing sales charges and distribution fees such as 12b-1 fees. 40 (4/2026)  After determining the share classes that the Programs are eligible to purchase, pursuant to each fund’s prospectus, we will further evaluate each of these share classes and aim to select the lowest cost available share class for which the majority of the programs’ clients are eligible to purchase. This results in Park Avenue excluding certain share classes with the lowest expense ratios if the majority of clients are not eligible to purchase, such as certain Retirement share classes. Moreover, while we avoid using share classes that charge a Distribution Fee, such as a 12b-1 fee, as part of our Programs, if a Distribution Fee bearing share class is transferred into a client account, the fees are credited to client accounts monthly, as applicable, until the share class is converted pursuant to Park Avenue’s share class conversion process. Please read the section below for additional details related to share class conversions. In some instances, among the various share classes issued by a mutual fund company, a fund company may offer share classes that include a fee referred to as a Sub-Transfer Agent Fee (“Sub-TA Fee”) and share classes that do not contain this fee. Sub-TA Fees are paid by the mutual fund company to a third-party provider to subsidize certain services otherwise done by the mutual fund company, such as processing daily transactions, maintenance of account balances, mailing of prospectuses, etc. The Sub-TA Fee increases the total expense ratio of a fund. The amount of a Sub-TA Fee may differ by mutual fund company. Details related to the cost of a Sub-TA Fee are described within fund prospectuses. As matter of practice, in these instances, Park Avenue will select the share class containing the Sub-TA Fee for use within the Programs. This means that Park Avenue may not select the lowest cost share class for which the client is eligible even if there is a less costly share class that does not charge Sub-TA Fees. The Sub-TA Fee compensates Pershing, LLC (Park Avenue’s custodian) for sub-accounting, recordkeeping, and related services at the individual account level. Pershing, LLC passes along a surcharge to Park Avenue for any mutual fund that is part of a Park Avenue advisory Program which does not contain a Sub-TA Fee. Park Avenue’s practice of selecting a share class that contains a Sub-TA Fee when a share class of the same fund without a Sub-TA Fee is available, causes a conflict of interest as Park Avenue has a financial interest in selecting the Sub- TA bearing share class to avoid the Pershing, LLC surcharge. In the Park Avenue Portfolio Select, Park Avenue UMA Select and Park Avenue Signature Portfolio programs, your IAR can make mutual fund recommendations as part of your overall asset allocation. The mutual funds made available for recommendation and selection by your IAR in these programs will only be those with which Park Avenue has a selling agreement and those that have been deemed appropriate for these programs by Park Avenue. You should not assume that you will be invested in the share class with the lowest expense ratio for a mutual fund in the Park Avenue Portfolio Select, Park Avenue UMA Select and Park Avenue Signature Portfolio programs. Share Class Conversions. At least annually, Park Avenue will review the mutual fund share classes held within the Park Avenue Portfolio Select and Park Avenue Signature Portfolio programs. Mutual funds recommended by IARs in the UMA Select program will also be reviewed. If a lower cost share class is found to be available in these programs, pursuant to the funds’ eligibility requirements and Park Avenue’s share class selection processes, Park Avenue will process a conversion to a lower cost share class. Therefore, you may hold a higher cost share class of a mutual fund in these circumstances for up to twelve months before Park Avenue converts your investment to a lower cost share class. Until the conversion is implemented, we will continue to retain shares of the less favorable class for your account. Park Avenue will only convert share classes to a lower cost share class. If you are already invested in a share class that is lower in cost than what is available in these programs, as described above, you will retain your investment and will not be converted to a higher cost share class. Park Avenue SMA Select and UMA Select, Park Avenue Strategist Select and Strategist Select Plus, and Quantitative Innovations and Foundations Investment Manager Mutual Fund Share Class Selection Park Avenue IARs may also recommend the use of third-party Strategists or third-party Investment Managers 41 (4/2026)  within the above referenced Programs who may use mutual funds as part of an asset allocation for your account. Each Strategist or Investment Manager has their own policy regarding mutual fund share class selection and they are responsible for the mutual fund share classes chosen. Park Avenue cannot require an Investment Manager or Strategist to use the lowest cost share class available. Park Avenue also reviews a Strategist/Investment Manager’s mutual fund share class selection as part of Park Avenue’s ongoing due diligence process to determine the continued use of such Strategist/Investment Manager. Please refer to the applicable Strategist or Investment Manager’s Form ADV Part 2A or Wrap Fee Program disclosure included in your account opening documents or at www.adviserinfo.sec.gov for information regarding their mutual fund share class selection. You should not assume that you will be invested in the share class with the lowest expense ratio for a mutual fund in the Park Avenue SMA Select, Park Avenue UMA Select, Park Avenue Strategist Select, Park Avenue Strategist Select Plus, and Park Avenue Quantitative Innovations and Foundations programs. Cash Management Sweep Program A Cash Management Sweep Program (“Sweep Program”) is a service Park Avenue makes available to clients which allows clients to automatically transfer free credit balances to either a money market fund product (the “Money Market Sweep”) or an account at a bank whose deposits are insured by the Federal Deposit Insurance Corporation (“Bank Sweep”). Park Avenue Proprietary Program Accounts (“Accounts”) are eligible to participate in the Sweep Program. The Park Avenue Sweep Program is comprised of a Bank Sweep product, which all clients shall be defaulted to at account opening, as well as specific money market funds which serve as overflow funds for accounts whose Bank Sweep product balance exceeds certain Federal Deposit Insurance (“FDIC”) limits. At the time you open your Account, you shall be defaulted to one of two Bank Sweeps. All Accounts, except for IRA and Retirement Plan Accounts, will be defaulted to the Dreyfus Insured Deposits Program (DIDV). The default DIDV Bank Sweep product is an FDIC insured multi-bank deposit sweep program. Additionally, balances in DIDV within the same account which are in excess of the $2.5 million FDIC insured limit will be automatically redirected to the Dreyfus Government Money Fund (DGUXX). IRA and Retirement Plan Accounts will default to DIDM—a design of the Dreyfus Insured Deposit Program specifically for IRA/Retirement Accounts. Any balances within the same IRA/Retirement Plan Account over the $2.5 million in FDIC coverage will be diverted to the Dreyfus Government Money Fund (DGVXX). When depositing into either the default DIDV or DIDM Dreyfus Insured Deposit Programs, you will receive a Disclosure Statement and Terms and Conditions of the program you are defaulted into. Amongst other items, the Disclosure Statement and Terms and Conditions detail various conflicts of interest associated with the Dreyfus Insured Deposit Program you are participating in, how interest rates are determined, and risks associated with the program. In addition, the Disclosure Statement and Terms and Conditions will provide a description of the DGUXX or DGVXX Dreyfus Money Fund associated with your Sweep Program. You are encouraged to carefully read and understand the Disclosure Statement and Terms and Conditions. The Disclosure Statement and Terms and Conditions is readily available on our Cash Management webpage at https://www.parkavenuesecurities.com/cash- management, by contacting your IAR, or by contacting our Home Office at 888-600-4667. In addition, if invested into either DGUXX or DGVXX Dreyfus Money Funds, you will receive a prospectus of the fund you are invested into. Park Avenue has a conflict of interest by offering the DIDV Bank Sweep and the DGUXX Money Market Sweep Programs. Park Avenue receives a significant economic benefit when cash balances are swept into these Sweep Programs, rather than being reinvested in other investment funds or securities. For the DIDV Bank Sweep, Park Avenue receives a share in the earned income based on the amount of assets placed within the Bank Sweep. Park Avenue also receives a distribution from the DGUXX Money Market Sweeps used for overflow balances pursuant to the Fully Disclosed Clearing Agreement with its clearing firm, Pershing, LLC. The income earned from the DIDV Bank Sweep and the distribution received from the DGUXX Money Market Sweep, both of which are generated from, and paid by client deposits, are in addition to the Total Client Fee paid by clients to Park Avenue, related to investing in Park Avenue Proprietary Program Accounts. This conflict gives us a financial incentive to (i) select the DIDV and DGUXX Sweep Programs as the default Sweep Programs for all Proprietary Program Accounts other than 42 (4/2026)  IRA and Retirement Plan Accounts, rather than other Sweep Programs that are available that pay Park Avenue relatively lower or no revenue; (ii) recommend or advise clients to increase their deposits within the DIDV and DGUXX Sweep Programs; (iii) recommend or advise clients to invest in Proprietary Program Accounts that default into the DIDV and DGUXX Sweep Programs rather than accounts held directly with Third-Party Investment Advisory Programs; and (iv) recommend a Sweep Program option based on the compensation we receive instead of your needs. As a result, if you are invested in a Sweep Program option that pays Park Avenue a fee, the cost to you may be more than if you are invested in a Sweep Program that does not pay Park Avenue a fee. You may choose to opt out of the Sweep program by contacting your IAR. For additional information regarding payments received by Park Avenue regarding the DIDV Bank Sweep and Money Market alternative option, please review Item 14, Client Referrals and Other Compensation, specifically Other Compensation (Park Avenue Proprietary Programs). For more information on the Bank Sweep and Money Market overflow options as well as current yields and available bank lists please go to the following pages: https://www.parkavenuesecurities.com/cash- management and http://www.pershing.com/rates. Please note that Park Avenue does not offer all of the sweep options listed on the Pershing website. Assets held in any of the Sweep Programs will be included in the calculation of the client’s Total Client Fee, (i.e., they are considered “billable assets”). Your Account may require a certain amount of cash to remain in the Sweep Program to cover for certain costs associated with your Account. Different Sweep Program vehicles will have different rates of return, may pay Park Avenue a distribution fee, have different costs, and have different terms and conditions, such as FDIC insurance or SIPC protection, depending on the sweep vehicle. If the rate of return received from Sweep Programs fall below that of your Total Client Fee, you will experience a net negative overall return with respect to your Sweep Program deposits. The sweep vehicle is reflected on your account opening documents and on your statements. The selection of a more expensive share class of a Money Market Fund will negatively impact your overall investment returns. Sweep Program vehicles are not intended for use as a long-term investment option and are best used for short periods of time. You may be able to earn a higher yield through a different investment, and you should consult with your IAR about the available sweep options. Federal Deposit Insurance Corporation insured bank deposits are not protected by Securities Investor Protection Corporation. Although a money market mutual fund seeks to preserve the value of your investment at $1 per share, it may be possible to lose money by investing in a money market mutual fund. Shares of a money market mutual fund or the balance of a bank deposit product held in your account may be liquidated upon request with the proceeds credited to your account. Please see the money market fund’s prospectus or the bank deposit product’s disclosure document or contact your financial professional for additional information. Pursuant to SEC Rule 10b- 10b(1) confirmations are not sent for purchases into money market mutual funds processed on the Sweep Program. Over any given period, the interest rates on cash balances in the Bank Sweep product may be lower than the rate of return on money market vehicles which are not FDIC insured or on bank account deposits offered outside the Sweep Program. If any sweep vehicles designated within the Sweep Program becomes unavailable at any time for any reason, Park Avenue will select an alternative in its discretion provided Park Avenue gives you 30 days advance written notice of such change and you do not object. In this event, the free credit balances in your Account will be placed into the alternative Sweep Program option. As noted earlier, all accounts will be automatically invested in a Bank Sweep vehicle. However, Park Avenue realizes an economic benefit from the DIDV Bank Sweep by sharing in the earned income based on the amount of assets placed within the Bank Sweep. For Accounts which hold a sweep vehicle charging a distribution fee retained by Park Avenue, Park Avenue does not share the distribution fee with your IAR. Therefore, your IAR does not have a financial incentive to recommend a Sweep Program option based on whether it pays a distribution fee or not. 43 (4/2026)  For additional information on money market funds and FDIC-Insured Deposit Sweeps, including applicable distribution fees, please see the fund prospectuses which are available on the following pages: https://www.parkavenuesecurities.com/cash-management and http://www.pershing.com/rates. Retirement Plan Consulting Services (Investment Advisory) The fee range for this program ranges from 0.10% to 1.00% of plan assets. Alternatively, Park Avenue may charge a fixed dollar amount that will equal no more than 1.00% of plan assets. Retirement Plan Services (Non-Investment Advisory) The fee range for this program ranges from 0.10% to 1.00% of plan assets. Alternatively, Park Avenue may charge a fixed dollar amount that will equal no more than 1.00% of plan assets. Investment Advice to Retirement Plan Participants The fee range for this program ranges from 0% to .50% of plan assets. Alternatively, Park Avenue may charge a fixed dollar amount that will equal no more than .50% of plan assets. Third-Party Investment Advisory Programs: Park Avenue receives fees with respect to Third-Party Investment Advisory Programs for advisory, solicitation or other services. Unless otherwise restricted by the Third-Party Adviser, Park Avenue IARs negotiate a fee for their services ranging from .50%-1.75% for assets under management. The specific paperwork for each Third- Party Investment Advisory Program will state the negotiated fee. Each Third-Party Adviser program has its own Wrap Fee Brochure or ADV Part 2A which describes in detail the investment options, services, and fees for each program. Your IAR is required to give you this brochure at or before the time you open your account with the Third-Party Adviser. To obtain a Wrap Fee Brochure or Form ADV Part 2A for a Third-Party Adviser program, please request the brochure from your IAR. Financial Planning / Subscription-Based Financial Planning / Financial Consulting / Business Exit Consulting / Corporate Financial Education Services / Fiscalyze Prospective clients have the opportunity to meet with an IAR for an initial consultation at no cost. If you decide to retain Park Avenue for financial planning/consulting or business exit consulting services, you must sign a client agreement and will pay for such services either by hourly or flat fees as you and your IAR may mutually agree. Financial planning/consulting fees are negotiable. Hourly fees will generally range from $100/hour to $500/hour, and flat fees will generally range from $500 to $25,000 per agreement.  Subscription-Based Financial Planning will generally have a maximum annual fee of $25,000 per agreement.  For Corporate Financial Education Services or business exit consulting services, the maximum fee is generally  $30,000 per agreement.  For consulting services utilizing Fiscalyze, the maximum fee is generally $30,000 per engagement or on an  annual basis. In the case of termination of your relationship with Park Avenue with respect to consulting or business exit consulting services, you will only be charged for services rendered prior to the termination of the engagement. ERISA Section 408(b)(2) Disclosure to Responsible Fiduciaries of ERISA-Covered Qualified Retirement Plans The federal law that regulates the administration and operation of retirement and other benefit plans, known as the Employee Retirement Income Security Act of 1974 or ERISA, requires “fiduciaries” of ERISA-covered plans 44 (4/2026)  (“Plans”) to act solely in the interest, and for the exclusive benefit of, plan participants and beneficiaries. As part of this obligation, the “administrator” of each plan or another responsible fiduciary named by the plan document must make informed decisions in selecting plan services and investments. Regulations adopted by the U.S. Department of Labor (“DOL”), called the “section 408(b)(2) regulations,” require service providers to ERISA- covered retirement plans to describe in writing information about their services and compensation (“Disclosure”). This Disclosure is provided in connection with the section 408(b)(2) regulations and is intended to assist you, as the responsible fiduciary of your Plan (“you”), in reviewing the services and compensation of Park Avenue and your IAR. Services we provide to your Plan Advisory Services: Proprietary Advisory Program – Together with your IAR, Park Avenue provides advisory services to you and to your Plan as described in our Statement of Investment Selection, Terms and Conditions, Advisory Account Application, and this Firm Brochure (together, the "Investment Advisory Agreement") relating to your Plan. Please review those documents. Pershing LLC (“Pershing”) provides custody and clearing services in connection with your advisory account and therefore acts as a subcontractor for Park Avenue. Please review the Pershing Subcontractor Compensation Disclosure provided at account opening for information related to Pershing’s compensation for providing these subcontracted clearing and custody services. If you do not have copies of any of the documents mentioned in this paragraph, please contact your IAR or our Home Office directly at 888-600-4667. Third-Party Advisory Program – Together with your IAR and Park Avenue, the third-party advisory program sponsor provides advisory services to you and to your Plan as described in the third-party program’s investment management agreement, account application, this Firm Brochure as well as the third-party advisory program sponsor’s Firm Brochure (together, the “Third-Party Investment Advisory Agreement”) relating to your Plan. Please review those documents. If you do not have copies, please contact your IAR, Park Avenue directly at 888-600- 4667 or the applicable third-party advisory program sponsor. Park Avenue acknowledges and agrees that, to the extent the advisory services provided to your Plan may include recommendations made by Park Avenue or your Park Avenue IAR with respect to investments that involve "investment advice" as defined under regulations issued under ERISA, we will be a “fiduciary" for ERISA purposes. Please note that Park Avenue does not and cannot provide legal, accounting or tax advice to you or to the Plan. You are responsible to maintain the Plan in compliance with requirements applicable to tax-qualified plans under the Internal Revenue Code, including, where applicable, receipt of a favorable determination letter, and Park Avenue does not have any responsibility for such matters. Park Avenue does not accept any responsibility for the administration of your Plan, including (without limitation) the timely transmission of required contributions, filing required governmental reports, preparing, or providing notices and communications to your Plan's participants as required by applicable law and regulation, or notifying you that any such notices or communications are required. You should seek the advice of your legal and other advisors with respect to these and other matters that might arise relating to the operation and administration of the Plan. Our Compensation for Services The fees charged to your Plan for providing services are as described by either the Investment Advisory Agreement or the Third-Party Investment Advisory Agreement, whichever is applicable, relating to your Plan. Park Avenue may pay between 35% and 85.5% of the Adviser Fee component received in connection with the services provided for your account to your IAR. If you have questions about the compensation that is paid to Park Avenue and the IAR, please ask your IAR or our Home Office at 888-600-4667. Other Matters If your Plan is a participant-directed Plan, your Plan's record-keeper and/or the investment provider that offers the investment platform through which your Plan's investments are processed is required to provide to you, 45 (4/2026)  information to comply with DOL regulations that require the delivery of information to your Plan's participants about the Plan's designated investment alternatives. If requested, your IAR may assist you in coordinating with the record keeper and/or investment provider to obtain these materials. Your investment providers are responsible for ensuring that these materials are complete and accurate, and Park Avenue does not make any representation as to the completeness and accuracy of these materials. In providing services to your Plan, Park Avenue relies on information provided by you and, if there is any material change in information pertaining to the Plan, you must promptly notify Park Avenue in writing and provide relevant updated information. You are responsible for the exercise of proxy voting and other shareholder rights pertaining to investments held by the Plan. In addition, neither Park Avenue nor your IAR may provide any investment or other advice with respect to assets of the Plan that may be invested in stock issued by the plan sponsor and/or a self-directed brokerage option that permits participants the opportunity to allocate some or all of their participant accounts to other investments, or with respect to continuing such investments as a part of the Plan. All investments fluctuate in value and the value of the investments, when sold, may be greater or lesser than the original cost. Park Avenue does not and cannot warrant or guarantee any level of performance by any of the investments or that any investment will be profitable over time. The Plan and its participants are assuming the market risk involved in the investment of Plan assets. Past investment performance does not guarantee any level of future investment performance. Park Avenue provides advisory services for other clients and may give advice and take action in the performance of duties for such other clients (including those who may have similar retirement plan arrangements), which may differ from advice given, or in the timing and nature of action taken, with respect to your Plan. Park Avenue has no obligation to advise you or the Plan in the same manner as we may advise any other clients of Park Avenue. In addition, if Park Avenue learns confidential information in providing services to another client, Park Avenue cannot divulge any confidential information to you or act upon such confidential information in providing services to you and your Plan. Some IARs engage in outside business activities that Park Avenue does not supervise, such as (without limitation) providing retirement plan consulting, administration, recordkeeping, or similar services with respect to retirement plans. Park Avenue does not endorse or recommend any IAR or any other person to provide services to you or to the Plan that are not within the scope of services described by this Disclosure and the Investment Advisory Agreement with you relating to your Plan, and Park Avenue will not supervise any IAR with respect to any such outside business activities. Therefore, if you engage your IAR to provide services other than the services described by this Disclosure and the Investment Advisory Agreement, it will be your responsibility to determine whether the services are appropriate for your Plan and to monitor the services. If you have any questions relating to this Disclosure, please contact your IAR or our Home Office directly at 888-600-4667. 6. Performance-Based Fees and Side-By-Side Management Park Avenue does not use a performance-based fee structure (fees based on a share of capital gains or capital appreciation of the assets of a client). 7. Types of Clients and Account Requirements Park Avenue provides investment advisory services to individuals, high net worth individuals, pension and profit- sharing plans, charitable organizations, and corporations. Park Avenue Proprietary Program Account Minimum Investment Requirements Park Avenue Portfolio SelectSM (Closed to New Investors) - Minimum initial investment requirement of $10,000. Park Avenue Signature PortfolioSM Program - Minimum initial investment requirement of $10,000. FoundationsSM and Quantitative InnovationsSM Programs - Minimum initial investment requirement of $10,000. 46 (4/2026)  Park Avenue Strategist SelectSM and Park Avenue Strategist Select PlusSM Programs - Subject to individual Strategist account minimums with the lowest minimum at $10,000. Park Avenue Separately Managed Account SelectSM Program (SMA Select) - Subject to individual Investment Manager Account minimums. Park Avenue Unified Managed Account SelectSM Program (UMA Select) - Minimum initial investment requirement of $10,000. Actual minimum may exceed $10,000 as certain investment strategies may have higher minimum requirements. VestWise™ - Minimum initial investment requirement of $5,000. 8. Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Park Avenue Proprietary Programs offer several investment strategies that involve investing in a wide range of securities and other financial instruments, including:  Equity securities  Exchange Traded Funds  Mutual Funds  Exchange-listed securities  Over-the-counter securities  Securities of foreign issuers (including ADRs, EDRs and GDRs)  Corporate debt  Commercial paper  Certificates of deposit  United States government securities  Municipal securities Investment Strategies Park Avenue Proprietary Programs include FoundationsSM, Quantitative InnovationsSM, Park Avenue Strategist SelectSM, Park Avenue Strategist Select PlusSM, Park Avenue Separately Managed Account SelectSM, Park Avenue Unified Managed Account SelectSM, Park Avenue Portfolio SelectSM, Park Avenue Signature PortfolioSM and VestWiseTM. Clients utilizing the Park Avenue Portfolio SelectSM or Park Avenue Signature PortfolioSM programs receive asset allocation and securities recommendations from the IAR(s) associated with their account. Clients utilizing the FoundationsSM, Quantitative InnovationsSM, Park Avenue Strategist SelectSM and Park Avenue Strategist Select PlusSM programs receive asset allocation and securities solutions via portfolios created and maintained by the selected Investment Manager or Strategist. Clients utilizing the Park Avenue Separately Managed Account SelectSM shall receive recommendations from their IAR on the Investment Manager(s) to manage the risk/return strategy. Clients will receive asset allocation and securities solutions via portfolios created and maintained by the Investment Manager. Clients utilizing the VestwiseTM program shall receive a model portfolio recommendation from Park Avenue. Franklin Advisers, Inc., an investment adviser registered with the SEC, provides Park Avenue with the Model Portfolios for the VestWise program, which are periodically updated by Franklin Advisers, Inc. acting in the role of a “model provider.” Based upon model changes made by Franklin Advisers Inc., Park Avenue will execute changes to the model portfolios to align to the asset allocation. 47 (4/2026)  Clients using Park Avenue Unified Managed Account SelectSM receive recommendations from their IAR on the Investment Manager(s), mutual funds and/or ETFs to manage the risk/return strategy. Clients will receive asset allocation and securities solutions via portfolios created and maintained by the Investment Manager. Asset allocation, often referred to as “tactical” or “strategic” asset allocation, is a strategy that seeks to diversify assets across various types of asset classes which may include broad asset classes (such as equity or fixed income), or sub-asset classes (such as large cap, small cap, or international). The weights assigned to each asset class are expected to result in an overall portfolio with risk and return characteristics that meet the client’s investment objectives. Asset allocation does not account for individual security risk. “Strategic asset allocation” assumes that the mix of asset classes will remain fairly consistent over a long period of time. The client’s asset allocation targets typically are not changed unless the client’s circumstances or objectives change. There are risks associated with asset allocation. One such risk is that the client may not participate in sharp increases in a particular security, industry, or market sector. Clients with a strategic asset allocation strategy may not achieve their investment objectives and may lose money. “Tactical asset allocation” is a strategy that actively adjusts a portfolio’s asset allocation based upon short- term trends that could include financial market trends, economic cycles, and asset class valuations. Based upon short- term assumptions, the portfolio allocations to certain asset classes are increased, while the portfolio allocations to other asset classes are decreased. There are risks associated with tactical asset allocation. Clients with a tactical asset allocation may not achieve their investment objectives and may lose money. Tactical asset allocation does not account for individual security risk. At different points in time, the tactical asset allocation and structure of the client’s portfolio vary significantly. There is no guarantee that a tactical asset allocation will correctly predict or track market movements or that it will provide comparable returns or decreased volatility relative to traditional strategic asset allocation programs. Clients in tactical asset allocations are relying significantly on the skills and experience of the manager’s ability to correctly judge changes in market behavior and construct a portfolio that predicts market behavior. In addition, even if the portfolio is correctly positioned, there is no guarantee that the client will not experience substantial losses. The tactical asset allocation strategy may result in a portfolio that experiences more frequent trading to take advantage of anticipated changes in market conditions. A high level of portfolio turnover may negatively impact performance by generating greater tax liabilities and brokerage and other transaction costs. Park Avenue and IARs may also offer what are commonly known as focused/completion strategies. Focused/completion strategies are portfolios that are concentrated in a certain asset class or deploy a narrow strategy. Generally, focused/completion strategies are used to complement other holdings. There are unique risks associated with focused and completion strategies, such as increased volatility since portfolios are often concentrated in a particular asset class. Park Avenue recommends mutual funds and, in some cases, ETFs, individual equities, individual fixed income securities and managed accounts to fulfill the recommended client asset allocation strategy. Tax Harvesting Subject to meeting minimum balance requirements, you may direct Park Avenue to employ a tax harvesting strategy in managing taxable accounts. This means that, once the tax harvesting threshold is met, Park Avenue will sell securities in your account at a gain or loss to offset potential capital gains, although the type and amount of capital gains will not be monitored by Park Avenue for this purpose. By authorizing tax harvesting, Park Avenue will sell one or more securities in the account and will hold proceeds in cash to avoid the 30-day wash rule. Once 30 days have passed, the funds will be reinvested in the model. Within Park Avenue Proprietary Programs, the Investment Manager or Park Avenue may select another ETF not substantially comparable to the security harvested to replace the securities that have been purchased or sold in your account. You should consult with your professional tax advisors or review the Internal Revenue Service (“IRS”) website at 48 (4/2026)  www.irs.gov regarding the consequences of tax harvesting in light of your particular circumstances and its impact on your tax return. If your IAR recommends a tax harvesting strategy for your account, that advice is not intended as tax advice. Neither Park Avenue nor your IAR represent that any particular tax results will be obtained. You are responsible for monitoring any accounts in your household, or accounts for which you maintain control (at Park Avenue or with another firm) to ensure that transactions in the same security or a substantially similar security do not create a “wash sale.” A wash sale is the sale at a loss and repurchase of the same security, or substantially similar security, within 30 days. If a wash-sale transaction occurs, the IRS may disallow or defer the loss for current tax reporting purposes. More specifically, the wash- sale period for any sale at a loss consists of 61 days: the day of the sale, the 30 days before the sale, and the 30 days after the sale (these are calendar days, not trading days). The wash-sale rule postpones losses on a sale if replacement shares are bought around the same time. The effectiveness of the tax harvesting strategy to reduce your tax liability will depend on your entire tax and investment profile, investments (e.g., taxable, or non-taxable) or holding period (e.g., short-term, or long-term). Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. Clients may experience loss in the value of their account due to market fluctuations. There is no guarantee that a client’s investment objectives will be achieved by participating in any of the programs described in this Brochure. Prior to investing, clients should carefully read a copy of the current prospectus for each security, where a prospectus is available, or other offering documents associated with the particular investment. The prospectus or offering documents contains information regarding the fees, expenses, investment objectives, investment techniques, and risks of each particular investment. The investment returns on a client account will vary and there is no guarantee of positive results or protection against loss. No warranties or representations are made by Park Avenue or IARs concerning the benefits of participating in the programs described in this Brochure. Park Avenue and IARs do not provide legal or tax advice. Clients with tax or legal questions should seek a qualified independent expert. Depending on the types of securities you invest in, you may be subject to the following investment risks including, but not limited to: Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market risks. Credit Risk: also known as default risk, is the possibility that a bond issuer will not pay interest as scheduled or repay the principal at maturity. Credit risk may also be a problem with insurance companies that sell annuity contracts, where your ability to collect the interest and income you expect is dependent on the claims-paying ability of the issuing insurance company. Sociopolitical Risk: The possibility that instability or unrest in one or more regions of the world will affect investment markets. Terrorist attacks, war and pandemics are examples of events, whether actual or anticipated, that impact investor attitudes toward the market in general and result in system wide fluctuations in stock prices. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. 49 (4/2026)  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on discoveries of oil and then refining it, a lengthy process, before they can generate a profit. These companies carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Financial Risk: Excessive borrowing to finance business operations increases the risk of loss if the company is unable to meet the terms of its loan obligations. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Liquidity Risk: When consistent with a client’s investment objectives, guidelines, restrictions and risk tolerances, client portfolios may be invested in illiquid securities, subject to applicable investment standards. Investing in an illiquid (i.e., difficult to trade) security may restrict the ability to dispose of investments in a timely fashion or at an advantageous price, which may limit the ability to take full advantage of market opportunities. Accounts may hold securities which are partnerships. Some partnerships are relatively liquid and may be either exchange listed or traded over the counter. However, most partnership securities are often illiquid and are subject to significantly less regulation than public investments. Fixed Income Risks: Portfolios that invest in bonds and other fixed income securities are subject to certain risks, including but not limited to, interest rate risk, credit risk, prepayment risk and market risk, which could reduce the yield that an investor receives from his or her portfolio. Foreign and Emerging Markets Risk: Investments in securities of foreign and emerging markets issuers involve different investment risks than those affecting obligations of U.S. issuers. Public information may be limited with respect to foreign and emerging markets issuers, and they may not be subject to uniform accounting, auditing and financial standards and requirements comparable to those applicable to U.S. companies. Additional risks include future political and economic developments, the possibility that a foreign jurisdiction might impose or charge withholding taxes on income payable with respect to foreign and emerging markets securities, and the possible adoption of foreign governmental restrictions such as exchange controls. Also, foreign currency exchange rates may affect the value of securities in the portfolio. High-Yield Bond Risk: Investments in high-yielding, non-investment grade bonds involve higher risk than investment grade bonds. Adverse conditions may affect the issuer's ability to make timely interest and principal payments on these securities. Structured Products Risk: These products often involve a significant amount of risk and should only be offered to clients who have carefully read and considered the product's offering documents, as their structure may be based on derivatives or other types of securities, which may be volatile. Structured products are intended to be “buy and hold” investments and are not liquid instruments. Interval Fund Risk: Investors investing in interval funds are subject to certain risks, including but not limited to fund shares not being listed on a public exchange, the lack of secondary markets, liquidity being provided only through repurchase offers by the fund on a schedule stated within the product prospectus (i.e. quarterly offers), no guarantee that an investor will be able to sell all the shares that the investor desires to sell during repurchase offer periods. Investors should consider these investments to be of limited liquidity. In addition, investing in interval funds may be speculative and involves a high degree of risk, inclusive of the risks associated with leverage. Investors should carefully read the fund’s prospectus prior to investing in an interval fund. Derivatives Risk: Derivatives are securities whose price is dependent upon or derived from one or more underlying assets. The derivative itself is a contract between two or more parties. Its value is determined by fluctuations in the underlying asset. Derivatives may involve significant risks and are not suitable for everyone. Derivatives trading can be speculative in nature and carry substantial risk of loss, including the loss of principal. Small/Mid Cap Risk: Stocks of small or mid-sized, emerging companies may have less liquidity than those of larger, established companies and may be subject to greater price volatility and risk than the overall stock market. 50 (4/2026)  Diversification Risk: Investments that are concentrated in one or few industries or sectors may involve more risk than more diversified investments, including the potential for greater volatility. Security Selection and Asset Allocation Risk: Securities selected from a particular asset class (e.g., stocks, bonds, money market instruments) may experience unusual market volatility or may not perform as expected. An asset allocation program does not guarantee achievement of a client’s investment objective nor protect against loss. ETF Risk: Exchange Traded Funds are subject to the following risks: (i) the market price of an ETF’s shares may trade above or below the net asset value; (ii) there may be an inactive trading market for an ETF; (iii) the ETF may employ an investment strategy that utilizes high leverage ratios; (iv) trading of an ETF’s shares may be halted, delisted, or suspended on the listing exchange; and (v) the ETF may fail to achieve close correlation with the index that it tracks. Real Estate Risk: Investment in real estate and real estate related assets is subject to the risk of adverse changes in national, state, or local real estate conditions (resulting from, for example, oversupply of or reduced demand for space and changes in market rental rates); obsolescence of properties; changes in the availability, cost, and terms of mortgage funds; and the impact of tax, environmental and other laws. 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. 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 Park Avenue’s advisory fee. Park Avenue 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, Park Avenue 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, Park Avenue 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 51 (4/2026)  price of securities held in the portfolio. 9. Disciplinary Information The following is a chronological summary of material disciplinary events relating to Park Avenue Securities, LLC. (“PAS”) and its management personnel over the past 10 years. 11/18/2016 – In connection with the misappropriation of funds from two customers by an unregistered sales assistant, FINRA censured and fined PAS $195,000 in its capacity as a broker-dealer for failing to enforce its written supervisory procedures regarding the monitoring of customer trades and for failing to establish and maintain a supervisory system reasonably designed to follow up on the performance of its supervisors with regard to monitoring trade executions, in violation of NASD Rules 3010(a), 3010(b) and FINRA Rule 2010. FINRA noted that PAS also failed to establish, maintain, and enforce a supervisory system reasonably designed to review and monitor the transmittal of funds from the accounts of its customers to third-party accounts and outside entities, in violation of NASD Rules 3010, 3012(a)(2)(B)(i) and FINRA Rule2010. 4/11/2018 – FINRA censured and fined PAS $300,000 in its capacity as a broker-dealer for failing to implement a supervisory system and written supervisory procedures reasonably designed to train and supervise Registered Representatives’ recommendations regarding the sale of multi-share class variable annuities, including L-Share contracts, to ensure their suitability. FINRA also found that PAS had no surveillance procedures to determine rates of variable annuity exchanges. FINRA found the foregoing to be in violation of NASD Rule 3010 and FINRA Rules 2330, 3110 and 2010. 3/11/2019 – PAS without admitting or denying the findings, consented to the entry of an Order Instituting Administrative and Cease and-Desist Proceedings (“Order”) by the SEC. Pursuant to the Order, the SEC found that from January 1, 2014 through October 31, 2018 certain PAS clients participating in proprietary advisory programs were invested in mutual fund share classes with higher costs (in the form of Rule 12b-1 fees) without adequately disclosing that lower-cost share classes (without Rule 12b-1 fees) of those funds were available. Specifically, PAS did not adequately disclose conflicts of interest related to its receipt of Rule 12b-1 fees, and the availability of mutual fund share classes that did not pay such fees. PAS consented to the entry of the Order that it violated Sections 206(2) and 207 of the Investment Advisers Act of 1940 and agreed to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 207. PAS agreed to pay disgorgement of $508,083 and prejudgment interest of $56,184 to affected clients. Additionally, as part of the Order, PAS has enhanced its disclosure regarding mutual fund share class selection, considered whether existing clients should be moved to a lower-cost share class, and updated its policies and procedures regarding mutual fund share class selection. 7/16/2019 – PAS without admitting or denying the findings, was censured by the Financial Industry Regulatory Authority (“FINRA”) in its capacity as a broker-dealer for failing to reasonably supervise the application of sales charge waivers for mutual fund purchases made by certain retirement plan and charitable organization customers. By failing to reasonably supervise such mutual fund sales to ensure that eligible purchasers received the benefit of applicable sales charge waivers, FINRA found that PAS violated NASD Conduct Rule 3010 (for misconduct before December 1, 2014), FINRA Rule 3110 (for misconduct on or after December 1, 2014 and FINRA Rule 2010. As part of this settlement, PAS agreed to pay restitution to eligible customers on the terms specified below, which totaled $640,552 (i.e., the amount eligible customers were overcharged, inclusive of interest). PAS also agreed to ensure that waivers are appropriately applied to all future purchase transactions made by retirement plan and charitable organization customers. FINRA recognized the extraordinary cooperation of PAS for initiating an investigation prior to detection or intervention by FINRA to identify whether applicable customers received sales charge waivers, for promptly establishing a plan of remediation to customers and taking action to correct the violative conduct. 5/31/2023 – In connection with an undisclosed outside business activity of a PAS Registered Representative, PAS, without admitting or denying the findings, agreed to a Letter of Acceptance, Waiver, and Consent with FINRA for the purpose of settling alleged FINRA rule violations. PAS was censured and fined $30,000 by FINRA for violating FINRA Rule 3110 by failing to investigate red flags that the Representative was engaged in an 52 (4/2026)  undisclosed outside business activity, unapproved private securities transactions and FINRA Rule 2010. 9/24/2024 – PAS, without admitting to or denying the findings, was censured by the Financial Industry Regulatory Authority (“FINRA”) in its capacity as a broker-dealer for failing to reasonably supervise mutual fund share class recommendations to retirement plan customers, from January 2019 through July 2021. FINRA found that PAS’ supervisory system and WSPs were not reasonably designed to achieve compliance with FINRA Rule 2111 or the Care Obligation of Regulation Best Interest. As part of this settlement, FINRA issued a $125,000 fine. PAS paid restitution to eligible customers in 2022 in the amount of $91,344, which was the amount eligible customers were overcharged, inclusive of interest. 10. Other Financial Industry Activities and Affiliations Park Avenue Securities, LLC (“PAS”), doing business under marketing name Park Avenue® Wealth Management, 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. PAS is an affiliate of The Guardian Insurance & Annuity Company, Inc. (“GIAC”), a Delaware insurance company. PAS is also an affiliate of Guardian Wealth Partners, LLC (“GWP”) and Park Avenue Institutional Advisers, LLC (“PAIA”), SEC registered investment advisers. GWP and PAIA are indirect wholly owned subsidiaries of GLIC. PAS or its IARs may recommend mutual funds whose investment adviser is a PAS affiliate, such as PAIA. PAIA is the sub-adviser to certain mutual funds offered by Victory Capital. Therefore, we have an incentive and conflict to recommend certain products which are managed by PAIA due to the additional compensation earned by such affiliate. In addition, PAS makes available alternative investment funds issued by Hamilton Lane Advisors, LLC (“Hamilton Lane”). PAS’ parent company, GLIC, has appointed Hamilton Lane to manage a portfolio of GLIC’s general account and in exchange has obtained warrants from Hamilton Lane. These warrants may be exercised in shares of Hamilton Lane, cash, or a combination of shares of Hamilton Lane and cash. While not considered a proprietary investment, the warrants issued by Hamiton Lane to GLIC creates a similar conflict. Many IARs of PAS are also agents of GLIC and GIAC and may sell a wide range of products issued by those entities, such as life insurance and variable annuities. IARs receive no additional compensation for recommending insurance products issued by affiliates or mutual funds managed by affiliates than they would if they recommend insurance products or mutual funds issued by or managed by non-affiliates. An IAR has an incentive to recommend a particular Proprietary Investment Advisory Program or Third- Party Investment Advisory Program in favor of another because of the receipt of higher fees or non- cash benefits such as additional services which include marketing support and training provided by the sponsor of the Third-Party Advisory Program. A description of these arrangements can be found in Item 14 of this brochure. 11. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Park Avenue has adopted a code of ethics (“Code of Ethics”) for all supervised persons of the firm, which governs the ethical standards of conduct and securities trading by supervised persons. The Code of Ethics includes provisions relating to, among other things, a prohibition on trading on the basis of material non-public information or confidential information, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons of Park Avenue must acknowledge the terms of the Code of Ethics annually. Park Avenue will provide a copy of the Code of Ethics to any client or prospective client upon request. It is Park Avenue policy that the firm generally will not affect any principal or agency cross transactions for client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to an advisory client. Park 53 (4/2026)  Avenue may engage in principal transactions only in limited circumstances where it elects to buy “worthless securities” out of client accounts in order to facilitate the liquidation of such positions. Park Avenue also will not permit agency cross transactions between client accounts. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Park Avenue may recommend to clients’ mutual funds that are managed or sub-advised by investment adviser affiliates of Park Avenue. For more information, see “Other Financial Industry Activities and Affiliations.” 12. Brokerage Practices Directed Brokerage Clients in a Park Avenue Proprietary Program must establish an account through Park Avenue with Pershing, which clears trades and acts as custodian for clients’ assets under the Park Avenue Proprietary Programs. Accordingly, all trading activity in connection with the Park Avenue Proprietary Programs will be processed through clients’ accounts with Pershing. Pershing acts in the capacity of a clearing firm and performs centralized custody, bookkeeping and execution functions. Pershing handles the delivery and receipt of securities purchased or sold on behalf of Park Avenue’s clients who are part of a Park Avenue Proprietary Program, receives and distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender offers and redemptions. Not all investment advisory firms will require their clients to direct brokerage. By directing brokerage, Park Avenue may be unable to achieve most favorable execution of your transactions, and this practice may cost you more money. Best Execution Investment advisers are obligated to provide “best execution” of customer orders where the adviser has the responsibility to select broker-dealers to execute client trades. “Best execution” refers to using reasonable diligence to seek to obtain the best price to buy or sell a security under prevailing market conditions. Park Avenue does not select other broker-dealers for processing of client transactions. Park Avenue must transmit all trades to Pershing for execution. Park Avenue’s objective in executing client trades is to obtain the most favorable execution and to aggregate and allocate trades fairly and equitably across all its clients. Park Avenue has adopted policies and procedures that are designed so that trading practices do not unfairly or systematically favor one client, group, or strategy over another. Park Avenue regularly receives reports from Pershing which contain information regarding the trade order execution experience of Pershing for all of its customers. Park Avenue undertakes an on- going review of its relationship with Pershing, including a quarterly review of trade order flows. Investment Managers in the SMA and UMA Select programs may not utilize Envestnet to facilitate certain trades within their strategies and consequently the use of these strategies may result in the additional trade-away fees that are not included in the Program fee, or that may be in addition to the Park Avenue wrap fee. Clients should consult with their IARs and review the Investment Manager’s Form ADV Part 2A for information related to any additional fees. Clients should carefully consider any additional trading costs the Client may incur before selecting an Investment Manager. Soft Dollars Soft dollars are defined as arrangements under which products or services other than the execution of securities transactions are obtained by an adviser from or through a broker-dealer in exchange for the direction of securities trades to the broker-dealer. Park Avenue does not maintain any soft dollar arrangements. Order Aggregation 54 (4/2026)  Park Avenue IARs generally manage their client’s accounts independently of one another based on each client’s specific needs and objectives, and transactions for each client account are often executed independently. Although each account is individually managed, Park Avenue may buy and sell the same securities for many advisory accounts simultaneously. In the Signature Portfolio Program, IARs will often aggregate the purchase or sale of multiple clients’ securities together to help facilitate best execution and provide each client with the same execution price. Aggregating multiple client orders together is particularly useful when Park Avenue or your IAR is utilizing model portfolio management strategies (multiple client accounts in the same model). IARs servicing accounts invested in the Signature Portfolio Program may determine not to aggregate transactions, for example, based on the size of the trades, the number of client accounts, the timing of the trades, and the liquidity of the securities purchased or sold. If IARs do not aggregate orders, some clients purchasing securities around the same time may receive a less favorable price than other clients. This means that this practice of not aggregating may cost clients more money. Park Avenue may aggregate transactions in the same security for many clients for whom Park Avenue has discretion to trade. If different prices are paid for securities in an aggregated transaction, each client in the transaction will receive the average price paid for the block of securities in the same aggregated transaction. If the client trade is aggregated with other client accounts and are executed at the same price, the client will receive the same price per unit. If we are not able to completely fill an aggregated transaction, we will normally allocate the filled portion of the transaction to our clients on a pro-rata basis. Park Avenue SMA and UMA Select Trade Allocations Some Investment Managers will not place Envestnet strategies in the same trade rotation as their non- Envestnet models or proprietary accounts. If Envestnet determines that such trade rotation policy does not provide equitable investment performance between the models and is creating a disadvantage to the client, Envestnet may restrict the availability of the Investment Manager or impose additional requirements, as necessary. Certain trade orders are created by the Investment Manager and sent directly to the appropriate custodian according to their own trade rotation policies. If the Investment Manager directs Envestnet to allocate orders within each custodian, the partial fill will be allocated pro-rata among the individual Client accounts. Investment Managers may aggregate Client trades with their own directed trades or trades for other Clients. Please refer to each Investment Manager’s Form ADV and Envestnet’s ADV for any policies they may have regarding aggregation of trades. 13. Review of Accounts At account opening, Park Avenue, through its IARs, gathers information from a client about that client’s financial situation, risk tolerance, investment objectives and any reasonable restrictions that the client wishes to impose upon the management of the account. Each IAR periodically reviews reports and otherwise consults with the client and contacts the client to review the client’s financial situation and investment objectives. Clients should notify their IARs of any changes in their financial situation, risk tolerance, investment objectives or account restrictions. Park Avenue employs individuals who are registered with the Financial Industry Regulatory Authority (“FINRA”) as principals (the “Registered Principals”), who review all accounts for suitability. Accounts are reviewed by the Registered Principals prior to being opened. Park Avenue Proprietary Program Accounts are monitored on an ongoing basis by Registered Principals. Park Avenue monitors and tracks all financial planning and consulting agreements. All financial plans and consultations must be submitted to Park Avenue for review and approval prior to presentation to a client. If the plan or consultation is approved, the plan or consultation may be presented to the client. Park Avenue provides each client with a quarterly written performance report. Performance information is calculated for all portfolios custodied at Pershing. The quarterly analysis measures performance of the account by comparing such performance against relevant market indices. 55 (4/2026)  14. Client Referrals and Other Compensation Client Referrals Park Avenue and/or its IARs may receive compensation pursuant to solicitation agreements for introducing clients to Third-Party Investment Advisers and for providing certain ongoing services. This compensation is typically equal to a percentage of the investment advisory fee charged by that investment adviser. Because IARs receive compensation from these investment advisers for referring clients and because such compensation may differ depending on the individual agreement with each investment adviser, the IAR has an incentive to recommend one of these Third-Party Investment Advisers over another with which Park Avenue has a less favorable compensation arrangement or alternative investment advisory programs. Full disclosure of all referral arrangements, including Part 2 of Form ADV and a solicitor’s disclosure statement, will be given to the client at the time of referral. Park Avenue has arrangements with several individuals (“Promoters”) under which the Promoters introduce potential advisory clients to Park Avenue in exchange for a referral fee. Whenever Park Avenue pays a referral fee, we require the prospective client to receive a copy of this Brochure and a separate disclosure statement that includes the following information: (1) the Promoter's name and relationship with Park Avenue; (2) the fact that the Promoter is being paid a fee; (3) the amount of the fee; and (4) whether the fee paid to Park Avenue by the client will be increased above our normal fees in order to compensate the Promoter. In general, the advisory fees paid to Park Avenue by clients referred by Promoters are not increased as a result of a referral. Other Compensation and Conflicts We have an incentive to recommend the product or account type that results in additional fees and revenues for us. We can recommend that you invest through different account type arrangements, such as through a brokerage account, an account directly held with the issuer of the investment (or its transfer agent), or an advisory account. Depending on factors such as the type and level of services you require as well as the frequency of trading in your account, one of these account types may be more cost-effective for you than the others. In addition, we receive miscellaneous account and service fees and other compensation (which are in addition to advisory fees) in connection with brokerage accounts or advisory accounts that we do not receive with a directly held account. We can also recommend that you invest in products that have higher up-front compensation along with ongoing trail payments. The availability of different products and account types incentivizes us and our IARs to recommend the product or account type that results in additional fees and revenues for us and your IAR even though another type of account may be more cost-effective for you. How We Address Certain Compensation Related Conflicts of Interest  Park Avenue discloses potential conflicts of interest to clients through documents such as this disclosure document, disclosures on our website and other materials discussing the products and services offered.  Park Avenue credits 12b-1 fees and service fees from mutual funds, other than those associated with the Cash Management Sweep Program, and all FundVest® program fee payments to client accounts within Park Avenue Proprietary Programs.  Park Avenue IARs do not receive any portion of the payments Park Avenue receives under the agreement between Park Avenue and Pershing.  Park Avenue IARs do not receive any portion of the revenue received from mutual fund compensation arrangements, or mutual 12b-1 fees/service fees. Park Avenue does not include within these revenue sharing arrangements assets held within plans covered by Title I of ERISA, or a plan described in Section 4975(e)(1) of the Internal Revenue Code. Listed below are additional payments that Park Avenue receives and the conflicts of interest they create. You should consider these conflicts of interest prior to investing as the receipt of such payments provides a financial incentive for Park Avenue to recommend Park Avenue Proprietary Programs over Third-Party Advisory Programs. 56 (4/2026)  Pershing Additional Payments Through an agreement with Pershing, Park Avenue earns the following payments from Pershing. These payments are not applicable to clients of Third-Party Advisory programs. 1) Park Avenue receives a recurring fixed payment from Pershing annually on the total dollar value of legacy assets transferred from Park Avenue’s previous custodian. 2) Park Avenue receives payments from Pershing on the total amount of assets in client accounts placed on the Pershing custodial platform annually, and for asset growth year over year, which shall also include assets of Park Avenue’s affiliate, Guardian Wealth Partners. This payment excludes the total dollar value of legacy assets transferred from Park Avenue’s previous custodian. The receipt of such payments from Pershing provides a financial incentive for Park Avenue to recommend Park Avenue Proprietary Programs over Third- Party Advisory Programs. 3) Park Avenue receives an annual fixed technology allowance credit in the amount of $200,000 for reasonable and documentable costs incurred by Park Avenue in association with the implementation of technology solutions provided by Pershing, its affiliates and/or other third party providers. 4) Park Avenue receives an annual discretionary fee allowance credit in the amount of $200,000 for Pershing related fees Park Avenue would like to absorb through this credit. 5) Park Avenue earns interest payments on non-purpose loans that have interest rates above the Federal Funds Rate +1.75%. For example, if the interest rate on a non-purpose loan is 5% and the Federal Funds is 3%, Park Avenue will earn .25% of what a client pays (5%-4.5%). The receipt of such payments provides a financial incentive for Park Avenue to recommend and approve non-purpose loans. 6) Pershing agrees to share certain service fees received by Pershing from mutual funds that participate in the FundVest® program. The FundVest® program is an open architecture platform of mutual funds and no- transaction fee mutual funds offered by Pershing. These mutual funds are offered within Park Avenue Proprietary Programs. The percentage of service fees Pershing shares with Park Avenue is based on the level of assets held by Park Avenue clients within the FundVest® program and generally ranges between 50-55% of such services fees received by Pershing from participating mutual funds Furthermore, Park Avenue addresses this conflict by crediting back all FundVest® program fee payments that it receives to clients invested in the Park Avenue Proprietary Programs. For additional details about Pershing’s mutual fund no-transaction-fee program, or a listing of funds that pay Pershing networking or omnibus fees, please refer to www.pershing.com/mutual_fund.htm. 7) Park Avenue has an incentive to have IARs recruited to us transfer their client accounts to Park Avenue because Pershing provides us with rebates for such account transfers. Pershing will reimburse us for out-of- pocket expenses associated with transfer and termination fees upon the successful onboarding of a newly hired IAR who transitions their client accounts from a financial services firm that does not clear through our clearing firm. Dreyfus Insured Deposits Program For the DIDV Bank Sweep each month, depository institutions pay a fee equal to a percentage of the average daily deposit balance in your deposit account(s) at the banks participating in the program (“Program Banks”) to Park Avenue, Pershing, and a third-party administrator. The fee paid to Park Avenue will not exceed 600 basis points (6%) on an annualized basis over a rolling 12-month period. The combined fee paid to Park Avenue, Pershing, and the third-party administrator will not exceed 675 basis points (6.75%) on an annualized basis on the average daily balances held in these deposit accounts over a 12- month rolling period. Park Avenue has discretion in determining the size of the portion of the fee it receives. This directly negatively impacts the interest rate yield client deposits will receive. Park Avenue may waive any portion or the entirety of its share of the fee received from Program Banks. Your IAR will not receive any portion of the fees paid to Program Banks. The amount of fee received by Pershing, Park Avenue, and any other service provider, will affect the interest rate paid in your deposit account(s). Other than applicable fee imposed by Park Avenue on your account (including fees charged on your Pershing, LLC IRAs) there will be no additional charges, fees, or commissions imposed on your account with respect to the DIDV Bank Deposit Sweep. 57 (4/2026)  In order to illustrate the effect of the interest retained by Pershing, Park Avenue and the administrator of the program please consider the following example. If the DIDV sweep is earning a gross interest rate yield of 2% and Park Avenue, Pershing, and the administrator retains 1.65% for administration, then the client rate would be .35%. The receipt of this fee creates an incentive for Park Avenue to select DIDV as the default cash sweep vehicle for the clients who do not select a Money Market Sweep vehicle or have an account which is automatically defaulted to DIDV, as it will result in additional compensation to Park Avenue. In addition, Park Avenue’s discretionary authority in determining its share of the fee creates a conflict of interest due to Park Avenue’s receipt of the fee, which in turn, negatively impacts the interest rate yield client deposits will receive. As disclosed in the Cash Management Sweep Program section, the overflow Money Market Sweep products pay a distribution to Park Avenue which will not be credited to your account. Park Avenue IARs do not receive any portion of the distribution fee and therefore do not have a conflict in recommending a Cash Management Sweep product which pays a distribution. You are encouraged to speak to your IAR regarding the Cash Management Sweep Program vehicle used for your account. Payments from Mutual Funds  Park Avenue receives Rule 12b-1 fees based on client investments in certain mutual funds. Rule 12b-1 fees are annual marketing or distribution fees on a mutual fund. The 12b-1 fee is considered an operational expense and, as such, is included in a fund's expense ratio. Except for 12b-1 fees generated by mutual funds associated with the Cash Management Sweep Program, Park Avenue Proprietary Program accounts will be rebated any 12b-1 fees generated by mutual fund investments within accounts. IAR Additional Compensation Paid by Park Avenue IARs who have a certain level of client assets invested in Park Avenue Proprietary Program accounts will, at the discretion of Park Avenue, receive additional compensation payments from Park Avenue. The receipt of these payments does not impact your Total Client Fee, however, it will incentivize these IARs to recommend a Park Avenue Proprietary Program account to you rather than a Third-Party Investment Advisory Program or other wealth management solution program that would not result in the payment of additional compensation to the IAR based on a level or total amount of client assets within such program. In addition, the calculation of these additional compensation payments will differ between Park Avenue Proprietary Programs resulting in differing amounts of payments to the IAR depending on the invested assets per Park Avenue Proprietary Program. This differential will incentivize IARs to recommend one Park Avenue Proprietary Program over another Park Avenue Proprietary Program. Therefore, the IARs and Park Avenue have a conflict of interest given their financial incentive to recommend that you participate in the Park Avenue Proprietary Programs and services that provide them with the highest rate and amount of overall compensation and benefits, and increase your assets under management in those programs, rather than other available programs and services that result in their receipt of lower or no additional compensation and benefits such as Third-Party Investment Advisory Programs for which IARs do not receive certain additional benefits. Further, Park Avenue and IARs have a conflict of interest as a result of their financial incentive to recommend the Park Avenue Proprietary Programs for which they can negotiate and receive the highest or relatively higher compensation. We address these conflicts of interest by disclosing them to you and requiring that there be a review of your account and transactions at account opening and periodically to determine whether they are appropriate and remain appropriate and in your best interest in light of your investment objectives, financial circumstances, and other characteristics. Guardian Club Credits Certain IARs may receive “Club Credits” for the recommendation of Park Avenue Proprietary Programs, Third- Party Investment Advisory Programs or Financial Planning/Consulting. These “Club Credits” are based upon sales 58 (4/2026)  production and count towards the attainment of various GLIC club memberships. Attainment of various club memberships may entitle IARs to attend GLIC-sponsored conferences. Park Avenue Securities VIP Program Certain IARs will qualify to receive service and financial support, as described in more detail below, based upon their overall sales production. The top 100 Park Avenue sales agents qualify for the VIP program. The qualifications to achieve VIP status are based upon total sales production or Gross Dealer Concession (“GDC”). GDC is the revenue generated via agent sales of brokerage products (i.e., stocks, bonds, mutual funds) and advisory services (i.e., Proprietary Programs, Third Party Investment Advisory Programs and Financial Planning/Consulting). The attainment of this VIP status entitles an IAR to receive a dedicated support person called a Relationship Manager, full or partial waiver of state registration fees and Park Avenue affiliation fees, and “Select Rewards Points.” The “Select Rewards Points” can be used to cover the cost of client account maintenance fees, termination fees, and/or service fees such as fed wire or overnight check fee. The decision to cover certain client costs is at the discretion of your Park Avenue IAR and not all clients will receive this benefit. Park Avenue Securities Pinnacle Council IARs are also eligible to qualify for a club award program called Pinnacle Council. To qualify for Pinnacle Council, an agent must be in the top 20 for total sales production based on the prior year GDC. The benefits of this club award include attendance at an annual recognition conference with paid travel accommodations (i.e., flight and hotel) and meals for the PAS Pinnacle Council qualifier and one guest. Park Avenue Securities Peak Council IARs are also eligible to qualify for a club award program called Peak Council. To qualify for Peak Council, an agent must be in the top 40 (21-40) for total sales production based on the prior year GDC. The benefits of this club award include attendance at an annual recognition conference with paid travel accommodations (i.e., flight and hotel) and meals for the PAS Peak Council qualifier and one guest. These programs create a conflict of interest by incentivizing an IAR to recommend certain products in attempting to qualify for these additional clubs and awards. Transitional Assistance Program (TAP) Park Avenue may offer some recruits the opportunity to obtain bonuses and loans that are dependent upon meeting sales targets. These transition assistance loans may also be forgiven based on years of service with Park Avenue, or its affiliates, assets under management, the amount of production with Park Avenue or its affiliates or the number of clients brought over to Park Avenue. This practice creates a conflict of interest as it provides a financial incentive for an RR or IAR to recommend that a client engage Park Avenue for advisory or brokerage services, and to recommend additional products from Park Avenue or its affiliates. Moreover, some recruits may obtain “early asset bonuses” if they transfer certain percentages of assets to our Firm within a specific timeframe from becoming registered with our Firm. If an RR or IAR has received a transition loan, they are incentivized to encourage the transfer of your account to our Firm so that bonuses can be earned. This conflict is especially acute as your IAR approaches his or her milestone date. The Park Avenue Transition Team will work with an RR or IAR to ensure a successful transition by providing everything from a customized transition plan, tailored training, account opening and account transfer support. The level of support and service received is dependent upon the RR or IARs trailing twelve-month GDC with their prior firm. In addition, if the prior firm does not clear through Pershing, Pershing will reimburse transfer and termination fees up to $125.00 to each client account. 59 (4/2026)  Transitional assistance presents a conflict of interest because of the incentive to affiliate with and recommend Park Avenue to clients. Private Client Group At their discretion, Park Avenue IARs may identify certain clients based on the amount of assets in either or both the Park Avenue Proprietary Investment Advisory Programs or Park Avenue broker-dealer accounts for participation in the Private Client Group program. Private Client Group clients will receive certain benefits which are not available to clients who are not selected for the program. These benefits include but are not limited to access to educational and exclusive private events, discount programs unrelated to services or products offered by Park Avenue as a broker-dealer/registered investment adviser, and specialized Park Avenue services. Many of the services offered by the Private Client Group are also available to clients who are not in the program. Park Avenue IARs have an incentive to select certain clients who have more assets with Park Avenue over other clients who do not have as many assets with Park Avenue. This creates a conflict of interest for Park Avenue and its IARs and incentives clients to maintain a certain level of assets at Park Avenue as well as increase their assets in attempt to qualify for these benefits and services which would generate higher advisory or broker-dealer transactional fees. Not all clients who meet the asset thresholds for membership will be offered invitations to the Private Client Group as invitation is at discretion of the Park Avenue IAR. Payments Related to Park Avenue Educational/Practice Management Conferences iCapital *First Trust Inland Capital Certain product sponsors and vendors pay Park Avenue a fee ranging from $40,000 to $172,000 to participate in Park Avenue sponsored educational/practice management conferences for Park Avenue IARs. In 2026, Park Avenue anticipates it will receive fees from the following:  BlackRock  State Street Global Advisors  Clark Capital  City National Rochdale  Halo   Capital Group/American Funds   Fidelity   Allianz  BNY Mellon  Brighthouse  Jackson  Lincoln  Nationwide  Prudential  Transamerica *First trust will pay Park Avenue the greater of $100,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. See section Revenue Sharing Payments for a description of revenue sharing. Other Compensation (Park Avenue Proprietary & Third-Party Advisory Programs ) Third-Party Advisor Payment Arrangements Park Avenue receives payments from SEI, Orion, and AssetMark as compensation for marketing and administrative services as follows:  SEI pays Park Avenue a flat annual fee. The fee for 2026 is $548,000.  Orion pays Park Avenue a flat annual fee for training and educating Park Avenue IARs. The fee for 2026 is $320,000. 60 (4/2026)   AssetMark pays Park Avenue a flat annual fee. The fee for 2026 is $1,000,000. o OBS, who is owned by AssetMark, pays Park Avenue a flat annual fee. The fee for 2026 is $88,000. You should also be aware that marketing, administrative or educational activities paid for with these payments by these sponsors and vendors lead to greater exposure of their products and services with Park Avenue IARs. Therefore, these payments create an incentive, or lead to a greater likelihood, for Park Avenue or its IARs to recommend a product of these sponsors and vendors over the products or services of a firm which does not pay Park Avenue a fee. Revenue Sharing Payments Certain product sponsors pay Park Avenue additional compensation in the form of revenue sharing. These revenue sharing payments are calculated as an annual percentage of the amount of assets held by Park Avenue customers within sponsor products. Park Avenue may receive compensation of up to 25 basis points (“bps”) on these assets. For example, if you hold a $10,000 position with a sponsor that provides Park Avenue a 25bps payment, Park Avenue will receive $25 from that sponsor. *HPS **First Trust The following product sponsors provide Park Avenue revenue sharing payments:  Open VC., Inc.  CION Ares Management  Hamilton Lane  The Carlyle Group  Janus Henderson   Pimco (Alternative Funds Only)   Allianz  Brighthouse Life Ins.  Equitable  Jackson National  Lincoln Financial  Nationwide  Prudential  Transamerica ***Redbrick  *HPS will pay Park Avenue the greater of $200,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. **First trust will pay Park Avenue the greater of $100,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. ***Redbrick will pay Park Avenue 25 basis points on new sales rather than assets held by Park Avenue customers when Park Avenue customers purchase Redbrick products. Receipt of revenue sharing payments creates a conflict of interest as Park Avenue is incentivized to sell you or recommend you hold investments that provide Park Avenue with such payments rather than investments that do not. In addition, as the payments differ by product sponsor, Park Avenue is incentivized to sell you or recommend you hold investments that provide a higher revenue sharing payment rate than investments that pay Park Avenue a lower revenue sharing payment rate. This conflict of interest is mitigated by the fact that IARs do not receive this firm-paid additional revenue sharing compensation from the product sponsors that provide Park Avenue these revenue sharing payments, and that the firm maintains reasonable policies and procedures to help ensure recommendations are in your best interest. SEI Advisor Benefits Program 61 (4/2026)  This program offers eligible IARs additional levels of service, fee discounts, discounted pricing, invitations to SEI conferences, and an annual marketing budget as the client assets placed in SEI investment solutions increase. Receipt by a Park Avenue IAR of program payments results in a conflict of interest. Clients are encouraged to speak with their IARs if they have any questions regarding the SEI Advisor Benefits Program. Not all Park Avenue IARs qualify to receive benefits pursuant to this program. SEI BusinessWise Program SEI has designed a two-part program that provides technology, integration, and coaching to help Park Avenue IARs who use SEI to build more competitive and sustainable businesses. Park Avenue IARs who participate in this program will have their subscriptions to certain client relationship management software, financial planning software and practice management webinars paid in full. Clients considering an investment in an SEI program should consider whether Park Avenue IAR participation in this program results in a conflict of interest. Clients are encouraged to speak with their IARs if they have any questions regarding the SEI BusinessWise Program. Not all Park Avenue IARs may qualify to receive such benefits pursuant to this program. Although a discontinued program, Park Avenue IARs enrolled in the program may continue to participate in the program. Advisor Benefits Program for Financial Advisors Under AssetMark’s Advisor Benefits Program, Park Avenue IARs are encouraged to utilize AssetMark’s advisor- directed tools, templates and best practices, or to engage with AssetMark to provide education and guidance in implementing a growth plan for their businesses. Certain Park Avenue IARs can receive an allowance or “growth support” for reimbursement of qualified expenses incurred by the Park Avenue IAR based on their participation in AssetMark sponsored events, marketing initiatives, or use of technology resources and tools. This program creates a financial incentive for Park Avenue IARs to recommend that you invest assets through AssetMark. Receipt of these expense reimbursements results in a conflict of interest. Clients are encouraged to speak with their IARs if they have any questions regarding the Advisor Benefits Program for Financial Advisors. AssetMark Community Inspiration Award To promote community involvement, AssetMark created the Community Inspiration Award to honor selected Financial Advisors. AssetMark will make a cash donation, subject to the published rules governing the program, to the Park Avenue IAR’s nominated charity. There is no direct compensation paid to the honored Park Avenue IAR. However, the existence of this program means that a Park Avenue IAR will be inclined to place or retain client assets on the platform because of AssetMark’s contribution to their supported charitable organization. AssetMark Discounted Fee Program AssetMark may grant discounted fee schedules for client accounts associated with Park Avenue offices that have attained certain assets levels with AssetMark. Clients considering an investment in an AssetMark program should ask their IAR whether their office has been granted such fee reduction, which creates conflict of interest. Clients are encouraged to speak with their IARs if they have any questions regarding the AssetMark Discounted Fee Program. Morningstar Managed Portfolio Loyalty Program IARs are eligible to participate in Morningstar’s Managed Portfolio Loyalty Program in which qualifying IARs receive a one-year license for a Morningstar software product at no cost. IARs must meet thresholds for the number of client accounts at Morningstar each year to qualify. 62 (4/2026)  Efficient Advisors, LLC Efficient Advisors, at its discretion, may cover certain marketing and administrative costs which would normally be borne by your IAR. Such payments will increase the net revenue to your IAR and therefore gives your IAR an incentive to refer clients to Efficient Advisors instead of an alternative portfolio manager. Efficient Advisors may also offer your IAR a reduced subscription rate to our affiliate, The Advisor Lab’s, suite of products. The Advisor Lab is a sales and marketing company that markets its services to financial professionals. This discount is generally scaled based on the total amount of assets referred by your IAR to Efficient Advisors and may result in your IAR receiving the subscription at no cost. Matson Money (“Matson”) Discounted Marketing Program Matson sells educational and client coaching products and services to Park Avenue IARs who wish to offer its programs. These products include pamphlets, books, audio compact discs, DVDs, and audio and/or video files of Matson, films or other media outlets that can be downloaded. The initial cost for educational and client coaching products is $12,000. This fee is paid for by your IAR and includes training courses for IARs, some of which are required by Matson prior to permitting participation as a solicitor. Payment for entry which permits IARs to use Matson Money portfolios incentivizes IARs to recommend clients participate in Matson programs to recoup the cost of entry. As the amount of assets referred to Matson by your IAR increases, the amount of marketing assistance provided to your IAR may also increase, at no additional cost. Matson may provide limited or no marketing support to the IAR and reserves the right to terminate its relationship with the IAR if the IAR solicits only a minimal amount of business. However, exceptions have been made at the sole discretion of Matson. From time to time, Matson or a related party may make a charitable contribution to charitable organizations that are related to or supported by a solicitor or co-advisor, which is viewed as a form of indirect compensation. As a result, Matson maintains records of charitable contributions and requires that all contributions be made directly to the charitable organization, a 501(c) (3) organization. No contribution will be made if the contribution implies that continued or future business with Park Avenue or an IAR depends on making such contribution. Clients considering an investment in any of the advisory programs identified above should ask their IAR if they have received any additional benefits via these programs, including but not limited to, free marketing and/or educational materials based on assets solicited or charitable contributions to an organization they support, as these instances result in a conflict of interest. Clients are also encouraged to speak with their IAR if they have any questions regarding any of the aforementioned marketing programs or charitable contributions and how they benefit Park Avenue or your IAR. Third Party Payments For some investments you purchase based on our recommendation, we receive payments from a third-party that are in addition to the advisory fee payments described in this document. For example, certain mutual fund issuers make ongoing payments based on invested assets (and not just new investments), such as 12b-1 fees, shareholder servicing fees or trail compensation. These third-party payments are described in further detail in the prospectus or offering materials for the investment, which will be made available to you in connection with any purchase. Third-party payments incentivize us and your IAR to sell you or recommend you hold investments that bring about such payments rather than investments that do not or result in comparatively lower payments. To mitigate this conflict and as discussed more within this Brochure, Park Avenue credits back to clients invested in Park Avenue Proprietary Program Accounts mutual fund 12b-1 and other service fees it would otherwise receive from mutual fund products, except those generated by the Cash Management Sweep Program. There may be instances where the portfolio managers our IARs recommend periodically pay us based on the total amount of customer assets we direct to them. These payments are sometimes called “revenue sharing” payments 63 (4/2026)  and incentivize us to recommend you hold investments that bring about such payments rather than investments that do not or result in comparatively lower payments. Some third-party portfolio managers may also make payments to us to cover the costs associated with certain educational conferences or training seminars we host for our IARs and to be allowed to present their products during such conferences and seminars. These payments are typically for fixed amounts and are not tied to total sales or customer assets. Even so, these payments incentivize us to recommend you hold investments by these managers that make these flat payments rather than managers that do not make these payments or make comparatively lower payments. Other IAR Conflicts The individual office managers/supervisors are paid based on the performance of the branches or regions they supervise. Our managers and supervisors oversee the sales and marketing activities of our Firm. The compensation of our managers and supervisors is tied to the production levels of branches or regions over which they have managerial or supervisory responsibility. The tying of managers’ and supervisors’ compensation to the production of the branches or regions they supervise incentivizes them to spend more time on increasing production levels in a given branch or region than on their supervisory responsibilities. Some of our IARs receive additional training and support from certain Strategist and Third Party Investment Advisers (“Managers”). Certain Managers and their affiliates provide some of our IARs or their branches with more training and administrative support services than others. If your IAR receives this additional training and support, his or her use of these Managers’ higher level of training and administrative support services incentivizes your IAR to recommend Managers that provide such training and services over issuers that do not. Some of our IARs receive compensation in the form of non-cash compensation or other gifts from vendors or product sponsors to assist with, and defray the expenses associated with educational seminars and client events held by the IAR or a branch office. At times, the amount of compensation provided to a IAR or branch may be dependent on volume of business that individual or branch has attained. IARs may also receive business entertainment from vendors or product sponsors with whom they interact or are authorized to do business. Entertainment engagement may be based on the amount of business placed with the vendors or product sponsors and may incentivize the IAR to place business with that vendor or product sponsor. IARs who are also representatives of the Park Avenue’s parent company, Guardian Life Insurance Company of America, receive employee benefits (i.e., health and pension benefits) that are subsidized by Guardian if the IAR reaches certain sales targets. This subsidization program creates a conflict of interest as it encourages more sales that result in your Financial Professional meeting these sales targets to obtain additional subsidies. Some IARs have outside business activities that compete for their time or may influence their recommendations. If your IAR engages in any outside business activities, these activities can incentivize your IAR to spend more time on the outside business activity rather than his or her advisory relationship with you. In addition, if the outside business activity provides your IAR a higher rate of compensation, your IAR can be incentivized to recommend the outside business activity rather than a brokerage or advisory service offered by Park Avenue. You may research any outside business activities your IAR may have on FINRA’s BrokerCheck website at https://brokercheck.finra.org/. Certain IARs may enter into loans or other lending arrangements in order to expand their own business or purchase other books of business. When IARs enter into these lending arrangements the debt incurred can otherwise impact the IAR’s overall compensation received throughout any particular time-period. The amount of debt incurred and these lending scenarios could influence the manner in which the IAR attempts to earn additional transactional-based commissions when acting in their capacity as a registered representative of Park Avenue (commissions paid for the recommendation and sale of securities products) or investment advisory fees when acting in their capacity as an IAR (investment advisory fees for the ongoing advice provided to you) in order to meet their own personal debt obligations which may also indirectly influence their advice and recommendations made to you as their client. 64 (4/2026)  15. Custody Although Park Avenue’s Proprietary Program Account assets are held by a qualified custodian, Park Avenue is deemed to have custody of client funds because it has the ability to direct such custodians to deduct advisory fees from the client’s account and because some client accounts have standing letters of instruction (“SLOAs”) or other similar asset transfer authorization agreements which gives us the authority to transfer funds to a third-party. Park Avenue provides quarterly performance reports to clients. Clients also receive at least quarterly statements from Pershing. Park Avenue urges you to carefully review such statements and compare such official custodial records to the quarterly performance reports that we provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Clients should be aware that the performance reports are not official account statements. It should be used only for informational purposes and should not be relied upon for making investment decisions or for tax purposes. Clients should promptly notify the Firm or his/her IAR upon discovery of any errors, discrepancies, or irregularities. 16. Investment Discretion FoundationsSM, Quantitative InnovationsSM, Park Avenue Strategist SelectSM, Park Avenue Strategist Select PlusSM, Park Avenue UMA SelectSM, Park Avenue SMA SelectSM, Park Avenue Signature PortfolioSM and VestWise™ are discretionary advisory programs. FoundationsSM, Quantitative InnovationsSM, Park Avenue Strategist SelectSM, Park Avenue Strategist Select PlusSM and VestWise™ use model portfolios that invest in selected mutual funds, ETFs, or other securities. In these programs, a client directs the applicable investment manager (Park Avenue or a Platform-Manager or Strategist, depending on the program selected) to invest the client’s program assets in accordance with the client’s investment objectives and the model portfolio chosen by the client. The client further directs and authorizes the applicable investment manager at its discretion to reallocate or rebalance the client’s investments in the account in accordance with adjustments made by the applicable investment manager to the model portfolio underlying the client’s investment objectives. By executing the investment advisory agreement, the client appoints the applicable investment manager as the client’s agent and attorney-in-fact with full discretion to execute the transactions within the client’s account without first seeking approval from or discussing these investment decisions with the client. For all Park Avenue Proprietary Programs, Envestnet is granted the authority to buy and sell securities and investments to perform rebalancing or other such discretionary authorities you agree upon. Envestnet shall be authorized to delegate the investment discretion described above to the Investment Manager. Each Investment Manager is responsible for selecting the securities for your investment in the investment strategy of such Investment Manager, including the share class if the investment strategy contains mutual funds. You also grant Park Avenue authority to open multiple custodial accounts based upon one account application for each Investment Manager strategy you choose. Park Avenue and/or the applicable Platform Manager or Strategist receives discretionary authority from the client at the outset of a discretionary advisory relationship to make all investment decisions with respect to the client’s account, consistent with the client’s investment objectives. As permitted in the client’s investment advisory agreement, a Platform-Manager or Strategist may act in the role of a model portfolio provider for FoundationsSM, Quantitative InnovationsSM, Park Avenue Strategist SelectSM or Park Avenue Strategist Select PlusSM. Park Avenue may also periodically provide investment advice to the client, including recommendations related to the management of program assets by one or more Platform-Managers or Strategists, subject to the approval of the client. When selecting securities and determining amounts, Park Avenue observes the investment policies, limitations and any reasonable restrictions placed by the client relating to the client’s account. When electing a third-party Investment Manager within the UMA Select program, 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 65 (4/2026)  Manager may directly trade client assets within the UMA Select Program instead of providing an Investment Model. In those instances, Envestnet shall be authorized to delegate the investment discretion described above to the Investment Manager. The discretionary Investment Manager is responsible for selecting the securities for client investment, including the share class if the investment is in mutual funds. Park Avenue may periodically provide investment advice to you on a non-discretionary basis only, subject to your approval, in a manner consistent with your investment objectives and Investor Risk Rating. 17. Voting Client Securities As a matter of firm policy and practice, Park Avenue generally does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Each Park Avenue wrap fee program and Third-Party Adviser has its own Wrap Fee Brochure which describes voting client securities for each program. Please refer to the applicable Wrap Fee Brochure for additional information. Park Avenue clients will receive proxies directly from the custodian, Pershing. For questions regarding proxies, clients may contact our Home Office at (888) 600-4667. 18. Financial Information A copy of Park Avenue Securities’ most recent financial statement is attached. Park Avenue does not have any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients. 66 (4/2026)  Park Avenue Securities LLC Notes to Statement of Financial Condition December 31, 2025 19. Report of Independent Registered Public Accounting Firm Report of Independent Registered Public Account Firm To the Board of Managers and Member of Park Avenue Securities LLC Opinion on the Financial Statement – Statement of Financial Condition We have audited the accompanying Statement of Financial Condition of Park Avenue Securities LLC (the “Company”) as of December 31, 2025, including the related notes (collectively referred to as the “financial statement”). In our opinion, the financial statement presents fairly, in all material respects, the financial position of the Company as of December 31, 2025 in conformity with accounting principles generally accepted in the United States of America. Basis for Opinion The financial statement is the responsibility of the Company’s management. Our responsibility is to express an opinion on the Company's financial statement based on our audit. We are a public accounting firm registered with the Public Company Accounting Oversight Board (United States) (PCAOB) and are required to be independent with respect to the Company in accordance with the U.S. federal securities laws and the applicable rules and regulations of the Securities and Exchange Commission and the PCAOB. We conducted our audit of this financial statement in accordance with the standards of the PCAOB. Those standards require that we plan and perform the audit to obtain reasonable assurance about whether the financial statement is free of material misstatement, whether due to error or fraud. Our audit included performing procedures to assess the risks of material misstatement of the financial statement, whether due to error or fraud, and performing procedures that respond to those risks. Such procedures included examining, on a test basis, evidence regarding the amounts and disclosures in the financial statement. Our audit also included evaluating the accounting principles used and significant estimates made by management, as well as evaluating the overall presentation of the financial statement. We believe that our audit provides a reasonable basis for our opinion. New York, NY February 26, 2026 We have served as the Company's auditor since 1999. www.pwc.com PricewaterhouseCoopers LLP, 300 Madison Avenue, New York, NY 10017 T: (646) 471 3000 67 (4/2026)  Park Avenue Securities LLC Notes to Statement of Financial Condition December 31, 2025 20. Statement of Financial Condition See accompanying notes to financial statement below. 68 (4/2026)  21. Notes to Statement of Financial Condition 1. Organization and Nature of Business Park Avenue Securities LLC (the “Company”) is a registered broker-dealer with the Securities and Exchange Commission (“SEC”) and is a member of the Financial Industry Regulatory Authority (“FINRA”) and Securities Investor Protection Corporation (“SIPC”). The Company is also a registered investment advisor under the Investment Advisers Act of 1940 and a Delaware Limited Liability company. The Company is a wholly owned subsidiary of The Guardian Life Insurance Company of America (“Guardian Life”). The Company, through its affiliate, The Guardian Insurance and Annuity Company Inc (“GIAC”), employs agencies as its distribution system through which all securities transactions are conducted. All agencies are subject to an Agency Agreement with GIAC that outlines the rights and responsibilities of GIAC and its affiliates. Registered representatives and investment advisors are agency employees whose rights and responsibilities are governed by a Registered Representative Agreement or Investment Advisor Representative Agreement, respectively, by and between the Company and the representative. The Company’s business as a securities broker-dealer consists of selling products currently offered by GIAC as well as third party sponsors to retail customers. Such products include mutual funds, variable annuities, variable life insurance, 401(k) plan and investment advisory services. Brokerage transactions are executed by the Company on behalf of its customers and are conducted on an agency or riskless principal basis and are introduced on a fully disclosed basis to Pershing LLC (the “Clearing Broker”). The Company does not carry customer accounts or perform custodial functions related to customer securities. Direct customer transactions are executed by third party sponsors, or GIAC on behalf of the customers. The Company also acts as a broker in the purchase and sale of securities which are conducted on a give-up basis. 2. Significant Accounting Policies Basis of Presentation The Company’s financial statements are prepared in accordance with generally accepted accounting principles in the United States of America (“GAAP”). Use of Estimates The preparation of these financial statements in conformity with GAAP requires management to make estimates and assumptions that affect the reported amounts of assets and liabilities and disclosure of contingent assets and liabilities at the date of the financial statements, as well as the reported amounts of revenues and expenses during the accounting period. Actual results could differ from those estimates. Cash, Cash Equivalents and Restricted Cash Cash and cash equivalents include amounts on deposit with banks and highly liquid investments with an original maturity of three months or less. They are reported at cost, which approximates fair value because of the relatively short period of time between their origination and expected maturity. Cash segregated in compliance with federal and other regulations represents restricted cash segregated for the exclusive benefit of customers of the Company. Receivable from clearing Broker-Dealer The Company clears certain customer transactions through the clearing broker. The Receivable from broker- dealer includes advisory fees, annual account fees and non-proprietary trail commission receivable. Receivables from clearing broker-dealer are stated net of a provision for credit losses, which is estimated based upon the evaluation of historical loss experience and management’s forecasts. The opening balance in this account as of 69 (4/2026)  January 1, 2025, was $14,855,129, which is net of allowance for credit losses of $10,828. During 2025, there were no write-offs related to this account. The increase in allowance for credit losses of $1,828 was included in Other Expenses. Receivable from Registered Representatives Receivable from registered representatives relates to annual fees (registered representative fees) charged for support functions, such as technology tools, licensing, compliance and regulatory oversight, and administrative services. Receivables are stated net of a provision for credit losses, which is estimated based upon the evaluation of aging, specific exposures, historical loss experience and management’s forecasts. The opening balance in this account as of January 1, 2025, was $3,709,162, which is net of allowance for credit losses of $7,166. During 2025, there were write offs of $200,491. The increase in allowance for credit losses of $82,848 was included in Other Expenses. Advisory Loans Advisor loans represent financial assistance provided to support the General Agencies in the recruitment of Financial Professionals. Agency loans are stated net of a provision for credit losses, which is estimated based upon the evaluation of historical loss experience and management’s forecasts. The opening balance in this account as of January 1, 2025, was $3,390,923, which is net of allowance for credit losses of $5,092,783. During 2025, there were write offs of $19,770. The decrease in allowance for credit losses of $314,916 was included in Other Expenses Commissions Receivable All transactions, other than those cleared through the clearing broker, represent activity conducted directly between the client and third-party sponsors. Commissions receivable include investment advisory service fees receivable from turnkey asset management programs (TAMPs), direct sponsor trailing commissions from mutual funds and revenue sharing receipts. Commissions receivable are stated net of a provision for credit losses, which is estimated based upon the evaluation of historical loss experience and management’s forecasts. The opening balance in this account as of January 1, 2025, was $11,536,466, which is net of allowance for credit losses of $57,972. During 2025, there were no write offs or recoveries related to this account. The increase in allowance for credit losses of $3,818 was included in Other Expenses. Other Assets Other Assets include prepaid licensing fees, agents’ non-cash credit balances, and prepaid expenses. The opening balance in this account as of January 1, 2025, was $2,341,484, which is net of allowance for credit losses of $33,179. During 2025, there were no write offs. The increase in allowance for credit losses of $25,240 was included in Other Expenses. Due to Guardian Life Amounts payable consist of general operating expenses payable to Guardian Life under an intercompany agreement. Commissions payable The Company remits commissions payments to the registered representatives on behalf of the general agents. Commissions payable represent balances owed to the registered representatives. Other Liabilities Other liabilities include reserves for loss contingencies and unpaid operating expenses. There was no accrual made for loss contingencies at year end. See Note 9 for further discussion of Contingencies. Income Taxes 70 (4/2026)  The Company is organized as a limited liability company and is treated as a disregarded entity for federal and state income tax purposes. The Company's results are included in Guardian Life's proforma federal income tax return, which is ultimately included in the consolidated federal income tax return of Guardian Life. The Internal Revenue Code ("the Code") limits the amount of non-life insurance losses that may offset life insurance company taxable income. The consolidated income tax liability is allocated among the members of the group in accordance with a tax allocation agreement. The tax allocation agreement provides that each member of the group is allocated its share of the consolidated tax provision or benefit, determined generally on a separate company basis, but may, where applicable, recognize the tax benefits of net operating losses or capital losses utilizable in the consolidated group. For state tax purposes, since Guardian Life is an insurance company, it is generally subject to tax on gross premium rather than tax on income. However, in those years where Guardian Life is subject to a state income tax, such income will be subject to the group's tax allocation agreement. Intercompany tax balances are settled quarterly on an estimated basis with a final settlement within 30 days of the filing of the consolidated return. Current Federal income taxes are charged or credited to operations based upon amounts estimated to be payable or recoverable as a result of taxable operations for the current year and any adjustments to such estimates from prior years. Deferred Federal income tax assets ("DTA's") and liabilities ("DTL's") are recognized for expected future tax consequences of temporary differences between GAAP and taxable income. Temporary differences are identified and measured using a balance sheet approach whereby GAAP and tax balance sheets are compared. Deferred income tax assets and liabilities are recognized for the future tax consequence of temporary differences between financial statement carrying amounts and income tax basis of assets and liabilities. The Company determines whether it is more-likely-than-not that a tax position will be sustained upon examination by the appropriate taxing authorities before any part of the benefit can be recorded in the financial statements. The amount of tax benefit recognized for an uncertain tax position is the largest amount of benefit that is greater than 50 percent likely of being realized upon settlement. Unrecognized tax benefits are included within the Statement of Financial Condition and are charged to earnings in the period that such determination is made. The Company classifies interest and penalties related to tax uncertainties as “income tax expense” in the accompanying Statement of Operations. Recent Accounting Pronouncements Measurement of Credit Losses for Accounts Receivable and Contract Assets In July 2025, the FASB issued guidance that provides a practical expedient for all entities and an accounting policy election for entities other than public business entities related to current accounts receivable and current contracts assets accounted for under Topic 606. Under the practical expedient, entities may assume that current conditions as of the balance sheet date remain unchanged for the remaining life of the asset when estimating expected credit losses. This standard is effective for annual reporting periods beginning after December 15, 2026 and applied prospectively. Early adoption is permitted. The Company is currently assessing the impact of the guidance on the Company’s financial statements. Reporting Comprehensive Income—Expense Disaggregation Disclosures In November 2024, the FASB issued guidance that requires public business entities to disclose, in the notes to the financial statements, additional information about certain costs and expenses included in the income statement. Subsequently, in January 2025, the FASB clarifies the effective date for non-calendar year-end entities. This standard is effective for annual reporting periods beginning after December 15, 2026. Early adoption is permitted. The Company is currently assessing the impact of the guidance on the Company’s financial statements. 71 (4/2026)  Income Taxes (Topic 740): Improvements to Income Tax Disclosure (ASU 2023-09) In December of 2023, the FASB issued ASU 2023-09, “Improvements to Income Tax Disclosures” which requires disaggregated information about a reporting entity’s effective tax rate reconciliation, information on income taxes paid, and contain other disclosure requirements. This ASU is effective for annual periods beginning after December 15, 2024, with early adoption permitted. Upon the effective date, the amendments should be applied prospectively with retrospective application permitted. The Company adopted the amendments of ASU 2023-09 for its fiscal year ending December 31, 2025. The adoption of ASU 2023-09 only impacted the income tax disclosures within the Company's financial statements and did not impact amounts reported on the Company's Statement of Financial Condition, Statement of Operations, Statement of Changes in Member’s Equity and Statement of Cash Flows. The Company has not adopted any other new accounting pronouncements that had a material impact on its consolidated financial statements. 3. Related Party Transactions A significant portion of the Company’s revenues and expenses relate to transactions with Guardian Life and its affiliates. Pursuant to an expense sharing agreement, Guardian Life charges the Company on a monthly basis for the services of certain employees of Guardian Life engaged in the Company’s business and for the Company’s use of Guardian Life’s centralized services. The Company settles those transactions with Guardian Life on a monthly basis. During 2025, the amounts charged for these services amounted to $77,975,140 which is comprised of general and administrative expenses, as defined in Note 2 of $75,074,531 and payroll and sales taxes of $2,900,609. The Due to Guardian Life under this agreement was $18,239,449. Refer to Note 6 for Income Tax related party transactions. During the year, the Company earned revenues of $24,706,274 from GIAC for sales of GIAC’s variable annuity and variable life insurance products, which is included in Commissions. The receivable for such revenues was $586,840 and is included in Commissions receivable. In 2025, the Company distributed dividends and return of capital totaling $20,000,000 to Guardian Life. 4. Reportable Segment The Company is engaged in a single line of business as a securities broker-dealer. The Company has identified its President as the chief operating decision maker (“CODM”), who uses net income to evaluate the results of the business, predominantly in the forecasting process, to manage the Company. Additionally, the CODM uses excess net capital (see Schedule I), which is not a measure of profit and loss, to make operational decisions while maintaining capital adequacy, such as whether to pay dividends. The Company’s operations constitute a single operating segment and therefore, a single reportable segment, because the CODM manages the business activities using information of the Company as a whole. The accounting policies used to measure the profit and loss of the segment are the same as those described in the significant accounting policies. 5. Fair Value of Financial Instruments Fair value is defined as the price that would be received to sell an asset or paid to transfer a liability in an orderly transaction between market participants at the measurement date. Fair value measurements are based on observable and unobservable inputs. Observable inputs reflect market data obtained from independent sources, while unobservable inputs reflect the Company’s view of market assumptions based on internally developed data 72 (4/2026)  in the absence of observable market information. The guidance requires entities to maximize the use of observable inputs and minimize the use of unobservable inputs when determining the fair value of an asset or liability. The statement classifies all assets and liabilities carried or disclosed at fair value in one of the following three categories: Level 1 – inputs are quoted market prices available in active markets for identical assets or liabilities on the reporting date. Level 2 – inputs are quoted prices for similar instruments in active markets, quoted prices for identical or similar instruments in markets that are not active and model derived valuations whose inputs are observable or whose significant value drivers are observable . Level 3 – significant inputs are unobservable where there is little or no market activity for the asset or liability and the Company makes estimates and assumptions based on internally derived information and other analytical techniques. In determining fair value, the carrying value of Cash and cash equivalents, Cash segregated in compliance with federal and other regulations, receivable from broker-dealer, commissions receivable and payables arising in the ordinary course of business approximate fair value because of the relatively short period of time between their origination and expected maturity or because we expect the assets and liabilities to be settled within a period of one year. There were no level 3 assets or liabilities carried at fair value as of December 31, 2025. 6. Income Taxes A summary of the net income tax expense included in the accompanying Statement of Operations is as follows: The Company’s Income Tax expense for the year ended December 31, 2025 differs from the amount computed by applying the expected federal income tax rate of 21% to income before income taxes for the following reasons: As of December 31, 2025, the Company had no unrecognized tax benefits or related interest expenses. The components of the net deferred tax asset as of December 31, 2024, were as follows: 73 (4/2026)  Deferred income taxes are generally recognized, based on enacted tax rates, when assets and liabilities have different values for financial statement and tax purposes. A valuation allowance is recorded if it is more likely than not that some portion or all of the deferred tax asset will not be realized. The Company’s management has concluded that the deferred tax assets are more likely than not to be realized. Therefore, no valuation allowance has been provided. At December 31, 2025, the Company recorded a current income tax recoverable of $544,240 due from Guardian Life in the accompanying Statement of Financial Condition and is included in Amounts due from Guardian Life. The components of income taxed paid by jurisdiction as of December 31, 2025, were as follows: As of December 31, 2025, there were no state jurisdictions where taxes paid exceeded the 5% of income taxes paid (net of refunds) threshold. The Inflation Reduction Act was enacted into law on August 16, 2022. This provision imposes a 15% Corporate Alternative Minimum Tax (“CAMT”) on adjusted financial statement income (“AFSI”) for applicable corporation with average annual AFSI over a three-year period in excess of $1 billion effective for taxable years beginning after December 31, 2022. As of December 31, 2025 management has determined that Guardian Life and its subsidiaries is not subject to CAMT in 2025. Guardian Life files U.S. federal income tax returns along with various state and local income tax returns. The Company’s federal income tax returns are routinely examined by the Internal Revenue service (“IRS”) and provisions are made in the financial statements in anticipation of the results of these audits. Tax years 2015 through 2023 are subject to examination by the IRS. The Company believes that it has established adequate tax liabilities for uncertain tax positions for all open years. 74 (4/2026)  7. Regulatory Requirements The Company is subject to the Uniform Net Capital requirements of the SEC under Rule 15c3-1, which requires that the Company maintain net capital equal to the greater of $250,000 or 6 2/3% of aggregate indebtedness. The Company had net capital of $80,153,935 which was $77,115,244 above the $3,038,691 required to be maintained. The ratio of aggregate indebtedness to net capital was 0.57 to 1. The Company claims an exemption from Rule 15c3-3 of the Securities Exchange Act of 1934 under paragraphs (k)(2)(i) and (k)(2)(ii) of that rule. The Company is also subject to Footnote 74 of the SEC Release No. 34-70073 adopting amendments to 17 C.F.R. § 240.17a-5 because the Company limits its business activities exclusively to: (1) proprietary trading; (2) effecting securities transactions via subscriptions on a subscription way basis where the funds are payable to the issuer or its agent and not to the Company. 8. Off-Balance Sheet Risk In the normal course of business, securities transactions of customers are introduced and cleared through a third-party clearing broker. Pursuant to an agreement between the Company and the clearing broker, the clearing broker has the right to charge the Company for certain losses that result from transactions with such customers. Direct customer transactions executed by third party sponsors on behalf of the customers may expose the Company to off-balance-sheet risk in the event the customer is unable to fulfill its contractual obligations and the Company has to sell the investment product at a loss. The Company’s policy is to monitor its customer and counterparty risk through the use of a variety of credit exposure reporting and control procedures, including reviewing, as considered necessary, the credit standing of each counterparty and customer with which it conducts business. The Company, in its normal course of business, may enter into other legal contracts that contain several of these representations and warranties which provide general indemnifications. The Company’s maximum exposure under these arrangements is unknown as this would involve future claims that may be against the Company that have not yet occurred. However, based on its experience, the Company expects the risk of loss to be remote . 9. Contingencies The Company may be engaged in various disputes, litigations, governmental regulatory inquiries and other proceedings arising out of its business operations. These matters could result in losses, monetary damages, fines, penalties or changes in the business operations of the Company. Due to the uncertainties inherent in these disputes, it is difficult to determine the ultimate loss the Company will experience. The Company evaluates each matter and establishes an accrual where a loss is probable, and the amount can be reasonably estimated. The Company also evaluates these matters for a reasonably possible range of loss. Due to the uncertainties inherent in these matters, such as timing of discovery and court decisions, the Company is not able to ascertain a reasonably possible range of loss for each matter. In the opinion of Management, as of December 31, 2025, the aggregate range of reasonably possible loss for those matters it is able to provide an estimate for is not material to the Company’s financial position. 10. Subsequent Events The Company considers events occurring after the Statement of Financial Condition date through February 26, 2026, the issuance date of the financial statements, to be subsequent events. There were no subsequent events through February 26, 2026, the date the financial statements were available to be issued that affect the Company's financial statement or require additional disclosure. 75 (4/2026) 

Park Avenue Securities LLC 10 Hudson Yards New York, NY10001 Phone: 888-600-4667 Web: https://www.parkavenuesecurities.com/ April 23, 2026 VestWiseTM Wrap Fee Program Brochure This wrap fee program brochure (“Brochure”) provides information about the qualifications and business practices of Park Avenue Securities LLC (“PAS”). If you have any questions about the contents of this Brochure or would like to obtain a free copy of this Brochure, please contact us at (888) 600-4667 or visit https://www.parkavenuesecurities.com/. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about PAS is also available on the SEC’s website at https://adviserinfo.sec.gov/. PAS is a registered investment adviser and conducts its business under marketing name Park Avenue® Wealth Management. Registration as an investment adviser does not imply a certain level of skill or training. PAS017974-VestWise (4/2026)  2. Material Changes Park Avenue Securities, LLC. (“PAS”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”) conducting business under marketing name Park Avenue® Wealth Management (“Park Avenue”, the “Firm”, “we”, “our” or “us”). Pursuant to SEC rules, this item summarizes the specific material changes, if any, that have been made to this Form ADV VestWise Wrap Fee Program disclosure brochure (“Brochure”) since the last annual update of this Brochure on March 19, 2025. When required or appropriate, we will also provide clients interim summary updates of material changes to this Brochure. You are strongly encouraged to read this Brochure in detail and contact your investment adviser representative (“IAR”) with any questions. Clients may ask for a copy of our current Brochure, which includes all material changes since the previous Brochure, or a summary of material changes to the previous Brochure at any time, without charge, by contacting us at (888) 600-4667 or via the Contact Us link at https://www.parkavenuesecurities.com/. Clients may also obtain a copy of this Brochure or a copy of any other of our Form ADV disclosure brochure by accessing and downloading them from our website at https://www.parkavenuesecurities.com/ under Form ADV Brochures. The following is a summary of material changes to this Brochure since the last annual update on March 19, 2025. April 23, 2026 Update Park Avenue Securities LLC begins operating under the marketing name Park Avenue® Wealth Management. Our legal name remains Park Avenue Securities LLC, and we will continue to be the registered investment adviser providing your advisory services. March 20, 2026 Update Item 9. Additional Information:  Disclosure and descriptions of IAR conflicts related to outside business activities and IAR loan/lending arrangements are provided under section Other IAR Conflicts. December 31, 2025 Update Item 9. Additional Information:  Information has been added related to PAS’s parent company, The Guardian Life Insurance Company of America (“GLIC”), obtaining warrants from Hamilton Lane and Hamilton Lane’s management of a portfolio of GLIC’s general account.  Additional information has been added regarding third-party payments in the form of revenue sharing being paid to PAS. March 19, 2025 Update Item 4. Services, Fees and Compensation:  Additional disclosures and descriptions related to program fees paid to PAS for the PAS Proprietary Programs and the Cash Management Sweep Program. 2 PAS017974-VestWise (4/2026)   Additional disclosures and descriptions of available accounts and relationships with PAS’ lending services, and PAS’ capacity as broker-dealer of record on all PAS Proprietary Program accounts. Item 9. Additional Information  Additional disclosure and descriptions related to client referrals and other compensation.  Additional language regarding PAS being deemed to have custody of certain client funds. 3 PAS017974-VestWise (4/2026)  3. Table of Contents Section: Page: 1. Cover Page ....................................................................................................................................................... 1 2. Material Changes .............................................................................................................................................. 2 3. Table of Contents. ............................................................................................................................................. 4 4. Services, Fees and Compensation ................................................................................................................... 5 5. Account Requirements and Types of Clients .................................................................................................. 18 6. ETF Selection and Evaluation ......................................................................................................................... 19 7. Client Information Provided to Portfolio Managers .......................................................................................... 23 8. Client Contact with Portfolio Managers ........................................................................................................... 23 9. Additional Information. ..................................................................................................................................... 23 PAS017974-VestWise (4/2026) 4  4. Services, Fees and Compensation Park Avenue Securities LLC (“PAS”), doing business under the marketing name Park Avenue® Wealth Management (“Park Avenue”, the “Firm”, “we”, “our” or “us”), is a dually registered broker-dealer and investment adviser that makes available to you a number of proprietary and non-proprietary investment advisory programs and services. VestWise™ is the branded name for our automated or digital (i.e., internet/web-based) investment advisory solution. We act as the sponsor and the discretionary investment manager for this program, which means we are 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 and open an account, we use this discretion to make changes to the holdings within the account over time consistent with the strategy you have elected. If you wish to learn about other investment advisory programs and services that we offer, you may contact us by calling (888) 600-4667 or go to www.parkavenuesecurities.com to receive a similar disclosure brochure for those programs and services. VestWise is a wrap fee program. Wrap fee programs bundle together several service providers: an investment adviser, a broker-dealer, a clearing firm, and a custodian, and offer most of these services for a single advisory fee. Except as otherwise disclosed in this Brochure, there are no individual ticket charges assessed to the client for trades within a wrap fee program. Some clients prefer to have the various services "packaged" together within a wrap fee program; others prefer to select their own providers for the various services needed to manage their investments. Similarly, some clients prefer a fee structure that converts trading costs into an asset-based fee calculated on the same basis as advisory fees; others prefer trading costs to be assessed on a per trade basis. Depending on a number of factors, such as the number of transactions, number of shares, and nature of the securities transactions in an advisory account, the overall fees and charges borne by the client over time could be more or less than what these fees and charges would be if the same services were provided on a separate basis. Understanding your Relationship with Park Avenue We are subject to the Investment Advisers Act of 1940, as amended (the “Advisers Act”), and as a registered investment adviser, we, along with our IARs, have a fiduciary duty to you. This generally means that Park Avenue and our IARs will act in your best interest when providing investment advice under the Advisers Act and will disclose or avoid material conflicts of interest. Throughout the various sections of this Brochure we have identified conflicts of interest within specific sections that are otherwise describing the services we provide or the fees or compensation we or our IAR’s receive. Within the advisory programs described in this Brochure, we provide services as an investment adviser under the Advisers Act. In providing investment advice, your Park Avenue Investment Adviser Representative (“IAR”) can select from among different products and programs. This includes the advisory program described in this brochure and other advisory programs described in Park Avenue Firm Brochure. Your IAR can also act in his or her capacity as a registered representative of Park Avenue providing securities recommendations in a Park Avenue 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 Park Avenue. You should discuss the benefits and costs associated with the different advisory programs available at Park Avenue 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 IARs ongoing obligations when acting as an IAR versus a registered representative. Certain of our IARs market their practices using marketing names that differ from the name under which we 5 PAS017974-VestWise (4/2026)  primarily conducts its advisory business. In these circumstances, clients should be aware that all investment advisory services described herein are provided by IARs through and on our behalf, not the marketing names that IARs use to market their practices. Our IARs assist clients in pursuing their financial goals by providing personalized financial planning services and investment solutions. Any information you receive from us or our IARs relating to tax considerations affecting your financial arrangements or transactions is not intended to be tax advice and you should not rely upon it as tax advice. Neither we nor our IARs provide tax, legal, or accounting advice. AVAILABLE ACCOUNTS AND RELATIONSHIP TYPES When you choose to purchase products and services through us and work with our financial professionals, you have the option of investing through a transaction-based account, such as a brokerage account, a fee-based investment advisory account, or both. It is important for you to understand the services you will receive, the fees, costs, and expenses you will pay, and conflicts of interest of ours and of your financial professional in connection with each of these different types of accounts and relationships with us and your financial professional. The services, fees, costs, expenses, and conflicts of interest are summarized below and described in much greater detail in our Form CRS, Regulation Best Interest (“Reg BI”) Disclosure Document and Forms ADV, Part 2A, as applicable, which are available on our website at https://www.parkavenuesecurities.com/. In addition, if considering investing into a Third-Party Investment Advisory Program, you are encouraged to review the Third- Party Investment Adviser’s Form ADV Part 2 which will contain important information such as the program fees and expenses and any conflicts of interest of the Third-Party Investment Adviser which may exist. Transaction-Based Account, Such as a Brokerage Account As a broker-dealer, we offer 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, we may offer general, impersonal investment advice in the form of publications and other services. We will not be deemed to be providing investment advisory services unless it has entered into a contract with the client for that purpose. With a transaction-based account, such as a brokerage account, you will pay commissions and other charges (such as sales loads on mutual funds and other securities and investment products) at the time of each transaction, such as the purchase or sale of a mutual fund, stock, bond, option, Alternative Investments (“AI”), or other security or investment product. These commissions and other charges are Park Avenue’s and your Park Avenue financial professional’s primary source of compensation for the transaction-based advice your Park Avenue financial professional provides when recommending such transactions. When serving as your broker, your Park Avenue financial professional can make recommendations and provide guidance to you in selecting securities, other investment products, and services. Your Park Avenue financial professional may also provide investment education and research services, which are incidental to the brokerage services Park Avenue provides. A transaction-based account can potentially be more appropriate for you than a fee-based investment advisory account if you do not want ongoing investment advice on assets held in your account, or ongoing management of your account, and instead want only periodic or on-demand advice and recommendations specific to the purchase and sale of securities and other investment products. Additionally, this type of account can potentially result in lower costs for you if you expect to trade on an infrequent or occasional basis. When Park Avenue and your Park Avenue financial professional make securities and investment strategy recommendations to you as broker-dealer for your transaction-based account, such as a brokerage account, Park Avenue and your Park Avenue financial professional will be acting in their broker-dealer capacities for such account and are required to act in your best interest, without placing their financial or other interests ahead of your interests. You should be aware that Park Avenue and Park Avenue financial professionals are subject to various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles Park Avenue 6 PAS017974-VestWise (4/2026)  and your Park Avenue financial professional play in a transaction, Park Avenue’s and your Park Avenue financial professional’s compensation arrangements, and Park Avenue’s financial and other arrangements with custodians, clearing firms, and other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in our Form CRS and Reg BI Disclosure Document, as well in the other important client disclosures available on our website, https://www.parkavenuesecurities.com/. An advisory account may not be appropriate for low trade volume activity, if you have a long term buy-and- hold investment strategy, or if you prefer to direct Park Avenue 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 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. For additional information on our broker-dealer services and transaction-based account offerings, please see our Form CRS and Reg BI Disclosure Document, which are available on our website at www.parkavenuesecurities.com. Our Form CRS and Reg BI Disclosure Document may also be requested by contacting Park Avenue at (888) 600-4667 or via the Contact Us link at https://www.parkavenuesecurities.com/. For detailed information regarding the commissions, trading/execution fees, and brokerage service charges that Park Avenue establishes, controls, and charges clients when serving as a broker-dealer of record for transaction-based accounts held with Pershing, LLC (“Pershing”) as our clearing firm and custodian, please see our Fee and Commission Schedule for Accounts with Pershing (the “Client Fee Schedule”) which is provided to you at account opening, will change over time, and can be found on our website at www.parkavenuesecurities. Before consenting to any broker-dealer relationship with us or our financial professionals, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation we and its financial professionals will receive, and Park Avenue’s and our financial professionals’ conflicts of interest. After reviewing these disclosures, please address any questions you may have with your Park Avenue financial professional. Fee-Based Investment Advisory Account A fee-based investment advisory account, sometimes called a “managed account,” can potentially be more appropriate for you than a transaction-based account, such as a brokerage account, if you want ongoing investment advice and management of your account. Park Avenue offers a number of different investment advisory account programs and acts as the sponsor and broker-dealer in connection with some of those different investment advisory account programs. With a fee-based investment advisory account, you will pay an ongoing investment advisory fee based on the value of the assets held in your account in exchange for ongoing investment advice and management of your account and related services. This asset-based fee is Park Avenue’s and your IAR’s primary source of compensation related to the servicing of investment advisory accounts. The Park Avenue investment advisory accounts that are currently offered to new clients charge an “all-inclusive’ bundled fee based on the value of the assets in your account. This bundled fee usually includes a portfolio management fee, transaction, trading, and execution costs, and investment advice and is sometimes referred to as a “wrap fee.” Fees vary depending on which Park Avenue advisory program accounts you use. Investment 7 PAS017974-VestWise (4/2026)  advisory account fees are billed either in arrears (i.e., following the completion of the applicable billing period) or in advance (i.e., at the beginning of the applicable billing period) depending on the advisory program you select, and your billing methodology (i.e., in arrears or in advance) will be specified, your Statement of Investment Selection (“SIS”) and Terms and Conditions (for Park Avenue Proprietary Program Accounts, other than VestWise), the VestWise Investment Advisory Agreement, or the account opening documentation of the Third- Party Investment Advisor Program Accounts (collectively, the “Client Agreement”), or other account opening documentation. Fee charges are specified in your Client Agreement or other account-opening documentation, based on the assets held within your account for services including, but not limited to, ongoing investment advice, investment selection and recommendations, asset allocation, execution of transactions (depending on the program you are in), custody of securities, and account reporting services. Please see your Client Agreement and other account-opening documentation for additional information. After reviewing these documents, please address any questions you have with your IAR. For all Park Avenue Proprietary Program Accounts other than VestWise, Park Avenue’s advisory fees are generally negotiable. The Park Avenue Portfolio Select Program charges separately for asset management services, ongoing investment advice, and transaction costs. In this Program, you will be charged for any transaction, trading, and execution fees, costs, and expenses that applicable to trades and other transaction occurring within your account, as described in your account-opening documentation, in addition to your asset- based advisory fees (unless your IAR has agreed to incur such charges and expenses specific to your Park Avenue Portfolio Select Program account). Applicable transaction, trading, execution, and other fees, costs, and expenses are described in detail in the applicable Client Agreement, SIS, transaction, trading, execution, and brokerage service fee schedules, other account-opening documentation, and Form ADV, Part 2A. When Park Avenue and your Park Avenue financial professional serve as investment adviser for your fee-based account, Park Avenue and your Park Avenue financial professional will be acting in their investment advisory capacities for such account and are fiduciaries, without placing their financial or other interests ahead of your interests. Additionally, when Park Avenue and your Park Avenue financial professional provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA, Park Avenue and your Park Avenue financial professional are fiduciaries within the meaning of Title I of ERISA and the Internal Revenue Code of 1986, as amended (the “Internal Revenue Code”), as applicable, which are laws governing retirement accounts. You should be aware that Park Avenue and Park Avenue financial professionals are subject to various conflicts of interest in connection with the recommendations and other services they provide to you in connection with your transaction-based accounts. These conflicts of interest result from various arrangements, including, but not limited to, the roles Park Avenue and your Park Avenue financial professional play in a transaction, Park Avenue’s and your Park Avenue financial professional’s compensation arrangements, and Park Avenue’s financial and other arrangements with custodians, clearing firms, and other service providers, its affiliates, third-party product and service providers, and others. Important information regarding these conflicts of interest is provided in our Form CRS and Reg BI Disclosure Document, as well as in the other important client disclosures available on our website, www.parkavenuesecurities.com. 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. You should periodically discuss the various investment advisory program options with your IAR or Park Avenue. The Park Avenue IAR assigned to your account is compensated for servicing and providing general investment advice for the VestWise program. Because of the automated nature of this Program, compensation, which is paid to Park Avenue and the IAR, is expected to be less than what a Park Avenue and the IAR would receive for recommending another proprietary investment advisory program offered by Park Avenue, and may be more than what Park Avenue and the IAR would receive if you pay separately for investment advice, brokerage, and other 8 PAS017974-VestWise (4/2026)  services. Under Park Avenue Proprietary Programs, clients must establish an account through Park Avenue with Pershing LLC (“Pershing”). Pershing acts as the clearing firm and custodian for client assets within Park Avenue Proprietary Programs. Accordingly, all trading activity under Park Avenue 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. In addition, for all Park Avenue Proprietary Programs, Park Avenue is serving as the broker-dealer of record. By signing the VestWise Investment Advisory Agreement, client authorizes and directs Park Avenue to trade through Pershing, the applicable custodian and clearing firm. When Park Avenue acts in the capacity of the broker-dealer on your account, it receives additional compensation which it would not otherwise receive if another firm acted in the capacity of the broker-dealer on your account. Park Avenue’s receipt of additional compensation in its capacity as the broker-dealer on your account creates a conflict of interest for Park Avenue because Park Avenue has a financial incentive to, among other things, recommend itself as the broker-dealer of record and Pershing as the custodian for your account (rather than other available broker-dealers and custodians). For additional details regarding the conflicts of interest that Park Avenue has in connection with the various revenue streams it receives as your broker-dealer, please see Item 9, Additional Information, below. Park Avenue addresses these conflicts of interest by disclosing them to you; providing you with the Client Fee Schedule, which discloses the amount and rate of transaction, trading, execution, and brokerage services charges you will incur for your Park Avenue Proprietary Program accounts for which Park Avenue serves as the broker-dealer of record, the services you receive, and the securities and other investment products you purchase, hold, and sell in your account; not sharing any transaction, trading, execution, or brokerage service charges with the IARs that recommend products, share classes, transactions, strategies, or services for your account; and by requiring that there be a review of your account and transactions at account opening and periodically to determine whether they are suitable and in your best interest in light of your investment objectives, financial circumstances, and other characteristics. Pershing handles the delivery and receipt of securities purchased or sold on behalf of Park Avenue 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. For additional information on our investment advisory programs and services, please see our Form CRS and Forms ADV, Part 2A, which are available on our website at www.parkavenuesecurities.com, and through the SEC’s website at www.adviserinfo.sec.gov. Our Form CRS and Forms ADV, Part 2A may also be requested by contacting us at (888) 600-4667. Before consenting to any investment advisory relationship with us or our financial professionals, you should review the important disclosures referenced above, including those related to the services you will receive, the fees, costs, and expenses you will pay, the compensation we and our financial professionals will receive, and conflicts of interest or ours and of our financial professionals. After reviewing these disclosures, please address any questions you may have with your financial professional. Rollovers and Fiduciary Acknowledgement When Park Avenue and its IARs provide investment advice to you on a regular basis regarding your ERISA retirement plan account or IRA and 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, Park Avenue and its IARs are fiduciaries within the meaning of Title I of ERISA and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not necessarily mean Park Avenue 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, Park Avenue, or the IARs. With respect to rollover transactions, certain portions of this Brochure disclosure are intended to comply with requirements under the U.S. Department of Labor’s Prohibited Transaction Exemption 2020-02, specifically; 9 PAS017974-VestWise (4/2026)  information regarding the scope of services provided by Park Avenue and its IARs, (ii) the fiduciary acknowledgement above, and (iii) the description of the material conflicts of interest under which Park Avenue and your IARs are operating. Rollovers Park Avenue and your IAR get paid when you engage in a rollover transaction. Park Avenue can recommend that you rollover assets from your workplace retirement plan or from an existing IRA into an IRA account with Park Avenue. When you engage in a rollover to an IRA, Park Avenue 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 Park Avenue and your IAR to make a rollover recommendation. Transferring an Existing Account to Park Avenue 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 may 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, the previously described charges. 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 Park Avenue 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. Investing in VestWiseTM To invest in VestWise, you must establish an account through Park Avenue with Pershing LLC (“Pershing”), which clears trades and acts as custodian for your VestWise assets. Accordingly, all trading activity in connection with VestWise will be processed through your account 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 your behalf, receives, and distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender offers, and redemptions. Pershing will send statements of all activity in your account no less frequently than quarterly. Park Avenue, together with the IAR assigned to your account, provide advisory services to you as described in the Client Application, VestWise Investment Advisory Agreement, Client Fee Schedule, Investment Policy Statement, and this Brochure. Please review those documents carefully. If you do not have copies, please contact your IAR or our Home Office directly at 888-600-4667. Your IAR will periodically review performance and other periodic reports provided to you and will offer to meet with you to determine whether there have been any changes in your financial situation and investment objectives and whether you wish to impose any reasonable restrictions on the management of your account or reasonably modify existing restrictions. Park Avenue IARs are available to assist you in articulating and quantifying your goals, organizing financial data, identifying needs and opportunities, evaluating alternative courses of actions, and determining whether and how VestWise can assist you with your financial goals. 10 PAS017974-VestWise (4/2026)  Additionally, you are required to notify Park Avenue through the VestWise website or your IAR of any changes to your financial situation or investment objectives. Park Avenue utilizes a risk tolerance questionnaire (“RTQ”) to determine an appropriate investment strategy for you. The RTQ has ten questions. VestWise uses an algorithm that scores your answers to the questionnaire and uses the score to determine your risk profile and then matches the risk profile with a Strategy Selection (“Model Portfolio”) as indicated in the Investment Policy Statement (“IPS”). Park Avenue believes the algorithm it uses indicates the most appropriate Model Portfolio for you, but other investment advisory programs may use different algorithms with different results. VestWise does not use any other information about you, such as other investments or your tax situation, to determine the most appropriate strategy for you. It is important to note that the VestWise program is not a comprehensive financial plan and the investment advice that is provided to you is targeted to meet the specific goals that you specify in your answers to the RTQ and does not consider your broader financial situation. The IPS will contain the following: The responses to your RTQ.  The VestWise program Model Portfolio selected for you, including the investments which comprise your Model Portfolio.  The name of your IAR.  Other relevant information, if any, provided by you during the RTQ process. The VestWise program is intended to be a hybrid of a digital adviser combining an internet/web-based adviser and a traditional human IAR who is affiliated with Park Avenue. As part of the VestWise program your IAR will be available to assist you, upon your request, with the following:  Reviewing the Model Portfolio VestWise has recommended for you.  Providing you with advice and guidance based on the information provided at the time you opened your VestWise account and as you update or amend it from time to time.  Reviewing performance and other periodic reports provided to you and discussing whether there have been any changes in your financial situation and investment objectives.  Assisting you as you seek to articulate and quantify goals, organize financial data, identify needs and opportunities, evaluate alternative courses of actions, and determine whether and how VestWise can assist you in determining your financial goals. Park Avenue 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  Periodic rebalancing of the holdings in your account to align with your Model Portfolio using rebalancing rules established by Park Avenue. Important Documents, Electronic Signature and Electronic Delivery If you choose to invest your assets in VestWise, you will sign a Client Application after you have had the opportunity to review the following documents which will detail all of the important terms and conditions pertaining to your account, including the advisory fee:  This Brochure  VestWise Investment Advisory Agreement  Park Avenue Brokerage Account Customer Agreement  Client Fee Schedule 11 PAS017974-VestWise (4/2026)   Part 2B of Form ADV – Brochure Supplement containing information about your IAR. You are encouraged to read all of the above referenced documents carefully before you open a VestWise account. Either party may terminate the Investment Advisory Agreement upon 30 days written notice to the other, or as otherwise provided in the Investment Advisory Agreement. Pursuant to the Investment Advisory Agreement, you direct Park Avenue to invest your funds in a VestWise account in accordance with your IPS and the Model Portfolio that is selected based on your responses to the RTQ. You are required to notify Park Avenue of any material changes to your financial situation or of any reasonable restrictions you wish to place on your account. It is important to note that a condition of the VestWise program is that you consent to the Docusign electronic delivery and electronic signature process. This consent is effective immediately and can be revoked at any time by contacting Support@VestWise.com. A detailed description of the electronic delivery and electronic signature process is contained in the Docusign disclosure (titled “Electronic Record and Signature Disclosure”) that you will have the opportunity to review and consent to prior to opening your account with Park Avenue. This Docusign disclosure includes important information such as how to revoke your consent, how to update or change your email address for delivery, and a statement of hardware and software requirements. You will also have the opportunity to review the electronic delivery information that is contained in the Park Avenue Brokerage Account Customer Agreement. You will receive electronically all communications that are delivered by Park Avenue or its vendors related to your VestWise account. You will receive electronic notifications that documents are available for review in lieu of physical copies. These notifications will be sent to the email address that you have provided to Park Avenue. All documents will be made available in the VestWise Client Portal Document Center. If you revoke your consent to the electronic delivery and/or electronic signature process, Park Avenue will terminate your Investment Advisory Agreement no sooner than thirty (30) days after your revocation and transfer the ETFs in your Model Portfolio to a brokerage account established at Park Avenue. Additional documents might need to be completed by you to effect this transfer. If you prefer, you can initiate the transfer of your assets to another financial institution by providing the receiving firm with valid transfer instructions. Franklin Advisers, Inc. (“Franklin Advisers”) The VestWise program consists of eleven Model Portfolios whose underlying holdings consist of a series of individual Exchange Traded Funds, (“ETFs”). Franklin Advisers, an investment adviser registered with the U.S. Securities and Exchange Commission (“SEC”), provides Park Avenue with the Model Portfolios for the VestWise program, which are periodically updated by Franklin Advisers acting in the role of a “model provider.” Franklin Advisers reviews the ETF holdings in the Model Portfolios on an ongoing basis in light of sector exposure, currency exposures, credit quality and other measures and periodically considers changes in asset allocation and specific ETF holdings. Each Model Portfolio is built with a specific investment strategy and each is designed to be consistent with a specific risk tolerance level. For example, certain investment strategies are intended for investors who are seeking income generation, while others focus on market growth. Current market conditions are also taken into account. Based on its review of the Model Portfolio information provided to Park Avenue by Franklin Advisers, Park Avenue will revise the asset allocation of the Model Portfolios by adding, removing, or otherwise changing the individual underlying ETFs in an existing Model Portfolio as instructed by Franklin Advisers. Additionally, when the Model Portfolio for your account is revised, Park Avenue will use its discretionary authority to make trades to revise the holdings in your account to match the revised Model Portfolio. The technology platform being utilized by Park Avenue to provide the VestWise program is offered by AdvisorEngine, an affiliate of Franklin Advisors. Park Avenue pays AdvisorEngine an annual technology fee that is calculated based on the assets under management on the platform. The technology fee that Park Avenue pays AdvisorEngine is waived related to the platform assets within the Franklin Templeton Core Multi Manager ETF Model Portfolios (ETFs) model. This technology fee waiver creates a conflict of interest to Park Avenue in recommending these models, however that conflict is mitigated as the recommendation of the model is based on the client’s risk tolerance questionnaire score. 12 PAS017974-VestWise (4/2026)  Program Fees The annual client advisory fee agreed upon by you and Park Avenue is indicated in the VestWise Investment Advisory Agreement. The maximum annual fee for the VestWise program is 0.45% paid quarterly in arrears. The fee is calculated quarterly, using the average daily balance of the assets held in the Model Portfolio for your account for the completed quarter. Your advisory fee is paid to Park Avenue for the following services:  The advisory services provided by Park Avenue;  The model management provided by Franklin Advisers;  The technology-related services and/or the administrative services provided by Park Avenue, and  The brokerage services involved in purchasing and selling the securities in your account, as well as the custodial and clearing services provided by Pershing. The advisory fee charged by Park Avenue does not include internal expenses charged by the ETFs in which account assets are invested. All internal expenses are fully disclosed in the respective ETF prospectuses. The advisory fee also does not include costs or charges associated with liquidation of a client’s account and related charges, including but not limited to, express postage and handling charges, returned check charges, wire or transfer fees, transfer taxes or exchange fees, or other fees mandated by law, or non-brokerage related fees such as custodian fees and foreign transaction taxes, each of which is charged separately. In addition, Individual Retirement Accounts (“IRAs”) will be assessed a $125 termination fee upon account termination. These related charges are collected by Pershing; however, Park Avenue marks up the noted charges by as much as 150% and retains the markup. For example, to process a domestic overnight check, Pershing charges Park Avenue $12, you will be charged $15 (Pershing collects $12, Park Avenue collects $3). The markup on these charges help defray our costs associated with maintaining and servicing client accounts. The additional compensation due to the markup presents a conflict of interest because Park Avenue receives a financial benefit when it provides services in connection with maintaining and servicing your account. However, because your IAR does not share in these other account fees, your IAR does not have a financial incentive to recommend certain transactions or recommend that Park Avenue provide such additional services. If cash or cash-equivalent funds in your account are not sufficient to pay the fee, or any of the other fees charged in connection with your account, investments in your account may be liquidated in order to pay the outstanding fees. If your account is managed for only a portion of the quarter, the fee will be prorated accordingly. A full listing of charges is listed in the current Client Fee Schedule which is provided to you at account opening, will change over time, and can be found on our website at https://www.parkavenuesecurities.com/, or may be obtained by calling us at (888) 600-4667. Cash Management Sweep Program If your VestWise account is funded with less than the required minimum initial investment amount as set forth in the “Account Requirements and Types of Clients” section of this Brochure, any funds deposited into the account will remain in the Cash Management Sweep Program (“Sweep Program”) until your account reaches the required minimum initial investment amount. Any debits in your VestWise account will also be covered automatically by redemptions from the Sweep Program to the extent you have a balance in the Sweep Program sufficient to cover the debit balance. When funds in your VestWise account reach the required minimum initial investment amount, Park Avenue will invest all amounts in excess of the prescribed cash allocation amount pursuant to the Model Portfolio listed in the IPS. After you have reached the required minimum initial investment amount and your account has been invested in a Model Portfolio, Park Avenue will review your VestWise account on each day that the New York Stock Exchange is open for trading to determine whether the cash position is within the prescribed cash allocation drift parameters for your VestWise account. In the event your cash position is no longer within the drift parameters, Park Avenue reserves the right to adjust the positions in your account to 13 PAS017974-VestWise (4/2026)  comply with VestWise drift parameter rules. The Cash Management Sweep Program is a service Park Avenue makes available to clients which allows clients to automatically transfer free credit balances to either a money market fund product (the “Money Market Sweep”) or an account at a bank whose deposits are insured by the Federal Deposit Insurance Corporation (“Bank Sweep”). Park Avenue Proprietary Program Accounts (“Accounts”) are eligible to participate in the Sweep Program. The Park Avenue Sweep Program is comprised of a Bank Sweep product, which all clients shall be defaulted to at account opening, as well as specific money market funds which serve as overflow funds for accounts whose Bank Sweep product balance exceeds certain Federal Deposit Insurance (“FDIC”) limits. At the time you open your Account, you shall be defaulted to one of two Bank Sweeps. All Accounts, except for IRA and Retirement Plan Accounts, will be defaulted to the Dreyfus Insured Deposits Program (DIDV). The default DIDV Bank Sweep product is an FDIC insured multi-bank deposit sweep program. Additionally, balances in DIDV within the same account which are in excess of the $2.5 million FDIC insured limit will be automatically redirected to the Dreyfus Government Money Fund (DGUXX). IRA and Retirement Plan Accounts will default to DIDM - a design of the Dreyfus Insured Deposit Program specifically for IRA/Retirement Accounts. Any balances within the same IRA/Retirement Plan Account over the $2.5 million in FDIC coverage will be diverted to the Dreyfus Government Money Fund (DGVXX). When depositing into either the default DIDV or DIDM Dreyfus Insured Deposit Programs, you will receive a Disclosure Statement and Terms and Conditions of the program you are defaulted into. Amongst other items, the Disclosure Statement and Terms and Conditions detail various conflicts of interest associated with the Dreyfus Insured Deposit Program you are participating in, how interest rates are determined, and risks associated with the program. In addition, the Disclosure Statement and Terms and Conditions will provide a description of the DGUXX or DGVXX Dreyfus Money Fund associated with your Sweep Program. You are encouraged to carefully read and understand the Disclosure Statement and Terms and Conditions. The Disclosure Statement and Terms and Conditions is readily available on the our Cash Management webpage at https://www.parkavenuesecurities.com/cash-management, by contacting your IAR, or by contacting our Home Office at 888-600-4667. In addition, if invested into either DGUXX or DGVXX Dreyfus Money Funds, you will receive a prospectus of the fund you are invested into. Park Avenue has a conflict of interest by offering the DIDV Bank Sweep and the DGUXX Money Market Sweep Programs. Park Avenue receives a significant economic benefit when cash balances are swept into these Sweep Programs, rather than being reinvested in other investment funds or securities. For the DIDV Bank Sweep, Park Avenue receives a share in the earned income based on the amount of assets placed within the Bank Sweep. Park Avenue also receives a distribution from the DGUXX Money Market Sweeps used for overflow balances pursuant to the Fully Disclosed Clearing Agreement with its clearing firm, Pershing, LLC. The income earned from the DIDV Bank Sweep and the distribution received from the DGUXX Money Market Sweep, both of which are generated from, and paid by client deposits, are in addition to the Total Client Fee paid by clients to Park Avenue, related to investing in Park Avenue Proprietary Program Accounts. This conflict gives us a financial incentive to (i) select the DIDV and DGUXX Sweep Programs as the default Sweep Programs for all Proprietary Program Accounts other than IRA and Retirement Plan Accounts, rather than other Sweep Programs that are available that pay Park Avenue relatively lower or no revenue; (ii) recommend or advise clients to increase their deposits within the DIDV and DGUXX Sweep Programs; (iii) recommend or advise clients to invest in Proprietary Program Accounts that default into the DIDV and DGUXX Sweep Programs rather than accounts held directly with Third-Party Investment Advisory Programs; and (iv) recommend a Sweep Program option based on the compensation we receive instead of your needs. As a result, if you are invested in a Sweep Program option that pays Park Avenue a fee, the cost to you may be more than if you are invested in a Sweep Program that does not pay Park Avenue a fee. You may choose to opt out of the Sweep program by contacting your IAR. For additional information regarding payments received by Park Avenue regarding the DIDV Bank Sweep 14 PAS017974-VestWise (4/2026)  and Money Market alternative option, please review Item 9, Additional Information, specifically Dreyfus Insured Deposits Program. For more information on the Bank Sweep and Money Market overflow options as well as current yields and available bank lists please go to the following pages: https://www.parkavenuesecurities.com/cash- management and http://www.pershing.com/rates. Please note that Park Avenue does not offer all of the sweep options listed on the Pershing website. Assets held in any of the Sweep Programs will be included in the calculation of the client’s Total Client Fee, (i.e., they are considered “billable assets”). Your Account may require a certain amount of cash to remain in the Sweep Program to cover for certain costs associated with your Account. Different Sweep Program vehicles will have different rates of return, may pay Park Avenue a distribution fee, have different costs, and have different terms and conditions, such as FDIC insurance or SIPC protection, depending on the sweep vehicle. If the rate of return received from Sweep Programs fall below that of your Total Client Fee, you will experience a net negative overall return with respect to your Sweep Program deposits. The sweep vehicle is reflected on your account opening documents and on your statements. The selection of a more expensive share class of a Money Market Fund will negatively impact your overall investment returns. Sweep Program vehicles are not intended for use as a long-term investment option and are best used for short periods of time. You may be able to earn a higher yield through a different investment, and you should consult with your IAR about the available sweep options. Federal Deposit Insurance Corporation insured bank deposits are not protected by Securities Investor Protection Corporation. Although a money market mutual fund seeks to preserve the value of your investment at $1 per share, it may be possible to lose money by investing in a money market mutual fund. Shares of a money market mutual fund or the balance of a bank deposit product held in your account may be liquidated upon request with the proceeds credited to your account. Please see the money market fund’s prospectus or the bank deposit product’s disclosure document or contact your financial professional for additional information. Pursuant to SEC Rule 10b-10b(1) confirmations are not sent for purchases into money market mutual funds processed on the Sweep Program. Over any given period, the interest rates on cash balances in the Bank Sweep product may be lower than the rate of return on money market vehicles which are not FDIC insured or on bank account deposits offered outside the Sweep Program. If any sweep vehicles designated within the Sweep Program becomes unavailable at any time for any reason, Park Avenue will select an alternative in its discretion provided Park Avenue gives you 30 days advance written notice of such change and you do not object. In this event, the free credit balances in your Account will be placed into the alternative Sweep Program option. As noted earlier, all accounts will be automatically invested in a Bank Sweep vehicle. However, Park Avenue realizes an economic benefit from the DIDV Bank Sweep by sharing in the earned income based on the amount of assets placed within the Bank Sweep. For Accounts which hold a sweep vehicle charging a distribution fee retained by Park Avenue, Park Avenue does not share the distribution fee with your IAR. Therefore, your IAR does not have a financial incentive to recommend a Sweep Program option based on whether it pays a distribution fee or not. For additional information on money market funds and FDIC-Insured Deposit Sweeps, including applicable distribution fees, please see the fund prospectuses which are available on the following pages: https://www.parkavenuesecurities.com/cash-management and http://www.pershing.com/rates. Lending Services Offered to Park Avenue Proprietary Program Clients Non-Purpose Loan Program You may apply for a non-purpose loan from Pershing through the Park Avenue Non-Purpose Loan Program using an eligible securities account as collateral. These eligible securities accounts may include one or more of 15 PAS017974-VestWise (4/2026)  your VestWise accounts. In order for VestWise accounts to be eligible to serve as collateral for a non-purpose loan, the account may not serve as collateral for any other loans or lending. Reinvestment into any securities or insurance products is prohibited. 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 in addition to any advisory fees charged by Park Avenue for the VestWise program being used as collateral. Park Avenue 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 Park Avenue Proprietary Program accounts. In order for Park Avenue 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 Park Avenue on the loan value in addition to any Program advisory fees charged in the Park Avenue Proprietary Program account being used as collateral. Park Avenue 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 Park Avenue 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, Park Avenue and your IAR continue to earn fees on the full account value. Park Avenue 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 Park Avenue 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 Park Avenue 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 Park Avenue and which may offer more competitive interest rates. 16 PAS017974-VestWise (4/2026)  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 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,   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 that you may not benefit from collateralizing your VestWise account for a non-purpose loan if the performance of your account does not exceed the interest expense being charged on the loan. Due to the fact your Park Avenue 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 Park Avenue 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 Park Avenue, 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. Park Avenue 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 Park Avenue nor its IARs will act as an investment adviser to you with respect to the liquidation of securities held in a VestWise account to meet a loan demand. Those liquidations will be executed in Park Avenue’ 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 a creditor, Park Avenue 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 read carefully 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 Park Avenue’s clearing firm Pershing LLC with rates based upon the 17 PAS017974-VestWise (4/2026)  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%. Park Avenue 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, Park Avenue 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 Park Avenue or Pershing, at their discretion, to liquidate 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 Park Avenue 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 Park Avenue has a financial incentive to recommend or maintain a margin loan. This compensation is retained by Park Avenue 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. 5. Account Requirements and Types of Clients The program’s minimum initial investment requirement is $5,000. However, there is no minimum dollar amount to open a VestWise account. You will not be charged investment advisory fees on your account until you meet the minimum initial investment requirements. Upon meeting the minimum initial investment requirement, your account will maintain a cash balance of at least 2%. Therefore, if you open your account with $5,000, $4,900 will be invested into the Model Portfolio selected for you and the remainder ($100) will be deposited into the default cash sweep vehicle. If you open an account with less than the minimum initial investment requirement, any proceeds deposited into the account will be invested in the default cash sweep vehicle until such time that your account meets the minimum initial investment requirement and is invested in the Model Portfolio that is identified on the IPS in response to your answers on the RTQ. Any assets that you have invested in the default cash sweep vehicle will not incur a Park Avenue advisory fee. Park Avenue has discretionary authority to reallocate or rebalance assets in your account without your prior consent. Reallocation of assets may have tax consequences. Park Avenue has established trading rules for the VestWise program that will be used to implement investment rebalancing for your Model Portfolio. Trading rules for the VestWise program will also apply to deposits and withdrawals that you make. Additionally, neither Park Avenue nor its IARs will provide investment advice to you regarding your VestWiseTM account until you meet the minimum initial investment requirement. Your account will not be invested in a Model Portfolio, and therefore you will not experience investment gains or losses, until you reach the minimum initial investment requirement. There may be instances due to market fluctuations, fees charged, or your withdrawal of funds from a VestWise account that may cause an account to no longer be able to be rebalanced in accordance with your Model Portfolio. In those instances, Park Avenue will contact you to either deposit additional proceeds or close your account. Clients will be notified of any changes in the VestWise account minimums. The minimums for the VestWise program may be modified or waived by Park Avenue on a case-by-case basis. 18 PAS017974-VestWise (4/2026)  VestWise is available to natural person clients who wish to open individual or joint accounts. 6. ETF Selection and Evaluation The Franklin Advisers, Inc. model portfolio construction process consists of an assessment of specific model parameters and goals, including allocation targets, volatility limits, income levels, and investable regions, as well as other objectives or constraints. Longer-term strategic asset allocation and shorter-term views provide an allocation framework for each model. Your responses to the RTQ will determine which Model Portfolio will be recommended for you. Your RTQ answers and your Model Portfolio will be reflected in the IPS. VestWise does not use any other information about you, such as other investments or your tax situation, to determine the most appropriate strategy for you. As mentioned previously, the RTQ has ten questions. VestWise uses an algorithm that scores your answers to the RTQ, to determine your risk profile and then matches the risk profile with the Model Portfolio indicated in the IPS. Park Avenue believes the algorithm it uses indicates the most appropriate Model Portfolio for you, but other investment advisory programs may use different algorithms with different results. Your RTQ score will correlate to a Model Portfolio generally ranging from conservative to aggressive. To illustrate, it is generally thought that a conservative type of VestWise account is one comprised primarily of ETFs that invest in fixed income securities. Fixed income securities, of course, have risks related to interest rate movements, and other risks. On the other end of the scale, it is thought that the riskiest type of VestWise account (depending upon security selections) would be an account comprised primarily of ETFs that invest in equity securities (subject to higher market risk, among other risks). You may impose any reasonable restrictions or modify any existing restrictions in a reasonable manner on the management of your VestWise accounts. There is no guarantee that the objectives of any Model Portfolio will be realized. In addition, you may lose money by having your assets managed in accordance with any Model Portfolio offered through the VestWise program. Throughout the life of your account, if you make any changes to your RTQ, the algorithm will also evaluate whether a different Model Portfolio should be recommended for your account. It is important to note that in a taxable account, a rebalancing or different strategy may cause a taxable event. Based on your RTQ, you will be matched to a Model Portfolio which corresponds to Park Avenue standard investment objectives. There are eleven types of VestWise Model Portfolios as described below. VestWise Model Portfolios There are 11 Model Portfolios consisting of ETFs with investments ranging from 100% Fixed Income securities to 100% Equity securities that will be assigned to a client based on the results of their Risk Tolerance Questionnaire (RTQ). The Model Portfolios will increase or decrease their ETF exposure to Fixed Income or Equity securities in 10% increments, based on the outcome of your RTQ. Franklin Advisers and its affiliates receive asset based and other fees for providing advisory and other services to the ETFs that they manage, including those ETFs that it may select to form a part of a Model Portfolio. Franklin Advisers therefore, will have an incentive to include one or more affiliated ETFs in any Model Portfolio. In addition, to the extent the profitability of a particular ETF is greater than the profitability of another product, Franklin Advisers, Inc. will have an incentive to include the most profitable product in the Model Portfolio. Franklin Advisers may construct Model Portfolios without considering ETFs not affiliated with Franklin Advisers even though there may (or may not) be third party funds that are more appropriate for inclusion in such Model Portfolios, including available third party funds in the applicable asset classes that have lower fees and expenses, greater performance or other favorable terms relative to an affiliated ETF. Performance Based Fees and Side by Side Management 19 PAS017974-VestWise (4/2026)  Park Avenue does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Methods of Analysis, Investment Strategies and Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. You may experience loss in the value of your account due to market fluctuations. There is no guarantee that your investment objectives will be achieved by participating in VestWise. Prior to investing, you should carefully read the current prospectus for each security, where a prospectus is available, or other offering documents associated with the particular investment. The prospectus or offering documents contain information regarding the fees, expenses, investment objectives, investment techniques, and risks of each particular investment. The investment returns on your account will vary and there is no guarantee of positive results or protection against loss. No warranties or representations are made by Park Avenue or IARs concerning the benefits of participating in the VestWise program described in this Brochure. Park Avenue and IARs do not provide legal or tax advice. If you have tax or legal questions, you should seek a qualified independent expert. Depending on the types of securities you invest in, you may be subject to the following investment risks including, but not limited to: ETF Risk: ETFs are subject to the following risks: (i) the market price of an ETF’s shares may trade above or below the net asset value; (ii) there may be an inactive trading market for an ETF; (iii) the ETF may employ an investment strategy that utilizes high leverage ratios; (iv) trading of an ETF’s shares may be halted, delisted, or suspended on the listing exchange; and (v) the ETF may fail to achieve close correlation with the index that it tracks. Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. Market Risk: The price of a security, bond or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market risks. Credit Risk: also known as default risk, is the possibility that a bond issuer will not pay interest as scheduled or repay the principal at maturity. Credit risk may also be a problem with insurance companies that sell annuity contracts, where your ability to collect the interest and income you expect is dependent on the claims-paying ability of the issuing insurance company. Sociopolitical Risk: The possibility that instability or unrest in one or more regions of the world will affect investment markets. Terrorist attacks, war and pandemics are examples of events, whether actual or anticipated, that impact investor attitudes toward the market in general and result in system wide fluctuations in stock prices. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This risk is also referred to as exchange rate risk. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on discoveries of oil and then refining it, a lengthy process, before they can generate a profit. These companies carry a higher risk of profitability than an electric company, which 20 PAS017974-VestWise (4/2026)  generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Financial Risk: Excessive borrowing to finance the operations of a business increases the risk of loss if the company is unable to meet the terms of its loan obligations. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Liquidity Risk: When consistent with a client’s investment objectives, guidelines, restrictions and risk tolerances, client portfolios may be invested in illiquid securities, subject to applicable investment standards. Investing in an illiquid (i.e., difficult to trade) security may restrict the ability to dispose of investments in a timely fashion or at an advantageous price, which may limit the ability to take full advantage of market opportunities. Accounts may hold securities which are partnerships. Some partnerships are relatively liquid and may be either exchange listed or traded over-the-counter. However, most partnership securities are often illiquid and are subject to significantly less regulation than public investments. Fixed Income Risks: Portfolios that invest in bonds and other fixed income securities are subject to certain risks, including but not limited to, interest rate risk, credit risk, prepayment risk and market risk, which could reduce the yield that an investor receives from his or her portfolio. Foreign and Emerging Markets Risk: Investments in securities of foreign and emerging markets issuers involve different investment risks than those affecting obligations of U.S. issuers. Public information may be limited with respect to foreign and emerging markets issuers, and they may not be subject to uniform accounting, auditing and financial standards and requirements comparable to those applicable to U.S. companies. Additional risks include future political and economic developments, the possibility that a foreign jurisdiction might impose or charge withholding taxes on income payable with respect to foreign and emerging markets securities, and the possible adoption of foreign governmental restrictions such as exchange controls. In addition, foreign currency exchange rates may affect the value of securities in the portfolio. High-yield Bond Risk: Investments in high-yielding, non-investment grade bonds involve higher risk than investment grade bonds. Adverse conditions may affect the issuer's ability to make timely interest and principal payments on these securities. Structured Products Risk: These products often involve a significant amount of risk and should only be offered to clients who have carefully read and considered the product's offering documents, as their structure may be based on derivatives or other types of securities, which may be volatile. Structured products are intended to be “buy and hold” investments and are not liquid instruments. Interval Fund Risk: Investors investing in interval funds are subject to certain risks, including but not limited to fund shares not being listed on a public exchange, the lack of secondary markets, liquidity being provided only through repurchase offers by the fund on a schedule stated within the product prospectus (i.e. quarterly offers), no guarantee that an investor will be able to sell all the shares that the investor desires to sell during repurchase offer periods. Investors should consider these investments to be of limited liquidity. In addition, investing in interval funds may be speculative and involves a high degree of risk, inclusive of the risks associated with leverage. Investors should carefully read the fund’s prospectus prior to investing in an interval fund. Derivatives Risk: Derivatives are securities whose price is dependent upon or derived from one or more underlying asset. The derivative itself is a contract between two or more parties. Its value is determined by fluctuations in the underlying asset. Derivatives may involve significant risks and are not suitable for everyone. Derivatives trading can be speculative in nature and carry substantial risk of loss, including the loss of principal. Small/Mid Cap Risk: Stocks of small or mid-sized, emerging companies may have less liquidity than those of larger, established companies and may be subject to greater price volatility and risk than the overall stock market. Diversification Risk: Investments that are concentrated in one or a few industries or sectors may involve more 21 PAS017974-VestWise (4/2026)  risk than more diversified investments, including the potential for greater volatility. Security Selection and Asset Allocation Risk: Securities selected from a particular asset class (e.g., stocks, bonds, money market instruments) may experience unusual market volatility or may not perform as expected. An asset allocation program does not guarantee achievement of a client’s investment objective or protect against loss. Real Estate Risk: Investment in real estate and real estate related assets is subject to the risk of adverse changes in national, state, or local real estate conditions (resulting from, for example, oversupply of or reduced demand for space and changes in market rental rates); obsolescence of properties; changes in the availability, cost, and terms of mortgage funds; and the impact of tax, environmental and other laws. Directed Brokerage You must establish an account through Park Avenue with Pershing, which clears trades and acts as custodian for your VestWise assets. Accordingly, all trading activity in connection with the VestWise program will be processed through your account with Pershing. Pershing acts in the capacity of a clearing firm and performs centralized custody, bookkeeping and execution functions. Pershing handles the delivery and receipt of securities purchased or sold on behalf of Park Avenue’s clients, receives and distributes dividends and other distributions, and processes exchange offers, rights offerings, warrants, tender offers and redemptions. Not all investment advisory firms will require their clients to direct brokerage. By directing brokerage, Park Avenue may be unable to achieve most favorable execution of your transactions, and this practice may cost you more money. Best Execution Investment advisers are obligated to provide “best execution” of customer orders where the adviser has the responsibility to select broker-dealers to execute client trades. “Best execution” refers to using reasonable diligence to seek to obtain the best price to buy or sell a security under prevailing market conditions. All trade orders are executed through Pershing, the custodian for the VestWise program. Park Avenue does not select other broker- dealers for processing of client transactions and transmits all trades to Pershing for execution. Park Avenue’s objective in executing client trades is to obtain the most favorable execution and to aggregate and allocate trades fairly and equitably across all its clients. Park Avenue has adopted policies and procedures that are designed so that trading practices do not unfairly or systematically favor one client, group, or strategy over another. Park Avenue regularly receives reports from Pershing which contain information regarding the trade order execution experience of Pershing for all of its customers. Park Avenue undertakes an on-going review of its relationship with Pershing, including a quarterly review of trade order flows. Soft Dollars Soft dollars are defined as arrangements under which products or services other than the execution of securities transactions are obtained by an adviser from or through a broker-dealer in exchange for the direction of securities trades to the broker-dealer. Park Avenue does not have any soft dollar arrangements. Order Aggregation Aggregating multiple client orders together is particularly useful when Park Avenue is utilizing model portfolio management strategies (multiple client accounts in the same model). Park Avenue may aggregate trades unless it believes that aggregation is not consistent with its duty to seek best execution for clients in the aggregate and consistent with the terms of the client’s investment advisory agreement. Park Avenue will often aggregate the purchase or sale of multiple clients’ securities together to help facilitate best execution and provide each client with the same execution price. If different prices are paid for securities in an aggregated transaction, each client in the transaction will receive the average price paid for the block of securities in the same aggregated transaction. If the client trade is aggregated with other client accounts and is executed at the same price, the client will receive the same price per unit. If we are not able to completely fill an aggregated transaction, we will normally allocate the filled portion of the transaction to our clients on a pro-rata basis. 22 PAS017974-VestWise (4/2026)  Park Avenue may exclude from aggregation those client accounts that have relevant restrictions or pending client activity. If trades are not aggregated, clients may pay prices for the transactions that are different from what they may have paid had the trades been aggregated. When aggregating, Park Avenue may, consistent with its policies and procedures and fiduciary duties, include proprietary and/or employee accounts in an aggregated order. If we are not able to completely fill an aggregated transaction, we will allocate the filled portion of the transaction following fair dealing principles, e.g., pro-rata, trade rotation. Park Avenue has invested $460,000 into the Model Portfolios available through the VestWise program. The purpose of the investment is to ensure each Model Portfolio has an investment performance history. Park Avenue will aggregate transactions in these accounts along with client accounts which also includes the rebalancing of accounts or model changes recommended by Franklin Advisers, Inc. Park Avenue will receive the average price paid as described above. Voting Client Securities As a matter of firm policy and practice, Park Avenue generally does not vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in client portfolios. Each Park Avenue wrap fee program and Third-Party Adviser has its own Wrap Fee Brochure which describes voting client securities for each program. Please refer to the applicable Wrap Fee Brochure for additional information. Park Avenue clients will receive proxies directly from the custodian, Pershing. For questions regarding proxies, clients may contact our Home Office at (888) 600-4667. 7. Client Information Provided to Portfolio Managers Park Avenue will receive or have access to the following client-related information: (i) account opening documents, which include, among other things, your investment objective, risk tolerance and any client-imposed restrictions on management of assets; (ii) online access to the account; (iii) confirmations; (iv) account statements; and (v) your quarterly performance reviews. 8. Client Contact with Portfolio Managers There are no restrictions placed on your ability to contact and consult with Park Avenue regarding the VestWise program. You should also contact your assigned IAR with any questions regarding VestWise. However, you may also contact the Park Avenue customer support center at (888) 600-4667. 9. Additional Information Disciplinary Information The following is a chronological summary of material disciplinary events relating to Park Avenue Securities, LLC. (“PAS”) and its management personnel in the last 10 years. 11/18/2016 – In connection with the misappropriation of funds from two customers by an unregistered sales assistant, FINRA censured and fined PAS $195,000 in its capacity as a broker-dealer for failing to enforce its written supervisory procedures regarding the monitoring of customer trades and for failing to establish and maintain a supervisory system reasonably designed to follow up on the performance of its supervisors with regard to monitoring trade executions, in violation of NASD Rules 3010(a), 3010(b) and FINRA Rule 2010. FINRA noted PAS also failed to establish, maintain, and enforce a supervisory system reasonably designed to review and monitor the transmittal of funds from the accounts of its customers to third party accounts and outside entities, in violation of NASD Rules 3010, 3012(a)(2)(B)(i) and FINRA Rule 2010. 23 PAS017974-VestWise (4/2026)  4/11/2018 – FINRA censured and fined PAS $300,000 in its capacity as a broker-dealer for failing to implement a supervisory system and written supervisory procedures reasonably designed to train and supervise Registered Representatives’ recommendations regarding the sale of multi-share class variable annuities, including L-Share contracts, to ensure their suitability. FINRA also found that PAS had no surveillance procedures to determine rates of variable annuity exchanges. FINRA found the foregoing to be in violation of NASD Rule 3010 and FINRA Rules 3110 and 2010. 3/11/2019 - PAS without admitting or denying the findings, consented to the entry of an Order Instituting Administrative and Cease and-Desist Proceedings (“Order”) by the SEC. Pursuant to the Order, the SEC found that from January 1, 2014 through October 31, 2018 certain PAS clients participating in proprietary advisory programs were invested in mutual fund share classes with higher costs (in the form of Rule 12b-1 fees) without adequately disclosing that lower-cost share classes (without Rule 12b-1 fees) of those funds were available. Specifically, PAS did not adequately disclose conflicts of interest related to its receipt of Rule 12b-1 fees, and the availability of mutual fund share classes that did not pay such fees. PAS consented to the entry of the Order that it violated Sections 206(2) and 207 of the Investment Advisers Act of 1940 and agreed to cease and desist from committing or causing any violations and any future violations of Sections 206(2) and 207. PAS agreed to pay disgorgement of $508,083 and prejudgment interest of $56,184 to affected clients. Additionally, as part of the Order, PAS has enhanced its disclosure regarding mutual fund share class selection, considered whether existing clients should be moved to a lower-cost share class, and updated its policies and procedures regarding mutual fund share class selection. 7/16/2019 – PAS without admitting or denying the findings, was censured by the Financial Industry Regulatory Authority (“FINRA”) in its capacity as a broker-dealer for failing to reasonably supervise the application of sales charge waivers for mutual fund purchases made by certain retirement plan and charitable organization customers. By failing to reasonably supervise such mutual fund sales to ensure that eligible purchasers received the benefit of applicable sales charge waivers, FINRA found that PAS violated NASD Conduct Rule 3010 (for misconduct before December 1, 2014), FINRA Rule 3110 (for misconduct on or after December 1, 2014 and FINRA Rule 2010. As part of this settlement, PAS agreed to pay restitution to eligible customers on the terms specified below, in the amount of $640,552 (i.e., the amount eligible customers were overcharged, inclusive of interest). PAS also agreed to ensure that waivers are appropriately applied to all future purchase transactions made by retirement plan and charitable organization customers. FINRA recognized the extraordinary cooperation of PAS for initiating an investigation prior to detection or intervention by FINRA to identify whether applicable customers received sales charge waivers, for promptly establishing a plan of remediation to customers and taking action to correct the violative conduct. 5/31/2023 – In connection with an undisclosed outside business activity of a PAS Registered Representative, PAS, without admitting or denying the findings, agreed to a Letter of Acceptance, Waiver, and Consent with FINRA for the purpose of settling alleged FINRA rule violations. PAS was censured and fined $30,000 by FINRA for violating FINRA Rule 3110 by failing to investigate red flags that the Representative was engaged in an undisclosed outside business activity, unapproved private securities transactions and FINRA Rule 2010. 9/24/2024 – PAS, PAS, without admitting to or denying the findings, was censured by the Financial Industry Regulatory Authority (“FINRA”) in its capacity as a broker-dealer for failing to reasonably supervise mutual fund share class recommendations to retirement plan customers, from January 2019 through July 2021. FINRA found that PAS’ supervisory system and WSPs were not reasonably designed to achieve compliance with FINRA Rule 2111 or the Care Obligation of Regulation Best Interest. As part of this settlement, FINRA issued a $125,000 fine. PAS paid restitution to eligible customers in 2022 in the amount of $91,344, which was the amount eligible customers were overcharged, inclusive of interest. Other Financial Industry Activities and Affiliations Park Avenue Securities, LLC (“PAS”), doing business under marketing name Park Avenue® Wealth Management, 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. 24 PAS017974-VestWise (4/2026)  PAS is an affiliate of The Guardian Insurance & Annuity Company, Inc. (“GIAC”), a Delaware insurance company. PAS is also an affiliate of Guardian Wealth Partners, LLC (“GWP”) and Park Avenue Institutional Advisers, LLC (“PAIA”), SEC registered investment advisers. GWP and PAIA are indirect wholly owned subsidiaries of GLIC. PAS or its IARs may recommend mutual funds whose investment adviser is a PAS affiliate, such as PAIA. PAIA is the sub-adviser to certain mutual funds offered by Victory Capital. Therefore, we have an incentive and conflict to recommend certain products which are managed by PAIA due to the additional compensation earned by such affiliate. In addition, PAS makes available alternative investment funds issued by Hamilton Lane Advisors, LLC (“Hamilton Lane”). PAS’ parent company, GLIC, has appointed Hamilton Lane to manage a portfolio of GLIC’s general account and in exchange has obtained warrants from Hamilton Lane. These warrants may be exercised in shares of Hamilton Lane, cash, or a combination of shares of Hamilton Lane and cash. While not considered a proprietary investment, the warrants issued by Hamiton Lane to GLIC creates a similar conflict. Many IARs of PAS are also agents of GLIC and GIAC and may sell a wide range of products issued by those entities, such as life insurance and variable annuities. IARs receive no additional compensation for recommending insurance products issued by affiliates or mutual funds managed by affiliates than they would if they recommend insurance products or mutual funds issued by or managed by non-affiliates. An IAR may have an incentive to recommend a particular PAS Proprietary Investment Advisory Program or Third-Party Investment Advisory Program in favor of another because of the receipt of higher fees or non-cash benefits such as additional services which include marketing support and training provided by the sponsor of the Third-Party Advisory Program. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Park Avenue has adopted a code of ethics (“Code of Ethics”) for all supervised persons of the firm, which governs the ethical standards of conduct and securities trading required to be adhered to by supervised persons. The Code of Ethics includes provisions relating to, among other things, a prohibition on trading on the basis of material non-public information or confidential information, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures. All supervised persons of Park Avenue must acknowledge the terms of the Code of Ethics annually. Park Avenue will provide a copy of the Code of Ethics to any client or prospective client upon request. It is Park Avenue policy that the firm generally will not affect any principal or agency cross transactions for client accounts. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to an advisory client. Park Avenue may engage in principal transactions only in limited circumstances where it elects to buy “worthless securities” out of client accounts in order to facilitate the liquidation of such positions. Park Avenue also will not permit agency cross transactions between client accounts. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker- dealer. Review of Accounts At account opening, Park Avenue, through the VestWise website, gathers information from you through the RTQ about your financial situation, risk tolerance and investment objectives. In addition, during the VestWise account opening process, Park Avenue will give you the opportunity to impose any reasonable restrictions upon the management of your account. You should notify Park Avenue of any changes in your financial situation, risk 25 PAS017974-VestWise (4/2026)  tolerance, investment objectives or account restrictions. In the event of such changes, it may be appropriate for you to complete a new RTQ. Park Avenue employs individuals who are registered with the Financial Industry Regulatory Authority (“FINRA”) as principals (the “Registered Principals”), who review all accounts for suitability. Accounts are reviewed by the Registered Principals prior to being opened. Park Avenue provides you with a quarterly performance report which calculates the performance of the securities held within your VestWise Model Portfolio. Custody Although Park Avenue’s Proprietary Program Account assets are held by a qualified custodian, Park Avenue is deemed to have custody of client funds because it has the ability to direct such custodians to deduct advisory fees from the client’s account and because some client accounts have standing letters of instruction (“SLOAs”) or other similar asset transfer authorization agreements which gives us the authority to transfer funds to a third- party. Client Referrals and Other Compensation Park Avenue and/or its IARs may receive compensation pursuant to solicitation agreements for introducing clients to the Third-Party Investment Adviser and for providing certain ongoing services. This compensation is typically equal to a percentage of the investment advisory fee charged by that investment adviser. Because IARs receive compensation from these investment advisers for referring clients and because such compensation may differ depending on the individual agreement with each investment adviser, the IAR may have an incentive to recommend one of these Third-Party Investment Advisers over another with which Park Avenue has a less favorable compensation arrangement or alternative investment advisory programs. Full disclosure of all solicitation arrangements, including Part 2 of Form ADV and a solicitor’s disclosure statement, will be given to the client at the time of referral. Park Avenue has arrangements with a number of individuals (“Promoters”) under which the Promoters introduce potential advisory clients to Park Avenue in exchange for a referral fee. Whenever Park Avenue pays a referral fee, we require the prospective client to receive a copy of this Brochure and a separate disclosure statement that includes the following information: (1) the Promoter's name and relationship with Park Avenue; (2) the fact that the Promoter is being paid a fee; (3) the amount of the fee; and (4) whether the fee paid to us by the client will be increased above our normal fees in order to compensate the Promoter. In general, the advisory fees paid to us by clients referred by Promoters are not increased as a result of a referral. Other Compensation and Conflicts We have an incentive to recommend the product or account type that results in additional fees and revenues for us. We can recommend that you invest through different account type arrangements, such as through a brokerage account, an account directly held with the issuer of the investment (or its transfer agent), or an advisory account. Depending on factors such as the type and level of services you require as well as the frequency of trading in your account, one of these account types may be more cost-effective for you than the others. In addition, we receive miscellaneous account and service fees and other compensation (which are in addition to advisory fees) in connection with brokerage accounts or advisory accounts that we do not receive with a directly held account. We can also recommend that you invest in products that have higher up-front compensation along with ongoing trail payments. The availability of different products and account types incentivizes us and our IARs to recommend the product or account type that results in additional fees and revenues for us and your IAR even though another type of account may be more cost-effective for you. How We Addresses Certain Compensation Related Conflicts of Interest  Park Avenue discloses potential conflicts of interest to clients through documents such as this disclosure 26 PAS017974-VestWise (4/2026)  document, disclosures on the Park Avenue website and other materials discussing the products and services offered.  Park Avenue credits 12b-1 fees and service fees from mutual funds, other than those associated with the Cash Management Sweep Program, and all FundVest® program fee payments to client accounts within Park Avenue Proprietary Programs.  Park Avenue IARs do not receive any portion of the payments Park Avenue receives under the agreement between Park Avenue and Pershing.  Park Avenue IARs do not receive any portion of the revenue received from mutual fund compensation arrangements, or mutual 12b-1 fees/service fees. Park Avenue does not include within these revenue sharing arrangements assets held within plans covered by Title I of ERISA, or a plan described in Section 4975(e)(1) of the Internal Revenue Code. Listed below are potential additional payments that Park Avenue may receive and the potential conflicts of interest they create. You should consider these potential conflicts of interest prior to investing in the Park Avenue Proprietary Programs as the receipt of such payments provides a financial incentive for Park Avenue to recommend Park Avenue Proprietary Programs over Third-Party Advisory Programs. Pershing Additional Payments Through an agreement with Pershing, Park Avenue earns the following payments from Pershing. These payments are not applicable to clients of Third-Party Advisory programs. 1) Park Avenue receives a recurring fixed payment from Pershing annually on the total dollar value of legacy assets transferred from Park Avenue’s previous custodian. 2) Park Avenue receives payments from Pershing on the total amount of assets in client accounts placed on the Pershing custodial platform annually, and for asset growth year over year, which shall also include assets of Park Avenue’s affiliate. Guardian Wealth Partners. This payment excludes the total dollar value of legacy assets transferred from Park Avenue’s previous custodian. The receipt of such payments from Pershing provides a financial incentive for Park Avenue to recommend Park Avenue Proprietary Programs over Third- Party Advisory Programs. 3) Park Avenue receives an annual fixed technology allowance credit in the amount of $200,000 for reasonable and documentable costs incurred by Park Avenue in association with the implementation of technology solutions provided by Pershing, its affiliates and/or other third party providers. 4) Park Avenue receives an annual discretionary fee allowance credit in the amount of $200,000 for Pershing related fees Park Avenue would like to absorb through this credit. 5) Park Avenue earns interest payments on non-purpose loans that have interest rates above the Federal Funds Rate +1.75%. For example, if the interest rate on a non-purpose loan is 5% and the Federal Funds is 3%, Park Avenue will earn .25% of what a client pays (5%-4.5%). The receipt of such payments provides a financial incentive for Park Avenue to recommend and approve non-purpose loans. 6) Pershing agrees to share certain service fees received by Pershing from mutual funds that participate in the FundVest® program. The FundVest® program is an open architecture platform of mutual funds and no- transaction fee mutual funds offered by Pershing. These mutual funds are offered within Park Avenue Proprietary programs. The percentage of service fees Pershing shares with Park Avenue is based on the level of assets held by Park Avenue clients within the FundVest® program and generally ranges between 50- 55% of such services fees received by Pershing from participating mutual funds. Furthermore, Park Avenue addresses this conflict by crediting back all FundVest® program fee payments that it receives to clients invested in the Park Avenue Proprietary Programs. For additional details about Pershing’s mutual fund no-transaction- fee program, or a listing of funds that pay Pershing networking or omnibus fees, please refer to www.pershing.com/mutual_fund.htm. 7) Park Avenue has an incentive to have IARs recruited to us transfer their client accounts to Park Avenue because Pershing provides us with rebates for such account transfers. Pershing will reimburse us for out-of- pocket expenses associated with transfer and termination fees upon the successful onboarding of a newly hired IAR who transitions their client accounts from a financial services firm that does not clear through our clearing firm. 27 PAS017974-VestWise (4/2026)  Dreyfus Insured Deposits Program For the DIDV Bank Sweep each month, depository institutions pay a fee (“Deposit Fee”) equal to a percentage of the average daily deposit balance in your deposit account(s) at the banks participating in the program (“Program Banks”) to Park Avenue, Pershing, and a third-party administrator. The fee paid to Park Avenue will not exceed 600 basis points (6%) on an annualized basis over a rolling 12-month period. The combined fee paid to Park Avenue, Pershing, and the third-party administrator will not exceed 675 basis points (6.75%) on an annualized basis on the average daily balances held in these deposit accounts over a 12- month rolling period. Park Avenue has discretion in determining the size of the portion of the fee it receives. This directly negatively impacts the interest rate yield client deposits will receive. Park Avenue may waive any portion or entirety of its share of the fee received from Program Banks. Your IAR will not receive any portion of the fees paid to Program Banks. The amount of fee received by Pershing, Park Avenue, and any other service provider, will affect the interest rate paid in your deposit account(s). Other than applicable fee imposed by Park Avenue on your account (including fees charged on your Pershing, LLC IRAs) there will be no additional charges, fees, or commissions imposed on your account with respect to the DIDV Bank Deposit Sweep. In order to illustrate the effect of the interest retained by Pershing, Park Avenue and the administrator of the program please consider the following example. If the DIDV sweep is earning a gross interest rate yield of 2% and Park Avenue, Pershing, and the administrator retains 1.65% for administration, then the client rate would be .35%. The receipt of this fee creates an incentive for Park Avenue to select DIDV as the default cash sweep vehicle for the clients who do not select a Money Market Sweep vehicle or have an account which is automatically defaulted to DIDV, as it will result in additional compensation to Park Avenue. In addition, Park Avenue’s discretionary authority in determining it’s share of the fee creates a conflict of interest due to Park Avenue’s receipt of the fee, which in turn, negatively impacts the interest rate yield client deposits will receive. As disclosed in the Cash Management Sweep Program section, the overflow Money Market Sweep products pay a distribution to Park Avenue which will not be credited to your account. Park Avenue IARs do not receive any portion of the distribution fee and therefore do not have a conflict in recommending a Cash Management Sweep product which pays a distribution. You are encouraged to speak to your IAR regarding the Cash Management Sweep Program vehicle used for your account. Guardian Club Credits Certain IARs may receive “Club Credits” for the recommendation of Park Avenue Proprietary Programs, Third- Party Investment Advisory Programs or Financial Planning/Consulting. These “Club Credits” are based upon sales production and count towards the attainment of various GLIC club memberships. Attainment of various club memberships may entitle IARs to attend GLIC-sponsored conferences. Park Avenue Securities VIP Program Certain IARs will qualify to receive service and financial support, as described in more detail below, based upon their overall sales production. The top 100 Park Avenue sales agents qualify for the VIP program. The qualifications to achieve VIP status are based upon total sales production or Gross Dealer Concession (“GDC”). GDC is the revenue generated via agent sales of brokerage products (i.e., stocks, bonds, mutual funds) and advisory services (i.e., Proprietary Programs, Third Party Investment Advisory Programs and Financial Planning/Consulting). The attainment of this VIP status entitles an IAR to receive a dedicated support person called a Relationship Manager, full or partial waiver of state registration fees and Park Avenue affiliation fees, and “Select Rewards Points”. The “Select Rewards Points” can be used to cover the cost of client account maintenance fees, termination fees, and/or service fees such as fed wire or overnight check fee. The decision to cover certain client costs is at the discretion of your Park Avenue IAR and not all clients will receive this benefit. 28 PAS017974-VestWise (4/2026)  Park Avenue Securities Pinnacle Council IARs are also eligible to qualify for a club award program called Pinnacle Council. To qualify for Pinnacle Council, an agent must be in the top 20 for total sales production based on the prior year GDC. The benefits of this club award include attendance at an annual recognition conference with paid travel accommodations (i.e., flight and hotel) and meals for the PAS Pinnacle Council qualifier and one guest. Park Avenue Securities Peak Council IARs are also eligible to qualify for a club award program called Peak Council. To qualify for Peak Council, an agent must be in the top 40 (21-40) for total sales production based on the prior year GDC. The benefits of this club award include attendance at an annual recognition conference with paid travel accommodations (i.e., flight and hotel) and meals for the PAS Pinnacle Council qualifier and one guest. These programs could create a conflict of interest by an IAR recommending certain products in attempt to qualify for these additional clubs and awards. Transitional Assistance Program (TAP) Park Avenue may offer some recruits the opportunity to obtain bonuses and loans that are dependent upon meeting sales targets. These transition assistance loans may also be forgiven based on years of service with Park Avenue, or its affiliates, assets under management, the amount of production with Park Avenue or its affiliates or the number of clients brought over to Park Avenue. This practice creates a conflict of interest as it provides a financial incentive for an RR or IAR to recommend that a client engage Park Avenue for advisory or brokerage services, and to recommend additional products from Park Avenue or its affiliates. Moreover, some recruits may obtain “early asset bonuses” if they transfer certain percentages of assets to our Firm within a specific timeframe from becoming registered with our Firm. If an RR or IAR has received a transition loan, they are incentivized to encourage the transfer of your account to our Firm so that bonuses can be earned. This conflict is especially acute as your IAR approaches his or her milestone date. The Park Avenue Transition Team will work with an RR or IAR to ensure a successful transition by providing everything from a customized transition plan, tailored training, account opening and account transfer support. The level of support and service received is dependent upon the RR or IARs trailing twelve-month GDC with their prior firm. In addition, if the prior firm does not clear through Pershing, Pershing will reimburse transfer and termination fees up to $125.00 to each client account. Transition assistance presents a conflict of interest because of the incentive to affiliate with and recommend Park Avenue to clients. Private Client Group At their discretion, Park Avenue IARs may identify certain clients based on the amount of assets in either or both the Park Avenue Proprietary Investment Advisory Programs or Park Avenue broker-dealer accounts for participation in the Private Client Group program. Private Client Group clients will receive certain benefits which are not available to clients who are not selected for the program. These benefits include but are not limited to access to educational and exclusive private events, discount programs unrelated to services or products offered by Park Avenue as a broker-dealer/registered investment adviser, and specialized Park Avenue services. Many of the services offered by the Private Client Group are also available to clients who are not in the program. Park Avenue IARs have an incentive to select certain clients who have more assets with Park Avenue over other clients who do not have as many assets with Park Avenue. This creates a conflict of interest for Park Avenue and its IARs and incentives clients to maintain a certain level of assets at Park Avenue as well as increase their assets in attempt to qualify for these benefits and services which would generate higher 29 PAS017974-VestWise (4/2026)  advisory or broker-dealer transactional fees. Not all clients who meet the asset thresholds for membership will be offered invitations to the Private Client Group as invitation is at discretion of the Park Avenue IAR. Payments Related to Park Avenue Educational/Practice Management Conferences iCapital *First Trust Inland Capital Certain product sponsors and vendors pay Park Avenue a fee ranging from $40,000 to $172,000 to participate in Park Avenue sponsored educational/practice management conferences for Park Avenue IARs. In 2026, Park Avenue anticipates it will receive fees from the following:  BlackRock  State Street Global Advisors  Clark Capital  City National Rochdale  Halo   Capital Group/American Funds   Fidelity   Allianz  BNY Mellon  Brighthouse  Jackson  Lincoln  Nationwide  Prudential  Transamerica *First trust will pay Park Avenue the greater of $100,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. See section Revenue Sharing Payments for a description of revenue sharing. Other Compensation (Park Avenue Proprietary & Third-Party Advisory Programs) Third-Party Advisor Payment Arrangements Park Avenue receives payments from SEI, Orion, and AssetMark as compensation for marketing and administrative services as follows:  SEI pays Park Avenue a flat annual fee. The fee for 2026 is $548,000.  Orion pays Park Avenue a flat annual fee for training and educating Park Avenue IARs. The fee for 2026 is $320,000.  AssetMark pays Park Avenue a flat annual fee. The fee for 2026 is $1,000,000. o OBS, who is owned by AssetMark, pays Park Avenue a flat annual fee. The fee for 2026 is $88,000. You should also be aware that marketing, administrative or educational activities paid for with these payments by these sponsors and vendors lead to greater exposure of their products and services with Park Avenue IARs. Therefore, these payments create an incentive, or lead to a greater likelihood, for Park Avenue or its IARs to recommend a product of these sponsors and vendors over the products or services of a firm which does not pay Park Avenue a fee. Revenue Sharing Payments Certain product sponsors pay Park Avenue additional compensation in the form of revenue sharing. These revenue sharing payments are calculated as an annual percentage of the amount of assets held by Park Avenue customers within sponsor products. Park Avenue may receive compensation of up to 25 basis points (“bps”) on 30 PAS017974-VestWise (4/2026)  these assets. For example, if you hold a $10,000 position with a sponsor that provides Park Avenue a 25bps payment, Park Avenue will receive $25 from that sponsor. *HPS **First Trust The following product sponsors provide Park Avenue revenue sharing payments:  Open VC., Inc.  CION Ares Management  Hamilton Lane  The Carlyle Group  Janus Henderson   Pimco (Alternative Funds Only)   Allianz  Brighthouse Life Ins.  Equitable  Jackson National  Lincoln Financial  Nationwide  Prudential  Transamerica ***Redbrick  *HPS will pay Park Avenue the greater of $200,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. **First trust will pay Park Avenue the greater of $100,000 or 5 basis points of the amount of assets held by Park Avenue customers within First Trust products. ***Redbrick will pay Park Avenue 25 basis points on new sales rather than assets held by Park Avenue customers when Park Avenue customers purchase Redbrick products. Receipt of revenue sharing payments creates a conflict of interest as Park Avenue is incentivized to sell you or recommend you hold investments that provide Park Avenue with such payments rather than investments that do not. In addition, as the payments differ by product sponsor, Park Avenue is incentivized to sell you or recommend you hold investments that provide a higher revenue sharing payment rate than investments that pay Park Avenue a lower revenue sharing payment rate. This conflict of interest is mitigated by the fact that IARs do not receive this firm-paid additional revenue sharing compensation from the product sponsors that provide Park Avenue these revenue sharing payments, and that the firm maintains reasonable policies and procedures to help ensure recommendations are in your best interest. Third Party Payments For some investments you purchase based on our recommendation, we receive payments from a third-party that are in addition to the advisory fee payments described in this document. For example, certain mutual fund issuers make ongoing payments based on invested assets (and not just new investments), such as 12b-1 fees, shareholder servicing fees or trail compensation. These third-party payments are described in further detail in the prospectus or offering materials for the investment, which will be made available to you in connection with any purchase. Third-party payments incentivize Park Avenue and your IAR to sell you or recommend you hold investments that bring about these payments rather than investments which do not or result in comparatively lower payments. To mitigate this conflict and as discussed more within this Brochure, Park Avenue credits back to clients invested in Park Avenue Proprietary Program Accounts mutual fund 12b-1 and other service fees it would otherwise receive from mutual fund products, except those generated by the Cash Management Sweep Program. There may be instances where the portfolio managers our IARs recommend periodically pay us based on the 31 PAS017974-VestWise (4/2026)  total amount of customer assets we direct to them. These payments are sometimes called “revenue sharing” payments and incentivize us to recommend you hold investments that bring about such payments rather than investments that do not or result in comparatively lower payments. Some third-party portfolio managers may also make payments to us to cover the costs associated with certain educational conferences or training seminars we host for our IARs and to be allowed to present their products during such conferences and seminars. These payments are typically for fixed amounts and are not tied to total sales or customer assets. Even so, these payments incentivize us to recommend you hold investments by these managers that make these flat payments rather than managers that do not make these payments or make comparatively lower payments. Other IAR Conflicts The individual office managers/supervisors are paid based on the performance of the branches or regions they supervise. Our managers and supervisors oversee the sales and marketing activities of our Firm. The compensation of our managers and supervisors is tied to the production levels of branches or regions over which they have managerial or supervisory responsibility. Tying managers’ and supervisors’ compensation to production generated by the branches or regions they supervise incentivizes them to spend more time on increasing production levels than on their supervisory responsibilities. Some of our IARs receive additional training and support from certain managers. Certain managers and their affiliates provide some of our IARs or their branches with more training and administrative support services than others. If your IAR receives this additional training and support, his or her use of these managers’ higher level of training and administrative support services incentivizes your IAR to recommend managers that provide such training and services over issuers that do not. Some of our IARs receive compensation in the form of non-cash compensation or other gifts from vendors or product sponsors to assist with, and defray the expenses associated with educational seminars and client events held by the IAR or a branch office. At times, the amount of compensation provided to a IAR or branch may be dependent on volume of business that individual or branch has attained. IARs may also receive business entertainment from vendors or product sponsors with whom they interact or are authorized to do business. Entertainment engagement may be based on the amount of business placed with the vendors or product sponsors and may incentivize the IAR to place business with that vendor or product sponsor. IARs who are also representatives of the Firm’s parent company, Guardian Life Insurance Company of America, receive employee benefits (i.e., health and pension benefits) that are subsidized by Guardian if the IAR reaches certain sales targets. This subsidization program creates a conflict of interest as it encourages more sales that result in your Financial Professional meeting these sales targets to obtain additional subsidies. Some IARs have outside business activities that compete for their time or may influence their recommendations. If your IAR engages in any outside business activities, these activities can incentivize your IAR to spend more time on the outside business activity rather than his or her advisory relationship with you. In addition, if the outside business activity provides your IAR a higher rate of compensation, your IAR can be incentivized to recommend the outside business activity rather than a brokerage or advisory service offered by Park Avenue. You may research any outside business activities your IAR may have on FINRA’s BrokerCheck website at https://brokercheck.finra.org/. Certain IARs may enter into loans or other lending arrangements in order to expand their own business or purchase other books of business. When IARs enter into these lending arrangements the debt incurred can otherwise impact the IAR’s overall compensation received throughout any particular time-period. The amount of debt incurred and these lending scenarios could influence the manner in which the IAR attempts to earn additional transactional-based commissions when acting in their capacity as a registered representative of Park Avenue (commissions paid for the recommendation and sale of securities products) or investment advisory fees when acting in their capacity as an IAR (investment advisory fees for the ongoing advice provided to you) in order to meet their own personal debt obligations which may also indirectly influence their advice and recommendations made to you as their client. 32 PAS017974-VestWise (4/2026)  Financial Information Park Avenue does not have any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients 33 PAS017974-VestWise (4/2026)