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)

MinMaxMarginal 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 AssetsAnnual FeesAverage 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 i | P a g e 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 1 | P a g e 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 2 | P a g e 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 8 | P a g e 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 10 | P a g e 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 11 | P a g e 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. 12 | P a g e 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. 13 | P a g e 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. 14 | P a g e 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. 15 | P a g e 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. 16 | P a g e