Overview
Assets Under Management: $121 million
High-Net-Worth Clients: 58
Average Client Assets: $2 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Fee Structure
Primary Fee Schedule (DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $1,000,000 | 1.00% |
| $1,000,001 | $5,000,000 | 0.75% |
| $5,000,001 | $10,000,000 | 0.50% |
| $10,000,001 | and above | 0.25% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $40,000 | 0.80% |
| $10 million | $65,000 | 0.65% |
| $50 million | $165,000 | 0.33% |
| $100 million | $290,000 | 0.29% |
Clients
Number of High-Net-Worth Clients: 58
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 87.13
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 326
Discretionary Accounts: 267
Non-Discretionary Accounts: 59
Regulatory Filings
CRD Number: 163994
Last Filing Date: 2025-02-13 00:00:00
Website: https://prakashadvisors.com
Form ADV Documents
Additional Brochure: DISCLOSURE BROCHURE (2025-07-17)
View Document Text
Item 1: Cover Page
PIAR LLC
5931 Flowering Hill Court
Las Vegas, NV 89131
978.273.9747
Disclosure Brochure
July 11, 2025
This Form ADV2A (“Disclosure Brochure”) provides information about the qualifications and
business practices of PIAR LLC (“PIAR” or the “Advisor”). If you have any questions about
the contents of this brochure, please contact the Advisor at 978.273.9747. The information
in this brochure has not been approved or verified by the United States Securities and
Exchange Commission (“SEC”) or by any state securities authority.
PIAR LLC is a registered investment advisor with the U.S. Securities and Exchange
Commission (“SEC”). Registration of an investment advisor does not imply any level of skill
or training.
Additional information about PIAR and its Advisory Persons is also available on the SEC’s
website at www.adviserinfo.sec.gov by searching with the Advisor firm name or CRD#
163994.
Item 2: Material
Changes
Item 3: Table of Contents
Investment Advisory fees.
Please see Item 5 for
additional information.
Future Changes
Item 4: Advisory Business ................. 1
Item 5: Fees and Compensation ....... 3
Item 6: Performance-Based Fees and
Side-by-Side Management ............... 5
Item 7: Types of Clients ...................... 6
Item 8: Methods of Analysis,
Investment Strategies and Risk of
Loss ...................................................... 6
Item 9: Disciplinary Information ..... 8
Form ADV 2 is divided into
two parts: Part 2A and
Part 2B. Part 2A (the
“Disclosure Brochure”)
provides information
about a variety of topics
relating to an Advisor’s
business practices and
conflicts of interest. Part
2B (the “Brochure
Supplement”) provides
information about the
Advisory Persons of PIAR
LLC (“PIAR” or the
“Advisor”).
Item 10: Other Financial Industry
Activities and Affiliations ................. 8
From time to time, the
Advisor may amend this
Disclosure Brochure to
reflect changes in
business practices,
changes in regulations or
routine annual updates as
required by the securities
regulators. This complete
Disclosure Brochure or a
summary of material
changes shall be provided
to each Client annually, or
more often when required
by regulations.
Item 11: Code of Ethics, Participation
or Interest in Client Transactions
and Personal Trading ....................... 8
The Advisor encourages
you to read this Disclosure
Brochure and discuss any
questions you may have
with the Advisor.
Item 12: Brokerage Practices ........... 8
Material Changes
Item 13: Review of Accounts ............. 9
Item 14: Client Referrals and Other
Compensation .................................... 9
At any time, you may view
the current Disclosure
Brochure online at the
SEC’s Investment Adviser
Public Disclosure website:
www.adviserinfo.sec.gov
by searching with The
Advisor’s firm name or
CRD# 163994.
Item 15: Custody ................................ 10
Item 16: Investment Discretion ...... 11
The following material
changes have been made
to this Disclosure Brochure
since the last annual
amendment filing on
March 21, 2025:
Item 17: Voting Client Securities .... 11
Item 18: Financial Information ...... 11
Brochure Supplement ..................... 12
The SEC’s website also
provides information
about any persons
affiliated with us who are
registered as investment
advisor representatives of
PIAR.
The Advisor has changed
its State of incorporation
to Nevada and now
operates under the name
PIAR LLC.
The Advisor has updated
its primary office address
to 5931 Flowering Hill
Court, Las Vegas, NV
89131.
CRD Number 163994
You may also request a
copy of this Disclosure
Brochure by contacting us
at 978.273.9747. The
Advisor will provide you
with the most recent
brochure at any time
without charge.
The Advisor has amended
its billing cadence for
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Item 4: Advisory Business
either a Client or prospective client of
PIAR. We use the terms "we", “us”,
"our" and “Advisor” throughout this
Disclosure Brochure to refer to PIAR
LLC. Also, you may see the term
“Advisory Persons” throughout this
brochure. Our Advisory Persons are
our firm's officers, employees, and all
individuals providing investment
advice on behalf of our firm. The use
of these terms is not intended to
imply that there is more than one
individual associated with the Advisor.
Portfolio Management
PIAR LLC (“PIAR” or the “Advisor”) is
a registered investment advisor with
the U.S. Securities and Exchange
Commission (“SEC”) based in Las
Vegas, NV. We are organized as a
limited liability company under the
laws of the State of Nevada. We were
founded in April of 2012 by Prakash D.
Simha, sole owner and executive
officer. Our registration as an
investment advisor was subsequently
approved by the Commonwealth of
Massachusetts Securities Division on
July 27, 2012. Our firm has since
transitioned to registration with the
SEC, which was approved by the SEC
on April 25, 2024.
The Advisor serves as a fiduciary to
Clients, as defined under the
applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty
of loyalty, fairness and good faith
towards each Client and seeks to
mitigate potential conflicts of interest.
Our fiduciary commitment is further
described in our Code of Ethics. For
more information regarding our Code
of Ethics, please see Item 11 – Code
of Ethics, Participation or Interest in
Client Transactions and Personal
Trading.
As of December 31, 2024, we had
$130,308,345 in Client assets, of
which are managed on a discretionary
basis. You may request more current
information at any time by contacting
the Advisor.
PIAR provides customized investment
advisory solutions for its Clients. This
is achieved through continuous
personal Client contact and interaction
while providing investment
management and consulting services.
We work with you to identify your
investment goals and objectives, as
well as risk tolerance and financial
situation, in order to create a portfolio
strategy. We then construct a
portfolio, consisting of individual
equity securities, mutual funds and/or
exchange-traded funds (“ETFs”) to
implement the allocation. We may
also utilize corporate bonds, options,
limited partnerships, and other
securities where appropriate. We may
advise upon other types of
investments, as necessary, to meet
the unique needs of certain Clients.
We may retain other types of
investments from the Client’s legacy
portfolio due to fit with the overall
portfolio strategy, tax-related reasons,
or other reasons as identified between
the us and the Client.
PIAR provides comprehensive
investment advisory services.
The following paragraphs describe our
services and fees. As used in this
Disclosure Brochure, the words "you",
"your" and "Client" refer to you as
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portfolio,
§ specific positions to increase sector
or asset class weightings,
§ employing cash positions as a
possible hedge against market
movement,
Typically, for liquid assets like stocks,
bonds, mutual funds and ETFs, we
would discuss and research various
individual securities using but not
limited to, The Wall Street Journal,
S&P 500 reports, Investor’s Business
Daily, Morningstar Database and
arrive at a mutually agreed decision to
invest in specific security(s).
§ selling positions for reasons that
include, but are not limited to:
ú harvesting capital gains or
losses,
ú business or sector risk exposure
to a specific security or class of
securities,
ú overvaluation or overweighting
of the position[s] in the
portfolio,
ú change in risk tolerance of
Client,
ú generating cash to meet Client
needs, or
For other investments like limited
partnerships and other illiquid
investments, fees may be charged on
an hourly basis. Typically, these
engagements are based on the length
of time spent discussing the product
with the Client, investment due
diligence, communication with other
professionals of the Client such as
CPAs and attorneys, research and
servicing the Clients - post
investment.
ú any risk deemed unacceptable
for the Client’s risk tolerance.
You may place reasonable restrictions
on the strategies to be employed in
your portfolio and the types of
investments to be held in your
portfolio.
PIAR does not manage or place Client
assets into a wrap fee program.
Investment management services are
provided directly by PIAR.
Your engagement begins with a
review of your investment goals,
financial situation, time horizon,
tolerance for risk and other factors to
develop an appropriate strategy for
managing your account. Your
participation in this process, including
full and accurate disclosure of
requested information, is essential for
the analysis of your situation. PIAR
shall rely on the financial and other
information you or your designees
provide without the duty or obligation
to validate the accuracy or
completeness of the provided
information. It is your responsibility to
inform us of any changes in financial
condition, goals or other factors that
may affect our analysis.
PIAR may recommend, on occasion:
§ redistributing investment
allocations to diversify your
Retirement Accounts- When the
Advisor provides investment advice to
Clients regarding ERISA retirement
accounts or individual retirement
accounts (“IRAs”), the Advisor is a
fiduciary within the meaning of Title I
of the Employee Retirement Income
Security Act (“ERISA”) and/or the
Internal Revenue Code (“IRC”), as
applicable, which are laws governing
retirement accounts. When deemed to
be in the Client’s best interest, the
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recommendations may be made that
you start or revise your investment
programs, commence or alter
retirement savings, establish
education savings and/or charitable
giving programs. We may also refer
you to an accountant, attorney or
another specialist, as appropriate for
your unique situation.
Advisor will provide investment advice
to a Client regarding a distribution
from an ERISA retirement account or
to roll over the assets to an IRA, or
recommend a similar transaction
including rollovers from one ERISA
sponsored Plan to another, one IRA to
another IRA, or from one type of
account to another account (e.g.
commission-based account to fee-
based account). Such a
recommendation creates a conflict of
interest if the Advisor will earn a new
(or increase its current) advisory fee
as a result of the transaction. No
client is under any obligation to roll
over a retirement account to an
account managed by the Advisor.
Consulting Services
Financial consulting recommendations
may pose a potential conflict of
interests, as implementation through
our firm may result in increased
revenues for us. You are not obligated
to implement any recommendations
we make or maintain an ongoing
relationship with us. If you elect to act
on any of the recommendations made
by PIAR, you are under no obligation
to do so through us.
Item 5: Fees and Compensation
Portfolio Management Fees
investment planning,
PIAR will typically provide a variety of
financial consulting services to
individuals and families, pursuant to a
written agreement. Generally, we will
provide you with financial advice
based on your financial goals,
objectives and situation. These
consulting services may encompass
one or more areas of need, including,
but not limited to:
§
§ evaluation of illiquid assets such as
limited partnerships or limited
offerings,
Investment advisory fees are paid
monthly, at the end of each calendar
month, pursuant to the terms of a
written agreement. The investment
advisory fee is based on the market
value of your assets under our
management at the end of each
month. Generally, investment
advisory fees are charged at a rate
between 1.00% and 2.00% annually
(billed monthly) according to the
following schedule:
§ retirement planning,
§ personal savings,
insurance needs
§
§ education savings, or
§ areas of your financial situation
specified by you.
A financial consultation usually
includes general recommendations for
a course of activity or specific actions
for you to take. For example,
0-1 Million – 2.0%
1-2 Million – 1.8%
2-3 Million – 1.6%
3-4 Million – 1.4 %
4+ Million – 1.0%
3 | P a g e
investment advisory fee. It is your
responsibility to verify the accuracy of
these fees, as the Custodian does not
assume this responsibility.
Either party may terminate the
investment advisory agreement, at
any time, by providing written notice
to the other party. In addition, you
may terminate the investment
advisory agreement within five (5)
business days of signing the Advisor’s
agreement at no cost to the Client.
After the five-day period, you are
responsible for the payment of fees up
to and including the effective date of
termination. Upon termination, we will
refund any unearned, prepaid fees on
a pro rata basis. Your investment
advisory agreement with us is non-
transferable without your prior
consent.
The investment advisory fee in the
first month of service is prorated from
the inception date of the account[s] to
the end of the first month. The fee for
the first month may be waived
completely or delayed until the invoice
of the first full month of service. Fees
are negotiable at our sole discretion
for some extenuating circumstances
like death of a breadwinner of the
family, disability, divorce or any such
circumstances that may lead to
financial distress. Your fees take into
consideration the aggregate assets
under management and advisement
with us, the complexity of your
financial situation, and the range of
services provided. All securities held in
accounts managed by PIAR will be
independently valued by the
Custodian. We will conduct periodic
reviews of the Custodian’s valuation to
ensure accurate billing.
Consulting Services Fees
PIAR offers consulting services on an
hourly basis at the rate of $250, which
may be negotiable, at the sole
discretion of the Advisor, depending
on the nature and complexity of each
Client’s circumstances. An estimate of
total hours will be determined prior to
establishing the advisory relationship.
Consulting service fees are invoiced
by the Advisor and are due upon
receipt of the agreed upon
deliverable[s].
You must provide written
authorization permitting PIAR to be
paid directly from your accounts held
by your Custodian as part of our
agreement and separate account
forms provided by your Custodian.
You may specify the account from
which you wish to have your advisory
fees withdrawn. We shall send an
invoice to your Custodian indicating
the amount of the fees to be deducted
from your account at the respective
month-end date. The amount due is
calculated by applying the monthly
rate (annual rate divided by 12) to the
total assets under management and
advisement with PIAR at the end of
each month.
You are provided with a statement, at
least quarterly, from the Custodian
reflecting the deduction of the
Either party may terminate a
consulting agreement, at any time, by
providing written notice to the other
party. In addition, you may terminate
the agreement within five (5) business
days of signing the agreement without
penalty. After the five-day period, you
will incur charges for bona fide
4 | P a g e
other fund expenses, account
administration (e.g. custody,
brokerage and account reporting), and
a possible distribution fee.
advisory services rendered to the
point of termination and such fees will
be due and payable. Refunds will be
given on a pro-rata basis. Your
consulting agreement with us is non-
transferable without your prior
consent.
Other Potential Fees
You could invest in these products
directly, but would not receive the
services provided by PIAR. These
services are designed, among other
things, to assist you in determining
which products or services are most
appropriate to your financial situation
and objectives.
In addition to our fees, you may be
required to pay other charges such
as:
§ custody fees,
§ brokerage commissions,
§
§
transaction fees,
internal fees and expenses charged
by mutual funds or exchange
traded funds (“ETFs”), and
§ other fees and taxes on brokerage
To fully understand the total cost you
will incur, you should review all the
fees charged by mutual funds,
exchange traded funds, our firm, and
others. For information on our
brokerage practices, please refer to
Item 12: Brokerage Practices.
accounts and securities
transactions.
Item 6: Performance-Based Fees
and Side-by-Side Management
None of these fees are paid to or are
shared with us.
We do not charge performance-based
fees (fees that are based on a share
of capital gains or capital appreciation
of a Client's account[s]). Side-by-side
management refers to the practice of
managing accounts that are charged
performance-based fees while at the
same time managing accounts that
are not charged performance-based
fees. We do not accept performance-
based fees or participate in side-by-
side management. Our fees are
calculated as described in Item 5:
Fees and Compensation section
above, and are not charged on the
basis of a share of capital gains upon,
or capital appreciation of, the funds in
your advisory account.
As part of our investment advisory
services to you, we may invest, or
recommend that you invest, in mutual
funds and exchange traded funds. Our
recommended Custodian does not
charge securities transaction fees for
ETF and equity trades in Client
account, provided that the account
meets the terms and conditions of the
Custodian’s brokerage requirements.
However, the Custodian typically
charges for mutual funds and other
types of investments. The fees that
you pay to our firm for investment
advisory services are separate and
distinct from the fees and expenses
charged by mutual funds and ETFs (as
described in each fund's prospectus)
to their shareholders. These fees will
generally include a management fee,
5 | P a g e
Item 7: Types of Clients
more than a year, but may hold for
shorter periods for the purpose of
rebalancing a portfolio or meeting
your cash needs. At times, PIAR may
also buy and sell positions that are
more short-term in nature, depending
on your goals and the fundamentals of
the security, sector or asset class.
We offer our advisory services
primarily to individuals, high net
worth individuals, trusts, estates and
defined contribution plans. PIAR
generally does not impose a minimum
size for establishing a relationship.
Item 8: Methods of Analysis,
Investment Strategies and Risk of
Loss
§
Funds are continuously monitored and
can be recommended for removal
from accounts for a number of
reasons. Reasons for elimination may
include:
§ underperformance of the manager
versus peers or expectations,
identification of lower internal
costs,
§ an increase in volatility of a
manager's returns,
§ an unwanted change or drift in
strategy, or
§ a change in management.
Our research and analysis is derived
from numerous sources, including
financial media companies, third-party
research materials, internet sources,
and review of company activities,
including annual reports,
prospectuses, press releases and
research prepared by others. We
primarily employ fundamental analysis
methods in developing investment
strategies for you.
PIAR may employ options strategies
to hedge or gain additional exposure
to a particular asset class or sector.
Our investment strategy may
encompass active trading in
concentrated portfolios.
You may place reasonable restrictions
on the strategies to be employed in
your portfolio and the types of
investments to be held in your
portfolio.
Fundamental analysis is a method of
evaluating a company that has issued
securities by attempting to measure
the value of its underlying assets. This
entails studying overall economic and
industry conditions as well as the
financial condition and the quality of
the company’s management.
Earnings, expenses, assets, and
liabilities are all important in
determining the value of a company.
The value is then compared to the
current price of the company’s
securities to determine whether to
purchase, sell or hold those securities.
PIAR generally employs long-term
investment strategies, as consistent
with your financial goals. We typically
hold all or a portion of a security for
The use of options are higher risk
strategies. Investments in options
contracts have the risk of losing value
in a relatively short period of time.
Option contracts are leveraged
instruments that allow the holder of a
single contract to control many shares
of an underlying stock. This leverage
can compound gains or losses.
6 | P a g e
Options can also expire worthless.
Item 9: Disciplinary Information
Securities laws require an advisor to
disclose any instances where the
Advisor or its Advisory Persons have
been found liable in a legal,
regulatory, civil or arbitration matter
that alleges violation of securities and
other statutes; fraud; false
statements or omissions; theft,
embezzlement or wrongful taking of
property; bribery, forgery,
counterfeiting, or extortion; and/or
dishonest, unfair or unethical
practices.
ETF Risks
The performance of ETFs is subject to
market risk, including the possible
loss of principal. The price of the ETFs
will fluctuate with the price of the
underlying securities that make up the
funds. In addition, ETFs have a
trading risk based on the loss of cost
efficiency if the ETFs are traded
actively and a liquidity risk if the ETFs
have a large bid-ask spread and low
trading volume. The price of an ETF
fluctuates based upon the market
movements and may dissociate from
the index being tracked by the ETF or
the price of the underlying
investments. An ETF purchased or
sold at one point in the day may have
a different price than the same ETF
purchased or sold a short time later.
You may independently view the
background of the Advisor on the
Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov
by searching with the firm name or
the Advisor’s CRD# 163994.
Item 10: Other Financial Industry
Activities and Affiliations
PIAR and our Advisory Persons do not
have any affiliations with other firms,
other than contracted service
providers, to assist with the servicing
of Client accounts.
Mutual Fund Risks
The performance of mutual funds is
subject to market risk, including the
possible loss of principal. The price of
the mutual funds will fluctuate with
the value of the underlying securities
that make up the funds. The price of a
mutual fund is typically set daily
therefore a mutual fund purchased at
one point in the day will typically have
the same price as a mutual fund
purchased later that same day.
PIAR does not utilize a third-party
money manager.
Options Contracts
Investments in options contracts have
the risk of losing value in a relatively
short period of time. Option contracts
are leveraged instruments that allow
the holder of a single contract to
control many shares of an underlying
stock. This leverage can compound
gains or losses.
7 | P a g e
receive. To eliminate this conflict of
interest, it is our policy that Advisory
Persons shall not have priority over
your account in the purchase or sale
of securities.
Item 11: Code of Ethics,
Participation or Interest in Client
Transactions and Personal
Trading
Description of Our Code of Ethics
PIAR allows our Supervised Persons to
purchase or sell the same securities
that may be recommended to and
purchased on behalf of Clients. PIAR
does not act as principal in any
transactions. In addition, the Advisor
does not act as the general partner of
a fund, or advise an investment
company. PIAR does not have a
material interest in any securities
traded in Client accounts.
Item 12: Brokerage Practices
PIAR requires you to select the
broker-dealer/custodian (herein the
"Custodian") to safeguard your assets.
You must authorize us to direct trades
to the Custodian as provided by our
written agreement. Not all advisors
require their Clients to direct
brokerage trades. When you direct
brokerage, we do not have an
obligation to seek and may be unable
to achieve the most favorable
execution for your transactions. Thus,
the transactions may cost you more
than if the brokerage were not
directed.
We strive to comply with applicable
laws and regulations governing our
practices. Therefore, our Code of
Ethics (“Code”) includes guidelines for
professional standards of conduct for
our Advisory Persons. Our goal is to
protect your interests at all times and
to demonstrate our commitment to
our fiduciary duties of honesty, good
faith, and fair dealing with you. All of
our Advisory Persons are expected to
adhere strictly to these guidelines.
Persons associated with our firm are
also required to report any violations
of our Code. Additionally, we maintain
and enforce written policies
reasonably designed to prevent the
misuse or dissemination of material,
non-public information about you or
your account holdings by persons
associated with our firm. We will
provide a copy of our Code Ethics to
you or any prospective Client upon
request.
Personal Trading Practices
PIAR will generally recommend that
Clients establish their account[s] at
Charles Schwab & Co., Inc.
(“Schwab”), a FINRA-registered
broker-dealer and member SIPC.
Schwab will serve as the Client’s
“qualified custodian”. PIAR maintains
an institutional relationship with
Schwab, whereby the Advisor receives
economic benefits from Schwab.
Our firm or its Advisory Persons may
buy or sell the same securities that we
recommend to you or securities in
which you are already invested. A
conflict of interest exists in such cases
because we have the ability to trade
ahead of you and potentially receive
more favorable prices than you will
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Item 14: Client Referrals and Other
Compensation
Please see Item 14 below. Clients are
not obligated to use the recommended
Custodian and will not incur any extra
fee or cost from us associated with
using a custodian not recommended
by PIAR.
We do not directly or indirectly
compensate any person who is not
one of our Advisory Persons for Client
referrals.
Item 13: Review of Accounts
Participation in Institutional Advisor
Platform
Securities in Client accounts are
monitored on a regular and
continuous basis by Mr. Simha,
President of PIAR. The Advisor also
monitors Client financial plans on a
regular and continuous basis. Formal
reviews are generally conducted at
least annually depending on the needs
of the Client.
We recommend changes or alternate
investments or opportunities when we
believe it is appropriate to do so.
General conditions in the stock and
bond markets are continuously
monitored. Factors triggering reviews,
and perhaps triggering buy or sell
recommendations, include a change of
your personal or financial
circumstances, changes in general
conditions in the stock and bond
markets, material changes in the
economic or political climate, and
changes in the individual investments
you own.
PIAR has established an institutional
relationship with Schwab through its
“Schwab Advisor Services” unit, a
division of Schwab dedicated to
serving independent advisory firms
like PIAR. As a registered investment
advisor participating on the Schwab
Advisor Services platform, PIAR
receives access to software and
related support without cost because
the Advisor renders investment
management services to Clients that
maintain assets at Schwab. Services
provided by Schwab Advisor Services
benefit the Advisor and many, but not
all services provided by Schwab will
benefit Clients. In fulfilling its duties
to its Clients, the Advisor endeavors
at all times to put the interests of its
Clients first. Clients should be aware,
however, that the receipt of economic
benefits from a custodian creates a
potential conflict of interest since
these benefits may influence the
Advisor's recommendation of this
custodian over one that does not
furnish similar software, systems
support, or services.
Clients receive custodial statements
no less than quarterly directly from
the Custodian. You may also establish
electronic access to the Custodian’s
website so that you may view these
reports and their account activity
online. These custodial statements
include all positions, transactions and
fees relating to your account[s].
Services that Benefit the Client –
Schwab’s institutional brokerage
services include access to a broad
range of investment products,
execution of securities transactions,
and custody of Client’s funds and
9 | P a g e
securities. Through Schwab, the
Advisor may be able to access certain
investments and asset classes that
the Client would not be able to obtain
directly or through other sources.
Further, the Advisor may be able to
invest in certain mutual funds and
other investments without having to
adhere to investment minimums that
might be required if the Client were to
directly access the investments.
investigate various securities we may
recommend to you. This creates a
conflict of interest as it may incent us
to recommend investments where the
sponsor pays for such trips over those
who do not. Our recommendation of a
particular product may be based in
part on the economic benefit to us
and not solely on the nature, cost or
quality of the investment provided to
you and our other Clients. We
nonetheless strive to act in your best
interests at all times. We keep records
of our due diligence and investment
analyses, recommending only those
investments we believe meet your
individual needs.
Item 15: Custody
PIAR does not accept or maintain
custody of Client accounts, except for
the limited circumstances outlined
below:
Services that May Indirectly Benefit
the Client – Schwab provides
participating advisors with access to
technology, research, discounts and
other services. In addition, the
Advisor receives duplicate statements
for Client accounts, the ability to
deduct advisory fees, trading tools,
and back office support services as
part of its relationship with Schwab.
These services are intended to assist
the Advisor in effectively managing
accounts for its Clients, but may not
directly benefit all Clients.
Deduction of Advisory Fees - To
ensure compliance with regulatory
requirements associated with the
deduction of advisory fees, all Clients
for whom PIAR exercises discretionary
authority must hold their assets with a
"qualified custodian." Clients are
responsible for engaging a “qualified
custodian” to safeguard their funds
and securities and must instruct PIAR
to utilize that Custodian for securities
transactions on their behalf. Clients
are encouraged to review statements
provided by the Custodian and
compare to any reports provided by
PIAR to ensure accuracy, as the
Custodian does not perform this
review.
Services that May Only Benefit the
Advisor – Schwab also offers other
services and financial support to PIAR
that may not benefit the Client,
including: educational conferences
and events, financial start-up support,
consulting services and discounts for
various service providers. Access to
these services creates a financial
incentive for the Advisor to
recommend Schwab, which results in
a potential conflict of interest. PIAR
believes, however, that the selection
of Schwab as Custodian is in the best
interests of its Clients.
In addition, we may receive
reimbursement from product sponsors
for all or a portion of travel expenses
incurred during due diligence trips to
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Item 16: Investment Discretion
proxies, however, you retain the sole
responsibility for proxy decisions and
voting. We are expressly precluded
from voting proxies on behalf of
ERISA accounts. In addition, we do
not take any action with respect to
securities that are named in, or
subject to, class action lawsuits. You
should receive your proxies or other
solicitations directly from your
custodian or a transfer agent.
Item 18: Financial Information
PIAR may have discretion over the
selection and amount of securities to
be bought or sold in Client accounts
without obtaining prior consent or
approval from the Client. However,
these purchases or sales may be
subject to specified investment
objectives, guidelines, or limitations
previously set forth by the Client and
agreed to by PIAR. Discretionary
authority will only be authorized upon
full disclosure to the Client. The
granting of such authority will be
evidenced by the Client's execution of
an investment advisory agreement
containing all applicable limitations to
such authority. All discretionary trades
made by PIAR will be in accordance
with each Client's investment
objectives and goals.
Neither PIAR nor its Advisory Persons,
have any adverse financial situations
that would reasonably impair the
ability of PIAR to meet all obligations
to its Clients. Neither PIAR nor its
Advisory Persons, have been subject
to a bankruptcy or financial
compromise.
Item 17: Voting Client Securities
PIAR is not required to deliver a
balance sheet along with this
Disclosure Brochure as the Advisor
does not collect advance fees of
$1,200 or more for services to be
performed six months or more in the
future.
We will not vote proxies on behalf of
your advisory accounts. If you own
shares of common stock or mutual
funds, you are responsible for
exercising your right to vote as a
shareholder. We may assist you by
answering questions relating to
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Item 1: Cover Sheet
PIAR LLC
Prakash D. Simha
2 Yardley Road
Andover, MA 01810
978.273.9747
Brochure Supplement
July 11, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about Prakash D.
Simha that supplements the Disclosure Brochure for PIAR LLC. (CRD# 163994) You
should have received a copy of that Disclosure Brochure. Please contact Prakash Simha,
President & Chief Compliance Officer, if you did not receive our Disclosure Brochure or if
you have any questions about the contents of this supplement.
Additional information about Prakash D. Simha is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2970036.
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Item 2: Educational Background and Business Experience
Prakash D. Simha
CRD# 2970036
Year of birth: 1955
Formal education:
§ Madurai Kamaraj University, PhD - 1988
§ Madurai Kamaraj University, MS in Molecular Biology - 1982
§ Bengaluru University, BS - 1978
Business background:
§ PIAR LLC, President & Chief Compliance Officer,
07/2012 - Present
§ The Strategic Financial Alliance, Inc., Investment Adviser Representative &
Registered Representative,
12/2009 – 09/2012
§ Golden Lotus Financials,
§
Representative
02/2003 - 07/2012
Investors Capital Corp.,
Registered Representative,
02/2003 – 12/2009
§ MetLife Securities, Inc.,
Registered Representative,
10/1997 – 02/2003
§ Metropolitan Life Insurance Co.,
Insurance Agent,
10/1997 – 02/2003
Item 3: Disciplinary Information
There are no legal or civil events to disclose regarding Mr. Simha. He has never
been involved in any civil or criminal action. There have been no lawsuits,
arbitration claims, or related proceedings against Mr. Simha.
We encourage you to independently view the background of Mr. Simha on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by
searching with his full name and his Individual CRD# 2970036.
Item 4: Other Business Activities
Mr. Simha is dedicated to the Investment Advisory activities of PIAR’s clients.
Mr. Simha does not have any other business activities.
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Item 5: Additional Compensation
Mr. Simha is dedicated to the investment advisory activities of PIAR. Mr. Simha
does not receive any additional forms of compensation.
Item 6: Supervision
As President and Chief Compliance Officer of PIAR, Mr. Simha is not supervised
by other persons in our firm. However, PIAR has written supervisory procedures
in place that are reasonably designed to detect and prevent violations of the
securities laws, rules, and regulations. Mr. Simha is also required to adhere to
the processes and procedures described in our Code of Ethics. Mr. Simha can be
reached at (978) 273-9747.
Furthermore, PIAR is subject to regulatory oversight by various agencies. These
agencies require registration by PIAR and its employees. As a registered entity,
PIAR is subject to examinations by regulators, which may be announced or
unannounced. PIAR is required to periodically update the information provided
to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
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Privacy Policy
Effective: March 25, 2025
Our Commitment to You
PIAR LLC (“PIAR” or the “Advisor”) is committed to safeguarding the use of personal
information of our Client’s (also referred to as “you” and “your”) that we obtain as your
Investment Advisor, as described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have
entrusted us with your private information, and we do everything that we can to maintain
that trust. PIAR (also referred to as "we", "our" and "us”) protects the security and
confidentiality of the personal information we have and implements controls to ensure that
such information is used for proper business purposes in connection with the management
or servicing of our relationship with you.
PIAR does not sell your non-public personal information to anyone. Nor do we provide such
information to others except for discrete and reasonable business purposes in connection
with the servicing and management of our relationship with you, as discussed below. Details
of our approach to privacy and how your personal non-public information is collected and
used are set forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in
the course of servicing your account. Federal and State laws give you the right to limit some
of this sharing and require RIAs to disclose how we collect, share, and protect your personal
information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number
Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Account applications and forms
Custody, brokerage and advisory
agreements
Other advisory agreements and legal
documents
Investment questionnaires and suitability
documents
Transactional information with us or others Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain
physical, procedural and electronic security measures. These include such safeguards as
secure passwords, encrypted file storage and a secure office environment. Our technology
vendors provide security and access control over personal information and have policies
over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal
information they receive from us.
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How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the
section below, we list some reasons we may share your personal information.
Basis For Sharing
Can you limit?
Do we
share?
Yes
No
No
Not Shared
Yes
Yes
Servicing our Clients
We may share non-public personal information with non-affiliated
third parties (such as administrators, brokers, custodians, regulators,
credit agencies, other financial institutions) as necessary for us to
provide agreed upon services to you, consistent with applicable law,
including but not limited to: processing transactions; general account
maintenance; responding to regulators or legal investigations; and
credit reporting.
Marketing Purposes
PIAR does not disclose and does not intend to disclose, personal
information with non-affiliated third parties to offer you services.
Certain laws may give us the right to share your personal information
with financial institutions where you are a customer and where PIAR
or the Client has a formal agreement with the financial institution.
We will only share information for purposes of servicing your
accounts, not for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients
PIAR does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to
persons who are no longer our Clients.
State-specific Regulations
Massachusetts
In response to Massachusetts law, the Client must “opt-in” to share non-public
personal information with non-affiliated third parties before any personal information
is disclosed. Client opt-in is obtained through the Client’s execution of authorization
forms provided by the third parties, by executing an Information Sharing
Authorization Form, or by other written consent by the Client, as appropriate and
consistent with applicable laws and regulations.
California
In response to a California law, to be conservative, we assume accounts with
California addresses do not want us to disclose personal information about you to
non-affiliated third parties, except as permitted by California law. We also limit the
sharing of personal information about you with our affiliates to ensure compliance
with California privacy laws.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing
relationship with us.
Periodically we may revise this Policy, and will provide you with a revised policy if the
changes materially alter the previous Privacy Policy. We will not, however, revise our
Privacy Policy to permit the sharing of non-public personal information other than as
described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current
Privacy Policy by contacting us at (978) 273-9747.
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