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Item 1 – Cover Page
Petredis Investment Advisors LLC
Form ADV Part 2A Brochure
October 16, 2025
This Brochure provides information about the qualifications and business practices of Petredis
Investment Advisors LLC. You should review this brochure to understand your relationship
with our firm and help you determine to hire or retain us as your investment adviser. If you have
any questions about the contents of this brochure, please contact us at 878-231-4300. The
information in this Brochure has not been approved or verified by the United States of America
Securities and Exchange Commission (“SEC”) or by any state securities authority.
Additional information about Petredis Investment Advisors also is available on the SEC’s
website at www.adviserinfo.sec.gov. You can search this site by our firm name or by using a
unique identifying number, known as a CRD number. The CRD number for Petredis Investment
Advisors is 322371.
Petredis Investment Advisors is a registered investment adviser. Registration of an investment
adviser does not imply any level of skill or training.
100 Pinewood Lane, Suite 307, Warrendale, PA 15086
878-231-4300
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Item 2 – Material Changes
This section of the brochure discusses specific material changes that have been made to the brochure
since the firm’s last annual update in March 2025. Below is a summary of those changes.
Item 12 – Brokerage Practices – Selection and Recommendation of Broker-Dealers
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Effective October 1, 2025, through March 31, 2026 (or beyond if the program is extended),
TradePMR is offering an asset match program to clients of PIA on new funds and
investments transferred into an advisory account managed by PIA on the TradePMR
brokerage platform. Please refer to Item 12 of this brochure for important information
related to TradePMR’s asset match program.
We will provide you with a Summary of Material Changes made to this brochure annually at no
cost. You may receive an updated copy of this brochure at any time by contacting us at 878-231-
4300.
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Item 3 - Table of Contents
Item 1 – Cover Page ....................................................................................................................... 1
Item 2 – Material Changes.............................................................................................................. 2
Item 3 -Table of Contents ............................................................................................................... 3
Item 4 – Advisory Business ............................................................................................................. 4
Item 5 – Fees and Compensation .................................................................................................... 8
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................. 11
Item 7 – Types of Clients .............................................................................................................. 11
Item 8 – Methods of Analysis, Investment Strategies ..................................................................... 11
Item 9 – Disciplinary Information................................................................................................. 17
Item 10 – Other Financial Industry Activities and Affiliations ....................................................... 17
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading .................... 17
Item 12 – Brokerage Practices ....................................................................................................... 18
Item 13 – Review of Accounts ...................................................................................................... 21
Item 14 – Client Referrals and Other Compensation ..................................................................... 22
Item 15 – Custody ........................................................................................................................ 23
Item 16 – Investment Discretion ................................................................................................... 23
Item 17 – Voting Client Securities ................................................................................................. 23
Item 18 – Financial Information ................................................................................................... 24
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Item 4 – Advisory Business
About Our Firm
Petredis Investment Advisors (“PIA”) is a registered investment adviser that provides investment
management and financial advisory services to individual and institutional investors to help them
achieve their financial needs and goals. PIA has been a registered investment adviser since 2022. The
shareholders of the firm are Charles W. Petredis, Alexandra Cameron, Christian Petredis, Athena
Mallios and Charles J. Petredis.
Our firm takes pride in providing personalized service to our clients and acknowledges that it is held
to a fiduciary standard of care.
Types of Advisory Services We Offer
PIA offers a variety of investment advisory services to individuals, high net worth individuals,
retirement plans, non-profit organizations and foundations, and businesses/corporations. These
services include:
Investment and wealth management
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• Financial planning and consulting
• Fiduciary and non-fiduciary services for plan sponsors
We work with our clients to determine their investment objectives and risk profile and develop and
execute a customized investment plan based on their individual needs and goals. PIA will utilize the
financial information provided by the client to analyze and develop strategies and solutions to assist
the client in meeting their financial goals.
Prior to PIA rendering any of the foregoing services, clients are required to enter into one or more
written advisory agreements with PIA setting forth the relevant terms and conditions of the advisory
relationship.
Investment and Wealth Management Services
As part of our investment and portfolio management services, we offer:
Investment policy development
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• Asset allocation analysis
Investment due diligence
•
Investment search and recommendations
•
Investment and portfolio monitoring
•
• Wealth management strategies
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PIA manages our clients’ portfolios on a discretionary and non-discretionary basis. Our investment
and portfolio management services are tailored to the needs of our clients and are based on a
comprehensive understanding of each client’s current situation, past experiences, and future goals.
With this acquired knowledge we create, analyze, strategize, and implement goal-oriented
investment solutions. These solutions become our clients’ investment policy. This policy and our
matched strategies are designed to be risk appropriate, cost effective and tax efficient.
Our portfolio management services generally include a broad range of comprehensive financial
planning and/or consulting services, as well as discretionary and non-discretionary management of
investment portfolios.
Client assets are primarily allocated among individual equity and debt securities, exchange-traded
funds ("ETFs") and mutual funds in accordance with the client's stated investment objective and
risk/volatility parameters. We may also recommend clients allocate a certain portion of their assets
to alternative investments. Where appropriate, PIA may also provide advice about many types of
legacy positions or other investments held in client portfolios. Clients may also engage PIA to
manage and/or advise on certain investment products that are not maintained at their primary
custodian, such as variable life insurance and annuity contracts and assets held in employer
sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, PIA will
direct or make recommendations on a non-discretionary basis for the allocation of client assets
among the various investment options available with the product. These assets are generally
maintained at the underwriting insurance company or custodian for the plan trustee or
administrator and clients retain responsibility for effecting trades in these accounts.
PIA consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time
horizon, liquidity constraints and other related factors relevant to the management of their
portfolios. You should promptly notify us if there are changes in your financial situation or if you
wish to place any limitations on the management of your account. You may impose reasonable
restrictions or mandates on the management of your account if PIA determines, in our sole
discretion, the conditions will not materially impact the performance of a management strategy or
prove overly burdensome to the firm's management efforts.
To the extent a client’s assets are invested in a particular fund, those funds will have their own
investment practices, which are described in each fund’s prospectus or offering or other disclosure
documents. In addition, selected funds typically have discretion to determine the type, and amount,
of securities to be purchased or sold for the portion of the assets managed by the fund.
Financial Planning and Consulting Services
PIA offers different levels of financial planning and consulting services to help our clients identify,
prioritize and work towards their goals and objectives. Our consulting services give our clients the
ability to receive a broad range of financial advice and services, including specific security
recommendations, for the duration of the advisory agreement.
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Our process starts with an extensive review of a client's family situation, which includes assets and
liabilities as well as estate, tax, and insurance needs. We then employ a risk tolerance and risk
capacity-focused simulation to get a detailed cash flow analysis and proposed asset allocation.
Together, this information is analyzed to develop a proposed financial plan, which is designed to be
dynamic in nature, ever-evolving due to life changes, along with changes in cash flow needs, risk
tolerance, time horizon, or investment objectives.
PIA’s financial planning and consulting services may include any of the following topics:
• Liability Management
• Cash Flow Analysis and Forecasting
Investment Consulting
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• Risk Management
• Distribution Planning
• Trust & Estate Planning
• Tax Planning
• Charitable Giving
Insurance Review
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• Education Planning
• Next Generation Family
• Business Planning
• Retirement Planning
• Retirement Plan Consulting and
Employee Benefits Analysis
While each of these services is available on a stand-alone basis, certain financial planning services
are rendered in conjunction with investment management services as part of a comprehensive
portfolio management engagement. In performing these services, PIA is not required to verify any
information received from the client or from the client's other professionals (e.g., attorneys,
accountants, etc.), and is expressly authorized to rely on such information. PIA may recommend
clients engage the firm for additional related services, or we may recommend other professionals to
implement our recommendations. These additional services by PIA or another professional are
provided at an additional cost to you, which is based on the nature, extent, complexity, and other
characteristics of the services. This creates a conflict of interest because we will have an incentive to
recommend additional services based on the compensation to be received, rather than solely based
on your needs, and in some cases, based on the prospect of cross-referrals of advisory clients from
the other professional or his or her firm. Implementation of financial planning recommendations is
entirely at your discretion. You have complete freedom in selecting a financial adviser to assist you
with implementing the recommendations made in your financial plan and are under no obligation
to act on the advice of PIA. Financial planning recommendations are of a generic nature and are
not limited to any specific product or service offered by a broker dealer or insurance company.
Should you choose to implement the recommendations contained in the plan, PIA suggests you
work closely with your attorney, accountant and/or insurance agent.
PIA will act solely in our capacity as a registered investment adviser and does not provide any legal,
accounting or tax advice. You should seek the counsel of a qualified accountant and/or attorney
when necessary. As part of our advisory services, we may assist clients with tax loss harvesting and
will work with the client’s tax specialist to answer any questions related to the client’s portfolio. Any
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incidental tax discussions on topics, such as required minimum distributions, retirement plan
contributions, etc. should be verified with your tax advisor.
Fiduciary and Non-Fiduciary Services for Plan Sponsors
Retirement plan sponsors may retain our firm to provide advisory and consulting services for plan
assets. Fiduciary services available to plan sponsors include:
• Reviewing and assisting in the establishment of investment policies and objectives on behalf
of the plan
• Assistance with development of an Investment Policy Statement
• Recommending core investments to be offered to plan participants for selection by the plan
sponsor
• Recommending investment managers, within the meaning of ERISA Section 3(38), on
behalf of the plan, to be offered as investment options for plan participants
• Monitoring of the plan’s investments or investment managers in accordance with the plan’s
Investment Policy Statement or other relevant guidelines
• Developing and managing model portfolios as investment options for plan participants, as
investment manager, within the meaning of ERISA Section 3(38), on behalf of the plan
Non-fiduciary consulting services available to plan sponsors include:
• Educating plan participants on investment options available within the plan
• Preparation of periodic performance reports for the plan’s investments
• Assistance with monitoring the reasonableness of the fees and expenses of the plan’s
investments or investment managers in accordance with the plan’s Investment Policy
Statement or other relevant guidelines
• Benchmarking existing plan service providers to industry peers, and where appropriate,
conducting a search for new providers for the plan sponsor’s consideration and providing our
recommendation
Portfolio Management Services for Wrap Fee Program
PIA offers portfolio management services through a wrap fee program. A bundled or “wrap fee”
program is an advisory fee program under which you pay one bundled fee to compensate PIA for
portfolio management, transaction costs and custodial services. A wrap fee program may not be the
lowest cost option if you would like to restrict your investments to open-end mutual funds or other
long-term investment products.
Amount of Assets We Manage
As of December 2024, PIA manages approximately $1,404,595,036 of assets on a discretionary
basis, $0 of assets on a non-discretionary basis and has an additional $99,225,116 of assets under
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advisement. Discretionary assets under management are those for which we have an ongoing
responsibility to select and make securities recommendations that are in line with your financial
needs and objectives and then effect those securities transactions without first consulting you. Non-
discretionary assets under management are those for which we have an ongoing responsibility to
select and make securities recommendations that are in line with your financial needs and objectives
and then effect those securities transactions only after consulting with you to inform you of the
transaction(s) and obtaining your approval to move forward. Assets under advisements are assets of
participant-directed 401k plans and other self-directed retirement plans for which PIA provides
investment advice.
Item 5 – Fees and Compensation
How We Are Compensated for Our Advisory Services
Our fees vary among the different types of advisory services we offer and may be negotiated at our
sole discretion. The specific fees and manner in which fees are charged and calculated are described
in your investment advisory agreement. You should carefully review the investment advisory
agreement prior to signing it.
Fees for our advisory services may be higher than fees charged by other advisers who offer similar
services. You may be charged different fees than similarly situated clients for the same services. You
should carefully review this brochure to understand the fees and other sources of compensation that
exist among our services prior to entering into an investment advisory contract with our firm.
Investment and Portfolio Management Services
PIA offers investment and wealth management services for an annual fee based on the amount of
assets under the firm’s management. Fees are generally billed in advance each calendar quarter
based on the market value of the assets under management/advisement on the last day of the
previous calendar quarter. The maximum fee rate for new clients is as follows:
Maximum Annual
Advisory Fee
0.90%
Fees may be based on cumulative household assets under management. However, certain ERISA
rules prevent householding corporate plans with personal assets for fee reductions. Existing clients
may be grandfathered and charged according to their existing fee rate. You should refer to your
advisory agreement for your specific fee rate(s).
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For investment and portfolio management services PIA provides to certain clients or for specific
client holdings (e.g., held-away assets, 529 plans, etc.), we may negotiate a fee rate that differs from
our standard fee.
Financial Planning and Consulting Services
Fees for financial planning and consulting services are billed at a fixed or hourly rate and are billed
in advance. Our hourly rate is generally between $250-$750 an hour and range up to $20,000.
Fees for financial planning and consulting services are due and payable as incurred. While financial
planning and consulting services are available on a stand-alone basis, certain services may also be
rendered in conjunction with investment portfolio management services at no additional cost as part
of a comprehensive portfolio management engagement.
Factors we consider when determining our financial planning and consulting fees include, but are
not limited to:
• The amount of time we expect to spend completing the financial planning or consulting
services and providing related advice;
• The complexity of your goals, issues and/or needs;
• The extensiveness and complexity of the data needed regarding your personal financial
information;
• Your net worth or the value of your investment accounts and/or other assets that are the
subject of the financial planning or consulting services; and/or
• Special circumstances related to life changes, marital status, health or special income needs,
or growth or decline of a personal business.
PIA may request a retainer to initiate financial planning and consulting services; however, we will
not request the prepayment of fees more than $1,200 in advisory fees more than six months in
advance.
You may engage PIA for additional investment management services to assist with implementing
one or more financial planning recommendations. You will incur additional fees if you retain our
firm for such services. You have complete freedom in selecting an investment adviser to assist you in
implementing any recommendations by PIA and are under no obligation to act upon the advice we
provide.
For stand-alone financial planning services, the agreement between PIA and the client will terminate
upon delivery of the plan or completion of the service. For consulting services, the investment
advisory agreement between PIA and the client will continue in effect until terminated by either
party.
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Fiduciary and Non-Fiduciary Services for Plan Sponsors
Fees for retirement plan sponsors are negotiable. Fees are based upon the value of the plan assets
that are the subject of the consulting services and are generally payable in arrears on a quarterly
basis. Fees for one-time projects are payable either upon completion of the project or half paid upon
execution of the agreement with the balance due upon completion of the project.
Payment of Fees
Clients authorize PIA to instruct the account custodian to directly debit fees from the client’s
account. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee.
Fees for our advisory services generally require you to pay investment advisory fees in advance of
receiving services. Any pre-paid, unearned fees will be promptly refunded. Advisory fees are
prorated for additions and withdrawals of more than $1,000,000 to or from an account throughout
the quarter. Household assets that are journaled from one account to another within the household
are billed in advance according to the valuation of the initial account for that quarter.
• For investment management and fiduciary and non-fiduciary consulting services, refunds are
calculated by taking the total advisory fee billed for the calendar quarter, dividing that
amount by the number of days in the calendar quarter and multiplying that amount by the
number of days services were not provided during the calendar quarter.
• For financial planning and consulting services, refunds are calculated based on the value of
the services that were completed prior to termination of the advisory agreement.
• For one-time consulting projects that are partly paid upon execution of the agreement, the
amount of the refund is calculated based on the value of the services that were completed.
Any earned, unpaid fees will be due and payable upon termination of the advisory contract.
Other Types of Fees and Expenses You May Incur
Clients may incur certain charges imposed by custodians, brokers, third-party investments and other
third parties, such as custodial fees, odd-lot differentials, ADR service charges, transfer taxes, wire
transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities
transactions. Decisions to reallocate your account assets may result in you incurring a redemption
fee imposed by one or more mutual funds held in your account. Mutual funds and exchange traded
funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such
charges, fees and commissions are exclusive of and in addition to PIA’s fee. PIA shall not receive
any portion of these commissions, fees, and costs, including any distribution or “12b-1” fees paid by
the mutual funds in which your account assets are invested.
There may be times when another broker-dealer is used to execute fixed-income trades (commonly
referred to as “trading away” or “step out trades”). In instances where PIA has determined it is in
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the client’s best interest to utilize another broker-dealer to execute a transaction, the cost of the
transaction will be included in the wrap program fee.
Other Types of Compensation We Receive
PIA has contracted with TradePMR, Inc. (“TradePMR”) for brokerage services, including trade
processing, collection of management fees, marketing assistance and research. Item 12 – Brokerage
Practices further describes the factors that PIA considers in selecting or recommending broker-
dealers for client transactions and determining the reasonableness of their compensation (e.g.,
commissions).
Item 6 – Performance-Based Fees and Side-By-Side Management
PIA does not charge any performance-based fees or participate in side-by-side management.
Item 7 – Types of Clients
PIA provides portfolio management services to individuals, high net worth and ultra-high net worth
individuals, families, including multi-generational families, retirement plans, non-profit
organizations and foundations, businesses/corporations, and other business entities.
PIA generally does not require a minimum initial investment for investment management services.
The firm, in its sole discretion, will accept clients based upon each client’s particular circumstances.
Item 8 – Methods of Analysis, Investment Strategies
Methods of Analysis and Investment Strategies
PIA carefully constructs a risk-adjusted, tax-efficient, and cost-effective asset allocation strategy
based on a client’s unique cash flow needs, stated return and risk profile. Security selection is based
on qualitative, quantitative, technical, and relative strength metrics. Portfolio holdings are constantly
monitored and adjusted as market conditions and our clients’ circumstances dictate. Clients may
hold or retain other types of assets as well and PIA may offer advice regarding those various assets
as part of our services. Advice regarding such assets generally will not involve asset management
services.
PIA predominantly utilizes a combination of active and passive strategies to allocate client assets
primarily among publicly traded securities, such as stocks, bonds, ETFs and mutual funds.
Nevertheless, individual client circumstances may dictate the use of other types of securities or
alternative investments. Depending upon the client’s financial needs, strategies implemented might
include long term purchases (securities held at least a year), short term purchases (securities sold
within a year), short sales, margin transactions, option writing, including covered options,
uncovered options or spreading strategies, and other securities transactions.
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Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. All investments
present the risk of loss of principal – the risk that the value of securities (e.g., stocks, mutual funds,
ETFs, bonds, etc.), when sold or otherwise disposed of, may be less than the price paid for the
securities. Even when the value of the securities when sold is greater than the price paid, there is the
risk that the appreciation will be less than inflation. In other words, the purchasing power of the
proceeds may be less than the purchasing power of the original investment. There is no guarantee
that investment recommendations made by PIA will be successful. We cannot assure that your
account will increase, preserve capital, or generate income, nor can we assure that your investment
objectives will be realized. Although all investments involve risk, our investment advice seeks to
limit risk through diversification among various asset classes.
We may recommend a variety of security types for your account in an effort to achieve your
individual needs and goals. This may include, but is not limited to, stocks, bonds, ETFs, open-end
and closed-end mutual funds, hedge funds, private equity funds, venture capital funds, real estate
investment trusts, or other private alternative or other investment funds. An investment in such other
funds or managers may present risks specific to the particular investment vehicle, such as long-term
illiquidity, redemption notice periods or other restrictions on redemptions, capital calls, or periodic
taxable income distribution.
We may recommend a variety of security types for your account to help you achieve your individual
needs and goals. Described below are the material risks associated with investing in the types of
securities we generally use in client accounts, as well as risks associated with our investment
strategies and methods of analysis and other general risks:
Product Risks
Equity Securities
In general, prices of equity securities (common, convertible preferred stocks and other securities
whose values are tied to the price of stocks, such as rights, warrants and convertible debt securities)
are more volatile than those of fixed-income securities. The prices of equity securities could decline
in value if the issuer’s financial condition declines or in response to overall market and economic
conditions. Investments in smaller companies and mid-size companies may involve greater risk and
price volatility than investments in larger, more mature companies.
Fixed-Income Securities
The return and principal value of bonds fluctuate with changes in market conditions. Fixed-income
securities are subject to interest rate risk and credit quality risk. The market value of fixed-income
securities generally declines when interest rates rise, and an issuer of fixed-income securities could
default on its payment obligations. Changes in interest rates generally have a greater effect on bonds
with longer maturities than on those with shorter maturities. If bonds are not held to maturity, they
may be worth more or less than their original value. Credit risk refers to the possibility that the issuer
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of a bond will not be able to make principal and/or interest payments. High yield bonds, also known
as “junk bonds,” carry higher risk of loss of principal and income than higher rated investment grade
bonds.
Exchange-Traded Funds (ETFs)
ETFs are typically investment companies that are legally classified as open-end mutual funds or unit
investment trusts. ETFs differ from traditional mutual funds in that ETF shares are listed on a
securities exchange. Shares can be bought and sold throughout the trading day like shares of other
publicly traded companies. ETF shares may trade at a discount or premium to their net asset value.
This difference between the bid price and ask price is often referred to as the “spread.” The spread
varies over time based on the ETF’s trading volume and market liquidity. It is generally lower if the
ETF has high trading volume and market liquidity and higher if the ETF has low trading volume
and market liquidity. Liquidity risks are higher for ETFs with a large spread. ETFs may be closed
and liquidated at the discretion of the issuing company.
Mutual Funds
Mutual funds may invest in different types of securities, such as value or growth stocks, real estate
investment trusts, corporate bonds, or U.S. government bonds. There are risks associated with each
asset class.
An investment in a money market fund is not insured or guaranteed by the Federal Deposit
Insurance Corporation or any other governmental agency. Although money market funds seek to
preserve the value of your investment at $1.00 per share, it is possible to lose money by investing in
the fund. Redemption is at the current net asset value, which may be more or less than the original
cost. Aggressive growth funds are most suitable for investors willing to accept price per share
volatility since many companies that demonstrate high growth potential can also be high risk.
Income from tax-free mutual funds may be subject to local, state and/or the alternative minimum
tax.
Because each mutual fund owns different types of investments, performance will be affected by a
variety of factors. The value of your investment in a mutual fund will vary from day to day as the
values of the underlying investments in a fund vary. Such variations generally reflect changes in
interest rates, market conditions and other company and economic news. These risks may become
magnified depending on how much a fund invests or uses certain strategies. A fund’s principal
market segment(s), such as large-cap, mid-cap or small-cap stocks, or growth or value stocks may
underperform other market segments or the equity markets as a whole.
You can find additional information regarding these risks in the fund’s prospectus.
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International Investing
The risks of investing in foreign securities include loss of value as a result of political or economic
instability; nationalization, expropriation or confiscatory taxation; changes in foreign exchange rates
and foreign exchange restrictions; settlement delays; and limited government regulation (including
less stringent reporting, accounting, and disclosure standards than are required of U.S. companies).
These risks may be greater with investments in emerging markets. Certain investments utilized by
PIA may also contain international securities.
Cash and Cash Equivalents
A portion of your assets may be invested in cash or cash equivalents to achieve your investment
objective, provide ongoing distributions, and/or take a defensive position. Cash holdings may result
in a loss of market exposure.
Alternative Investments
Alternative investments are illiquid investments and do not trade on a national securities exchange.
Alternative investments typically include investments in direct participation program securities
(partnerships, limited liability companies, business development companies or real estate investment
trusts), commodity pools, private equity, private debt, or hedge funds. Alternative investments are
subject to various risks, such as illiquidity and property devaluation based on adverse economic
and/or real estate market conditions.
Alternative investments are not suitable for all investors. Investors considering an investment
strategy utilizing alternative investments should understand that alternative investments are
generally considered speculative in nature and may involve a high degree of risk, particularly if
concentrating investments in one or few alternative investments. These risks are potentially greater
and substantially different than those associated with traditional equity or fixed income investments.
Additional information regarding these risks can be found in the product’s prospectus or offering
documents.
Options
Certain types of option trading may be permitted in your account in order to generate income or
hedge a security held in the account. There are additional risks with using options. An option holder
runs the risk of losing the entire amount paid for the option in a relatively short period of time. The
risks of covered call writing include the potential for the market to rise sharply, which may cause the
security to be called away and no longer be held in the account. The risk of buying long puts is
limited to the loss of the premium paid for the purchase of the put if the option is not exercised or
otherwise sold. The writer of a put option bears a risk of loss if the value of the underlying interest
declines below the exercise price, and such loss could be substantial if the decline is significant. The
obligation of a writer of a put that is not cash-secured to meet margin requirements creates
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additional risks. Combination transactions, such as option spreads, are more complex than buying
or writing a single option and carry additional risks.
You can find additional information regarding the risks associated with options trading on the
Options Industry Council website, www.optionseducation.org.
Investment Strategies Risks
Security Recommendations in Opposing Directions
PIA advises with regard to customized portfolios to meet individual client needs in accordance with
the client’s IPS. Customization of client portfolios can lead to PIA recommending that certain
clients buy a security and other clients sell the same security, which can result in material differences
in account performance between clients.
Operational Risks
Business Continuity
PIA's operations could be disrupted by catastrophic events, such as fires, natural disasters, terrorist
attacks, wars or similar emergencies resulting in property damage, network disruptions or prolonged
power outages. Despite having contingency plans and conducting regular tests, it's impossible to
prepare for every potential event. These risks could significantly impact PIA and its operations.
Pandemic Outbreak
Epidemics or pandemics can introduce market and business uncertainties, including market
volatility, business closures, supply chain disruptions, travel restrictions and widespread medical
absences. PIA has policies and procedures to manage these situations; however, the unpredictable
nature of large outbreaks means not all eventualities can be anticipated or addressed. The COVID-
19 pandemic highlighted the importance of having a robust Business Continuity Plan, which allows
PIA personnel to work remotely or on a hybrid office-remote basis. Future incidents might impact
operations differently, including those of PIA, third-party asset managers recommended or utilized
by PIA, product sponsors and key service providers.
Economic and Political Conditions
Economic changes, such as fluctuations in interest rates, inflation, currency values, industry
conditions, competition, technological advancements, trade relations, political events and tax laws,
can adversely affect investment performance. Economic, political and financial conditions, including
military conflicts and sanctions, can cause market volatility, illiquidity and other negative effects.
Economic or political instability, diplomatic issues or disasters in regions where client assets are
invested could harm many kinds of investments. The potential for recession and its impact on
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different asset classes is uncertain and beyond PIA's control, with no guarantees that PIA can predict
these developments.
Cybersecurity
PIA and its service providers, counterparts and other market participants rely heavily on information
technology and communications systems. These systems face numerous cybersecurity threats that
can negatively impact clients, despite efforts to mitigate these risks through advanced technologies,
processes and practices aimed at protecting system security and the confidentiality, integrity and
availability of our clients’ information. Unauthorized access, operational disruptions, data theft or
inadvertent disclosure of sensitive information could occur, posing significant risks. A breach or
security failure could lead to data or financial loss and system inaccessibility for clients and
regulatory penalties, reputational damage or additional compliance costs for PIA.
Custody
PIA is obligated to keep client funds and securities over which it has custody with a qualified
custodian. There is a risk of loss if a custodian faces insolvency, fraud or mismanagement. Cash and
securities held in a brokerage account may exceed Securities Investor Protection Corporation
coverage, which generally protects accounts up to $500,000, including up to $250,000 in cash.
Clients are at risk if a brokerage firm holding their assets fails to fulfill its obligations or faces
distress, potentially impacting your ability to access assets or utilize services. While non-cash assets
held in custody at a bank are typically outside a failed bank’s estate, client accounts could still be
impacted by delays in accessing funds, settling trades or delivering securities due to a bank's failure.
Diversifying custodial relationships may mitigate such risks.
Counterparties
PIA’s clients may face credit and liquidity risks from their dealings with various counterparties.
Should a counterparty fail due to financial distress, recovering assets or funds under contractual
agreements may be delayed or limited. The absence of independent evaluations of counterparties'
financial health and a regulated market can increase potential losses, especially under adverse
market conditions.
Key Persons
PIA’s investment success heavily relies on the experience of its executives. Losing one or more key
individuals could adversely impact investment performance due to diminished strategy
development, opportunity sourcing, relationship leveraging and investment expertise.
Artificial Intelligence and Machine Learning
The use of artificial intelligence and machine learning includes increased risk of data inaccuracies
and security vulnerabilities. Due to the rapid advancement of machine learning technologies, future
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risks related to artificial intelligence are unpredictable. As a measure to mitigate these risks to our
clients, PIA performs periodic due diligence of our service providers for assurance that the service
providers have appropriate controls in place to protect our clients’ information and to limit data
inaccuracies when artificial intelligence is used by the service provider.
Item 9 – Disciplinary Information
As a registered investment adviser, PIA is required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of our firm or the integrity of our
management. PIA has no disciplinary information to report.
Item 10 – Other Financial Industry Activities and Affiliations
PIA has no other financial industry activities or affiliations.
Item 11 – Code of Ethics, Participation in Client Transactions and Personal
Trading
Our Code of Ethics
PIA is committed to providing investment advice with the utmost professionalism and integrity. Our
firm strives to identify manage and/or mitigate conflicts of interest and has adopted policies,
procedures, and oversight mechanisms to address conflicts of interest. We have adopted a Code of
Ethics that emphasizes our fiduciary obligation to put client interests first and is designed to ensure
personal securities transactions, activities, and interests of employees will not interfere with the
responsibilities to make decisions in the best interest of clients. All supervised persons of our firm
must acknowledge and comply with our Code of Ethics. We will provide a copy of our Code of
Ethics to any client or prospective client upon request.
Participation in Client Transactions
PIA does not effect principal or agency cross securities transactions for client accounts. PIA also
does not 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 a security to an 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
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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.
Employee Personal Trading
Supervised persons of PIA may purchase or sell the same security that we recommend for
investment in client accounts. This creates a conflict of interest as there is a possibility that
employees of our firm might benefit from market activity by a client in a security held by the
employee. Our Code of Ethics is designed to assure that the personal securities transactions,
activities and interests of the employees of PIA will not interfere with making decisions in the best
interest of advisory clients and implementing such decisions while, at the same time, allowing
employees to invest for their own accounts. Under the Code of Ethics, certain classes of securities
have been designated as exempt transactions, based upon a determination that these would not
materially interfere with the best interest of PIA’s clients. Our Code of Ethics also places restrictions
on our employees’ personal trading activities. These restrictions include, but are not limited to, a
prohibition on trading based on non-public information and pre-clearance requirements for certain
types of transactions. Employee trading is continually monitored under the Code of Ethics in an
effort to prevent conflicts of interest between PIA and our clients.
Certain affiliated accounts may trade in the same securities with client accounts on an aggregated
basis when consistent with PIA’s obligation of best execution. In such circumstances, the affiliated
and client accounts will share commission costs equally and receive securities at a total average
price. PIA will retain records of the trade order (specifying each participating account) and its
allocation, which will be completed prior to the entry of the aggregated order. Completed orders will
be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro
rata basis. Any exceptions will be explained on the order.
Item 12 – Brokerage Practices
Selection and Recommendation of Broker-Dealers
Though PIA recommends brokers with which we have negotiated pricing on behalf of our clients,
we do not have discretionary authority to select brokers. We endeavor to recommend broker-dealers
that will provide the best services at the lowest commission rates possible. The reasonableness of
commissions is based on the broker's ability to provide professional services, competitive
commission rates, research and other services that will help our firm provide investment
management services to clients. PIA may recommend brokers who provide useful research and
securities transaction services even though a lower commission may be charged by a broker who
offers no research services and minimal securities transaction assistance.
We have negotiated competitive pricing and services with TradePMR, Inc. (“TradePMR) for
brokerage back-office and trade execution services. TradePMR clears trades and custodies assets at
First Clearing Corp. (“FCC”). First Clearing Corp. is a trade name used by Wells Fargo Clearing
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Services, LLC., a non-bank affiliate of Wells Fargo & Company. TradePMR and FCC are members
of SIPC and are unaffiliated registered broker-dealers and FINRA members. The brokerage
commissions and/or transaction fees charged by the broker-dealer are included in PIA’s advisory
fee. PIA regularly reviews the reasonableness of the compensation received by the broker-dealers
used for executing client transactions in an effort to ensure that our clients receive favorable
execution consistent with our fiduciary duty. Factors which PIA considers in recommending broker-
dealers to clients include, but is not limited to, their respective financial strength, reputation,
execution, pricing, research, and service. The commissions and/or transaction fees charged by these
brokers may be higher or lower than those charged by other broker-dealers.
The commissions paid by PIA’s clients are intended to be consistent with our duty to obtain “best
execution.” However, a client may pay a commission that is higher than what another broker-dealer
might charge to effect the same transaction when PIA determines, in good faith, that the
commission is reasonable in relation to the value of the brokerage and research services received. In
seeking best execution, the determinative factor is not the lowest possible cost, but whether the
transaction represents the best qualitative execution, taking into consideration the full range of a
broker-dealer’s services, including among others, execution capability, commission rates, and
responsiveness. There may be times when another broker-dealer is used to execute fixed-income
trades (commonly referred to as “trading away” or “step out trades”). In instances where PIA has
determined it is in the client’s best interest to utilize another broker-dealer to execute a transaction,
the cost of the transaction will be included in the wrap program fee. Consistent with the foregoing,
while PIA will seek competitive rates, it may not necessarily obtain the lowest possible commission
rates for client transactions.
TradePMR Asset Match Program
Effective October 1, 2025, through March 31, 2026 (or beyond if the program is extended),
TradePMR is offering an asset match program to clients of PIA on new funds and investments
transferred into an advisory account managed by PIA on the TradePMR brokerage platform. All
securities and options available to trade on the TradePMR brokerage platform are eligible for the
asset match. Non-eligible securities and products include private placements, mutual funds held
directly with the fund company and are not listed on an exchange, unlisted interval and closed end
funds, restricted securities not available for public trading, swaps and other over-the-counter
derivatives, control shares, annuities, and any securities not held in an account on the TradePMR
brokerage platform. The asset match offer does not apply to qualified plans and 529 accounts or
transfers from other accounts held at Wells Fargo Clearing Services, Wells Fargo Advisors Financial
Network or Wells Fargo Securities.
The asset match offer is 0.5% of the value of deposits into an advisory account managed by PIA on
the TradePMR brokerage platform and is subject to a five-year earn-out period. The asset match will
be earned if, on the 10th day of the calendar month following the month in which a deposit is made,
no portion of the deposit has been withdrawn. If any portion or all of the deposit is withdrawn prior
to the 10th day of the calendar month following the month in which the deposit was made, the
match on that portion withdrawn will not be earned. The asset match may have tax implications
depending on your account type and circumstances.
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Certain limitations apply to the asset match program offered by TradePMR, such as an early
removal fee if any assets are transferred out, withdrawn or distributed from an account receiving the
asset match that causes the value of the account to be less than the value of the assets deposited into
the account during a five (5) year period starting on the calendar day the asset match is credited to
the account. It is important for clients of PIA to review and understand the limitations of
TradePMR’s asset match program, which can be found on TradePMR’s website at TradePMR's
Asset Match Program Terms and Conditions.
The asset match program is being offered by TradePMR, as the introducing broker-dealer for PIA’s
client accounts. In no way is PIA involved in the offering of the asset match program, nor does
PIA’s recommendation to use TradePMR for brokerage services constitute an endorsement of or
recommendation to participate in the asset match program. You should be aware that the more
assets there are in your account, the more you will pay in fees to PIA, which creates an incentive for
PIA to recommend or encourage you to increase the assets in your account. Further, the early
removal fee under the asset match program presents a conflict of interest between PIA and our
clients. As a fiduciary, PIA is required to act in the best interest of our clients and seek to obtain the
best price and execution for clients’ securities transactions. It is PIA’s policy to conduct a best
execution review, at least annually, of the broker-dealers we recommend to clients at least annually
to evaluate the broker’s brokerage and execution practices. If at any point in the future PIA
determines TradePMR no longer provides competitive and quality brokerage services, we may
recommend another broker-dealer to our clients, which could result in a client participating in the
asset match program to pay an early removal fee to TradePMR if assets are transferred out of an
advisory account on the TradePMR brokerage platform. PIA will mitigate this conflict of interest by
adhering to our fiduciary duty to seek to achieve best execution for our clients in a manner that the
full range of and quality of a broker’s services to the client is the most favorable under the
circumstances and putting our clients’ best interest first.
For more information on TradePMR’s asset match program, please refer to TradePMR’s website at
TradePMR's Asset Match Program Terms and Conditions.
Products & Services Available to Us from Broker-Dealers
The broker-dealers we recommend to clients provide PIA with access to institutional trading and
custody services, which are typically not available to retail investors. These brokerage and custodial
services include the execution of securities transactions, custody, research, and access to mutual
funds and other investments that are otherwise generally available only to institutional investors or
would require a significantly higher minimum initial investment. Other benefits we may receive
include receipt of duplicate client confirmations and bundled duplicate statements; access to a
trading desk that exclusively services its participants; access to block trading, which provides the
ability to aggregate securities transactions and then allocate the appropriate shares to client accounts;
and access to an electronic communication network for client order entry and account information.
PIA also receives other services from broker-dealers (or third-party vendors with which they do
business) to help us manage and further develop our business enterprise. These services include
educational conferences and events; due diligence meetings; technology, compliance, legal,
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marketing and business consulting; publications and conferences on practice management and
business succession; and access to employee benefits providers, human capital consultants and
insurance providers. Fees for these services may be waived, discounted or compensated by the
broker-dealer. Irrespective of these direct and indirect benefits to our clients, we strive to enhance
our clients’ experience and always put the needs of our clients first.
Research and Other Soft Dollar Benefits
PIA does not participate in soft-dollar relationships.
Brokerage for Client Referrals
When selecting broker-dealers for the execution of client securities transactions, PIA does not
consider whether we will receive any client referrals from the broker-dealer or any other third-party.
Directed Brokerage
As PIA will not request the discretionary authority to determine the broker-dealer to be used or the
commission rates to be paid, clients must direct PIA as to the broker-dealer to be used. The
commissions and transaction fees charged by these broker-dealers could be higher or lower than
those charged by other custodians and broker-dealers. When directing the use of a particular broker-
dealer, it should be understood that PIA will not have authority to negotiate commissions among
various broker-dealers or obtain volume discounts. As such, best execution may not be achieved.
Not all investment advisers require clients to direct the use of specific broker-dealers
Aggregation of Orders
PIA typically effects trades on an aggregated basis whenever possible and advantageous to clients,
such as discretionary accounts aligned with one of the firm’s model portfolios. Clients with a
customized portfolio, non-discretionary account and certain other client transactions are generally
effected independently based on the client’s individual needs and goals. The blocking of trades
entails the trading of aggregate blocks of securities composed of assets from multiple client accounts
where transaction costs are shared equally and on a pro-rated basis between all accounts included in
the block. Block trading allows us to execute equity or fixed income trades in a timely, equitable
manner and to reduce overall commission charges to clients but is not always feasible. Clients who
do not provide PIA with discretion will not participate in block trades, and their trades in similar
securities will be placed with brokers after trades for discretionary accounts. Accounts owned by
supervised persons of our firm may participate in block trading with your accounts; however, these
individuals will not be given preferential treatment of any kind.
Item 13 – Review of Accounts
Accounts at PIA are reviewed on a periodic basis. This informal review includes assessing client
goals and objectives, monitoring the account, and addressing the need to rebalance, as necessary.
Individual securities held in client accounts are periodically monitored by the firm. Accounts are
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reviewed in the context of each client’s stated investment objectives and guidelines. More frequent
reviews may be triggered by material changes to a client’s individual circumstances, market
conditions, tax law changes or the political or economic environment.
PIA may also review tax-planning needs, cash-flow needs, as well as charitable giving, insurance,
and estate planning as part of our ongoing client reviews. Reviews are tailored to the services we
provide to you, as well as your individual needs and goals. We encourage you to discuss your needs,
goals, and objectives with us and keep us informed of any changes. If you engage our firm for
ongoing investment advisory services, we will contact you at least annually to determine whether
there have been any changes to your financial situation or investment objectives and whether you
wish to impose any reasonable restrictions on the management of your account or reasonably
modify any existing restrictions. At this time, we will advise you of any account changes we feel are
necessary to help you stay on track with meeting your financial goals and consider whether the
current services provided by our firm continue to be suitable for your needs.
As a convenience to our clients, in addition to reporting on clients’ financial assets, at a client’s
request we may prepare a global consolidated report that also includes certain non-financial assets
(e.g., real assets). In such instances, PIA relies on the client to provide current and accurate price or
other valuation information for those assets to be included in the client’s consolidated account
report. In no instance are non-financial assets included in any performance reporting. PIA does not
independently verify, and expressly disclaims responsibility for, the accuracy of any non-financial
asset values clients provided to us to include in their reporting.
Item 14 – Client Referrals and Other Compensation
Other Compensation Arrangements
PIA receives compensation from the broker-dealer used for your account and your account
custodian in the form of access to electronic systems that assist us in the management of client
accounts, as well as research, software and other technology that provide access to client account
data (such as trade confirmations and account statements), pricing information and other market
data, facilitate trade execution (and allocation of aggregated trade orders for multiple client
accounts), and client reporting capabilities. Your account custodian also offers us discounts for
products and services offered by vendors and third-party service providers, such as software and
technology solutions. These economic benefits create a conflict of interest in that it gives our firm an
incentive to recommend one broker-dealer or custodian over another that does not provide similar
electronic systems, support, or services. We address this conflict of interest by disclosing to our
clients the types of compensation that our firm receives so clients can consider this when evaluating
our firm. It is important that you consider the fees, level of service and investment strategies, among
other factors, when selecting an investment manager.
Client Referrals
PIA does not pay any referral fees to other individuals for referring clients to our firm.
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Item 15 – Custody
When you establish a relationship with our firm for investment management services, your assets
will be maintained by a bank, broker -dealer, mutual fund transfer agent or other such institution
deemed a ‘qualified custodian’ by the SEC. We rely on the custodian to price and value assets,
execute and clear transactions, maintain custody of assets in your account and perform other
custodial functions. PIA does not maintain physical possession of any client account assets. Clients’
assets must be held by a bank, broker dealer, mutual fund transfer agent or other such institution
deemed a qualified custodian. We utilize FCC as the qualified custodian for client accounts.
Nevertheless, PIA is deemed to have custody, pursuant to Rule 206(4)-2 of the Investment Advisers
Act of 1940, as amended, due to its authority over certain accounts to distribute assets subject to a
third-party standing letter of authorization. PIA relies on the SEC No-Action Letter issued to the
Investment Advisers Association, dated February 21, 2017, which provides an exemption from the
annual surprise custody examination by an independent accountant.
You will receive monthly and/or quarterly account statements directly from the qualified custodian.
PIA may also provide you with written quarterly performance reports for your account upon
request. We urge you to carefully review your account statements and compare the account balances
with the balances reflected on any performance report you may receive from our firm for accuracy.
Balances on our reports may vary slightly from custodial statements due to differences in accounting
procedures, reporting dates, valuation methodologies of certain securities or other operational
factors. You should promptly notify us if you do not receive account statements from your custodian
at least quarterly or if you believe the information on your account statements is inaccurate.
Item 16 – Investment Discretion
PIA typically has investment discretion over clients’ securities accounts. Investment discretion is the
authority to determine the securities or other assets to purchase or sell on behalf of an account.
Investment discretion may also include the authority to select or terminate a third-party asset
manager. This authority is exercised in a manner consistent with your stated investment objective
for the particular account. You must provide written authorization to our firm before we can assume
discretionary authority over your account. Any investment guidelines or restrictions you would like
to place on your account must be provided to PIA in writing.
Clients that wish to maintain discretion over their accounts should understand that PIA cannot
effect any account transactions without first obtaining your consent.
Item 17 – Voting Client Securities
As a general policy, PIA will retain proxy voting authority for clients that have given us the
authority to do so and will utilize a third-party service provider to assist the firm with voting proxies.
In such cases, we will follow the proxy voting guidelines outlined in our Proxy Voting Policies and
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Procedures. You may obtain a copy of our Proxy Voting Policies and Procedures and/or a record of
ballots voted upon request.
Clients may also elect to have us participate in class action lawsuits and related settlements on their
behalf. In such cases, we utilize a third-party service provider to assist the firm with the filing
process, who receives 20% of any settlement awarded to the client for their services.
Item 18 – Financial Information
As a registered investment adviser, PIA is required to provide you with certain financial information
about our firm.
Prepayment of Fees
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more
in advance.
Our Financial Condition
We do not have any financial commitment that is reasonably likely to impair our contractual
commitments to our clients, nor has our firm ever been the subject of a bankruptcy proceeding.
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