Firm Description Park Avenue Investment Advisory, LLC, doing business under the marketing name Park Avenue Investment Advisory or PAA, is a registered investment adviser offering investment advisory services and fee-based financial planning through investment adviser representatives (“IARs”). Park Avenue Investment Advisory has been registered with the SEC since October 15, 2020. Additional information about Park Avenue Investment Advisory is available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information about persons who are registered as IARs of Park Avenue Investment Advisory. Principal Owners Park Avenue Investment Advisory is an indirect wholly owned subsidiary of The Guardian Life Insurance Company of America (“GLIC”), a New York mutual life insurance company, and directly owned by Guardian Investor Services LLC, a wholly owned subsidiary of GLIC. Types of Advisory Services Offered Park Avenue Investment Advisory offers a variety of investment advisory programs and services to retail investors through our IARs. Based on your financial needs and objectives, an IAR will advise you on the management of investments which are comprised of wrap fee managed account portfolios (the “Programs”), such as the representative as portfolio manager program, a separately managed account program and a unified managed account program. Under a wrap fee program, you pay a single asset-based fee for investment advisory services and execution of your transactions. Additional services offered include financial planning and consulting, estate planning and retirement plan services. Understanding your Relationship with Park Avenue Investment Advisory Park Avenue Investment Advisory is subject to the Investment Advisers Act of 1940 (“the Advisers Act”), and as a registered investment adviser Park Avenue Investment Advisory and its IARs have a fiduciary duty to you. This generally means that Park Avenue Investment Advisory and its IARs will act in your best interest when providing investment advice under the Advisers Act and will disclose, mitigate, or avoid material conflicts of interest. Throughout the various sections of this Brochure PAA has identified material conflicts of interest where you see such language bolded or within specific sections identified as discussing material conflict of interest. In providing investment advice, your IAR will select from the various products and programs offered. This includes advice and recommendations to invest in various managed account portfolios that may be comprised of products such as load-waived and no-load mutual funds, exchange-traded funds (“ETFs”), closed-end funds, options, stocks and bonds as well as separately managed accounts and other securities products approved for use on the Park Avenue Investment Advisory platform. Fidelity Brokerage Services LLC and National Financial Services LLC, (together “Fidelity”), Pershing Advisor Solutions LLC (“Pershing”) and Schwab Advisor Services, a division of Charles Schwab & Co., Inc. (“Schwab”) are approved to act as custodian of the securities held in your account. To enroll in one of the Park Avenue Investment Advisory Programs, you must establish an account through Park Avenue Investment Advisory with one of the approved custodians. All trading activity under the Park Avenue Investment Advisory Programs will be processed through the custodian you have selected. Custodial firms perform custody, bookkeeping and trade execution functions. 5 5/2024 Rollovers and Fiduciary Acknowledgement When Park Avenue Investment Advisory and its IARs recommend to a) participants in ERISA-covered retirement plans to roll over assets into an IRA or b) owners of IRAs to roll over or transfer assets to another IRA, Park Avenue Investment Advisory and its IARs are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act of 1974 and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Fiduciary status for this purpose does not necessarily mean Park Avenue Investment Advisory and its IARs are acting as fiduciaries for purposes of other applicable laws. This acknowledgement of fiduciary status does not confer contractual rights or obligations on you, Park Avenue Investment Advisory, or the IARs. With respect to rollover transactions, certain portions of this Firm Brochure disclosure are intended to comply with requirements under the U.S. Department of Labor’s Prohibited Transaction Exemption 2020-02, specifically; (i) information regarding the scope of services provided by Park Avenue Investment Advisory and its IARs, (ii) the fiduciary acknowledgement above, and (iii) the description of the material conflicts of interest under which Park Avenue Investment Advisory and your IARs are operating. Rollovers Park Avenue Investment Advisory and your IAR get paid when you engage in a rollover transaction. Park Avenue Investment Advisory can recommend that you rollover assets from your workplace retirement plan or from an existing IRA into an IRA account with Park Avenue Investment Advisory. When you engage in a rollover to an IRA, Park Avenue Investment Advisory and your IAR will receive compensation in connection with the investments you will acquire for your IRA account and hold in the account. This compensation incentivizes Park Avenue Investment Advisory and your IAR to make a rollover recommendation. Transferring an Existing Account to Park Avenue Investment Advisory Programs There may be instances in which you have chosen to open a Park Avenue Investment Advisory account that requires you to liquidate existing investment assets or accounts and transfer the proceeds to the Park Avenue Investment Advisory Program in which you wish to participate. In liquidating assets and transferring proceeds, you may experience costs. These costs can include, but are not limited to, account termination charges, contingent deferred sales charges, surrender charges, and commissions on the sale of stocks, bonds, exchange traded funds, closed end mutual funds, limited partnership shares or any other securities you hold in these accounts. If you redeem, surrender or sell existing assets to fund an account you should carefully consider the costs and benefits of the transactions including any tax liability. You should also ask your IAR if the sale of the assets used to fund your account will benefit your IAR and take that into consideration before liquidating assets to fund your account. The liquidation of an investment may trigger losses or taxable gains, or the Alternative Minimum Tax (AMT) and may require additional quarterly estimated tax payments. Neither Park Avenue Investment Advisory nor your IAR provide tax advice or tax management services. You are responsible for any taxable consequences. You should always consult with your tax advisor for specific tax advice. Tailored Client Relationships For Park Avenue Investment Advisory Programs, your IAR will request information from you regarding your financial background, investment experience, investment objectives, risk tolerance, and any reasonable restrictions that you wish to impose on investing in certain specific securities and types of securities and will provide important disclosures to you. Your IAR will work with you to help you determine your investment goals and will assist you in selecting the appropriate Programs or other services. As your goals and objectives change over time, your IAR will update your records and client file and may provide new recommendations and advice to fit your needs. You should notify your IAR promptly if there are any changes in your financial situation, risk tolerance, investment objectives or account restrictions. Your IAR will periodically review 6 5/2024 performance and other reports provided to you and will offer to meet with you at least annually to review your financial situation and investment objectives. Investment Program Agreement If you select a Park Avenue Investment Advisory Program, you will sign an Investment Program Agreement. The Investment Program Agreement will detail all the important information pertaining to your account and you are encouraged to read all the terms of the Investment Program Agreement. Financial Planning and Consulting Park Avenue Investment Advisory IARs may offer financial planning and consulting services. These services may be included by your IAR as part of the holistic wealth management advice provided, which shall include investment management via the Programs as well as integrated financial planning or consulting at the IAR’s discretion or if requested by Client. Alternatively, financial planning and consulting services may be provided as a standalone service for a separate fee. The IAR may negotiate a fee based upon the overall experience of the IAR, a client’s financial needs and investment objectives, the time necessary to develop a plan and the complexity of a plan. If you engage an IAR for standalone financial planning or consulting services, at the beginning of the relationship your IAR will provide you with a Financial Planning and Consulting Agreement, which will detail all of the important terms and conditions pertaining to the financial plan or consultation, including the fee. Fee-based financial planning is a service that considers many different aspects of your financial circumstances, typically by utilizing a financial planning software program to create an overall plan that is designed to meet your goals and objectives. Financial consulting is an open architecture process that requires your IAR to collect information from you and develop customized recommendations that are delivered to you within the parameters of an agreed upon scope of consulting services. The financial planning and consulting services provide for ongoing consultation with your IAR, typically through a series of personal meetings and telephone calls. The services provided may include follow-up meetings with you and your other advisors (e.g., attorneys, accountants, etc.). Depending on your needs and pursuant to the agreement with your IAR, your formal written financial plan or consultation recommendations may cover:  General Financial Planning  Goal Planning (e.g., Education Planning)  Retirement Planning  Risk Management  Cash Flow Planning  Wealth Transfer Planning  Business Succession and Exit Planning  Business Planning  Corporate Retirement Planning  Investment Analysis  Insurance Planning Your written financial plan or consultation will consist of observations, assumptions, strategies and recommendations. You will have the opportunity to renew the agreement and update your plan at least annually, or as your circumstances change. You may choose to implement all or any part of the financial plan or consultation recommendations through Park Avenue Investment Advisory, or through a broker- 7 5/2024 dealer, investment adviser or service provider of your choice. Please note if you choose to implement all or part of the financial plan through Park Avenue Investment Advisory or a broker-dealer affiliate of Park Avenue Investment Advisory, your IAR (who may also be a registered representative of a broker-dealer affiliate of Park Avenue Investment Advisory) will receive additional compensation for further investment advisory or brokerage services, through the broker-dealer affiliate. Subscription Based Financial Planning Park Avenue Investment Advisory IARs may also offer on-going financial planning services via Subscription- Based Financial Planning. The subscription arrangement will provide you with the ability to engage your IAR for financial planning services by paying an annual fee on either a monthly or quarterly basis. Your agreement will renew annually unless you choose to terminate the agreement. Your IAR will provide you with analysis, recommendations, and ongoing monitoring based on your current financial situation and goals. On an annual basis you will receive a written summary of the terms of the engagement which will include an outline of your goals, both accomplished and future, a summary of the meetings with your IAR, your fee arrangement, and a reminder of the termination option within the agreement. Listed below is an overview of the services that may be provided through the Subscription-Based Financial Planning Program. Included with the services is access to your IAR throughout the subscription period. A full description of each service can be found within the Subscription-Based Planning Agreement. Core Services:  Initial Consultation, including obtaining and organizing essential documents  Cash Flow and Debt Planning Analysis  Net Worth Statement  Investment Analysis  Risk Analysis Advanced Planning:  Charitable Planning  Wealth Transfer Planning  Goals-based Planning  Education Planning and Funding  Retirement Planning  Tax Planning Strategies  Life Events It is important to note that if your IAR provides investment advice related to any Program accounts, the Subscription Based Financial Planning fee will be in addition to advisory fees associated with those accounts. However, the advice provided within the Subscription Based Financial Planning arrangement cannot solely be comprised of existing Park Avenue Investment Advisory Program accounts. Additionally, if you choose to implement recommendations from your IAR as part of this engagement, the advisory fees associated with the advisory products or services will be in addition to your Subscription Based Financial Planning fee. Business Exit Consulting Certain IARs will analyze the financial situation of your business for the purpose of establishing business exit planning strategies and recommendations. Your IAR will coordinate with your accounting and legal advisors as well as other professionals you deem 8 5/2024 appropriate or that your IAR recommends. These professionals are selected, retained and paid for by you. Any advice provided by these outside professionals is separate and distinct from the advice provided by your IAR and any fees paid to outside professionals are separate and distinct from the fee charged as part of the Business Exit Consulting Agreement. You may choose either a Comprehensive Exit Plan or a Focused Exit Plan. A Comprehensive Exit Plan is a written action plan for accomplishing your objectives with regards to the growth of your business, the preservation and realization of maximum business value, and your ultimate departure from the business within established timelines and terms. In a Focused Exit Plan, you will select your objectives from the following list:  Business Valuation  Incentive Planning  Ownership Transfer Planning  Business Continuity Planning  Personal Wealth Management Planning  Wealth Transfer Planning Once the objectives have been established, the IAR will collect the requisite information to create the focused plan. Please note that a Focused Exit Plan cannot solely be made up of the Personal Wealth Management Planning or Wealth Transfer Planning. Each component is fully described within the Business Exit Consulting Client Agreement which is signed by the client. A separate fee is charged for these services. Retirement Plan Consulting Services (Investment Advisory) Park Avenue Investment Advisory may enter into an agreement with an employer sponsored qualified retirement plan to provide investment advisory services to the plan. Park Avenue Investment Advisory, through its authorized IARs, will assist the named plan fiduciary in determining the investment lineup available to the plan's participants. Only appropriately credentialed IARs specifically approved by Park Avenue Investment Advisory are authorized to provide these services to plan sponsors. A summary of the services is provided below. Plan sponsors should refer to their written agreement with Park Avenue Investment Advisory for more details regarding the specific services to be provided as well as the fees charged. Investment Option Recommendations – The Park Avenue Investment Advisory IAR will analyze the list of available investment options for the qualified plan and provide the plan sponsor with a recommended list of core asset classes that, when combined, constitute an investment lineup for a qualified plan. If requested by the plan sponsor, the IAR may provide definitions of additional asset classes/categories that, when combined with core asset classes, will constitute investment lineups for those plan sponsors seeking more sophisticated levels of complexity. The IAR will identify for the plan sponsor's consideration one or more investment options from each asset class/category that are appropriate for long-term strategic asset allocations and will evaluate the investment options, including comparing their performance to appropriate benchmarks and peer group(s). The IAR will provide the plan sponsor with recommended investment options within each of the core asset class groups, as well as supplemental asset classes/categories if requested by the plan sponsor. The IAR will also provide some general guidelines as to how many and what management type (active or passive) of investment options are appropriate to select with respect to each of the asset class groups to assist the plan sponsor in making its final investment option selections. Monitoring of Investment Options – The IAR reviews investment option performance on at least a quarterly basis. Each investment option will be reviewed, and investment options that do not meet the identified criteria will be placed on a watch list. The placement of an investment option on the watch list does not mean that it will be recommended to be removed from the plan’s investment option lineup, but rather triggers further due diligence on the investment option. The purpose of the due diligence is to determine if the original reasons for selecting the investment option are still valid. The IAR shall provide the plan sponsor with a report summarizing its review. Once an investment option is on the watch list, it will remain on the watch list until 9 5/2024 further due diligence indicates that it should be removed from the watch list or it is recommended for removal as an investment option. To be removed from the watch list, certain qualitative and quantitative measures must be met. If, after further due diligence, the IAR determines that the investment option no longer meets the criteria for remaining on the core list, the IAR will, to the extent available on the platform, identify one or more suitable replacements for the plan sponsor to select from. Additional Provisions – Park Avenue Investment Advisory and its IAR will not exercise any discretion or authority regarding the plan sponsor's selection of the specific securities, mutual funds, institutional funds, or funds available through group annuity contracts and mutual funds that may be eligible investment options under the qualified plan. Furthermore, neither the IAR nor Park Avenue Investment Advisory will have any discretion over plan assets in any capacity. It is the sole responsibility of the plan sponsor or named fiduciary to review, approve and implement the recommendation of the IAR for the following items:  the investment policy statement for the qualified plan.  the selection and retention of service providers (e.g., (without limitation) investment provider(s), investment managers and advisers, a plan record-keeper and a third-party administrator). It is also the plan sponsor or named fiduciary’s sole responsibility to supervise the performance of such providers.  the determination of the appropriate mix and number of asset classes to be included in the investment options available under the qualified plan.  to the selection of the specific mutual funds, institutional funds, or funds available through group annuity contracts that will be investment options under the qualified plan. If a qualified plan contains a company stock or self-directed brokerage investment option, the IAR shall not be required to take such investment options into account with respect to its determinations or recommendations. The plan sponsor shall retain sole fiduciary responsibility with respect to such company stock or self-directed brokerage option. The plan sponsor will agree to review at least annually and to advise the IAR of any changes in the investment options that may be available under the qualified plan or any changes to the demographic or other information previously provided to the IAR regarding the qualified plan. In providing these services to plan sponsors, Park Avenue Investment Advisory and its IARs must utilize the software and other tools provided by Envestnet Retirement Solutions, LLC (“ERS”). Park Avenue Investment Advisory, its affiliates and IARs are not affiliated with or under common ownership, control, or operation with ERS. Park Avenue Investment Advisory’ agreements with plan sponsors for plan investment advisory services do not include services provided by other Park Avenue Investment Advisory IARs, who may work separately with plan participants in their individual capacity, including the provision of advice

regarding rollovers. This Brochure also constitutes the disclosure required to be provided to plan sponsors under the regulations promulgated by the United States Department of Labor pursuant to Section 408(b)(2) of the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). The fee charged for these services and other important information relating to the fees for the investment advisory services shall be contained within the Plan Services Agreement for Investment Advisory Services under Section 3(21) of ERISA (“Plan Services Agreement”). Please see the section entitled “ERISA Section 408(b)(2) Disclosure to Responsible Plan Fiduciaries of ERISA-Covered Qualified Retirement Plans” later in this Brochure for further information. In addition to the program described above, in limited circumstances, certain Park Avenue Investment Advisory IARs may enter into joint work arrangements whereby such professionals refer plans to other Park Avenue Investment Advisory IARs who are credentialed to provide such plan investment advisory services. In such instances, the credentialed IAR will serve as the primary client contact. The referring IAR may receive initial and ongoing compensation for the referral. Please contact your IAR for more details. ERISA Retirement Plan Services (Non-Fiduciary) Park Avenue Investment Advisory can enter into an agreement with an employer-sponsored qualified retirement plan to provide certain non-fiduciary services. Park Avenue Investment Advisory IARs will assist in assessing, analyzing, and addressing the needs of the plan. Below are the services made available to the plan sponsor and/or the plan participants. 10 5/2024 In addition to the services outlined below, PAA may recommend the use of a third party investment manager for the plan (LeafHouse Financial Advisors (“LeafHouse”)), that specializes in providing fiduciary investment management services to employer-sponsored qualified retirement plans. PAA and its IARs may refer employers needing assistance with investment lineup selection and/or investment models to LeafHouse. Neither PAA nor its IARs will receive any additional compensation for such referrals. Employers electing to use PAA ERISA Retirement Plan Services (Non-Fiduciary) will be subject to fees as described under section 5. Fees and Compensation; ERISA Retirement Plan Services (Non-Fiduciary). Plan Governance and Committee Education  Reviewing retirement plan committee structure and requirements  Assisting plan sponsor to determine plan objectives  Reviewing participant education and communication strategy  Assisting with responses to participant requests for additional information.  Assisting the plan sponsor with developing and maintaining a fiduciary audit file  Coordinating data and plan design with the designated third-party administrator Plan Service Provider Selection/Review and Vendor Management  Assisting plan sponsor in determining the appropriate funding vehicle for the Plan  Providing periodic benchmarking of fees and services to assess reasonableness  Assisting the plan sponsor to generate and evaluate service provider Requests for Proposals (RFPs) and/or Requests for Information (RFIs)  Assistance with service provider transition and/or plan conversion Services to be provided to Plan Participants  Employee investment education and communication  Organizing group enrollment and investment education meetings for employees  Providing periodic updates to participants, upon request or via newsletter  Assisting participants with retirement readiness Park Avenue Investment Advisory Programs Park Avenue Investment Advisory is the sponsor of the Park Avenue Investment Advisory Programs which offer a range of investment strategies, from conservative income to aggressive growth. All Park Avenue Investment Advisory Programs are wrap fee programs as defined earlier in this Brochure. Unless otherwise noted, administrative and investment advisory fees, along with transaction fees, are “wrapped” into one comprehensive fee, which is paid quarterly. A portion of the wrap fee is used to pay Park Avenue Investment Advisory and your IAR for investment advisory services. A wrap fee program may cost you more or less than purchasing such services separately, depending on the level of trading activity in your account and the individual costs of the services if provided separately. Your advisory fee is not impacted by your level of trading however; Park Avenue Investment Advisory has an incentive to limit the trading in your account because Park Avenue Investment Advisory is charged for your executed trades. Park Avenue Investment Advisory does not place trade limitations on its IARs or its third- party investment managers which mitigates this conflict. For all Park Avenue Investment Advisory Programs, your IAR will analyze your individual financial situation and make recommendations as to an appropriate Program based on your individual needs and investment objectives. Prior to funding a Park Avenue Investment Advisory Program account, your Park Avenue Investment Advisory IAR will help you complete a custodial account application and other forms in order to determine your target risk profile. Your target risk profile is described in your Proposal and is the level of risk you are willing to take with your investments. Your Proposal includes your recommended Park Avenue 11 5/2024 Investment Advisory Program based on the information you have provided. The Program you have selected may include closed-end funds, options, stocks and bonds as well as separately managed accounts and other securities products approved for use within the Park Avenue Investment Advisory platform. Park Avenue Investment Advisory Programs are fully discretionary. Your IAR or the applicable third-party manager manages your assets within the parameters of the program and model portfolio you select without requiring you to approve transactions in advance. In a discretionary program, you maintain the ability to impose reasonable restrictions or modify any existing restrictions on the management of your account. For all Park Avenue Investment Advisory Programs, your IAR is available on an ongoing basis to assist you in evaluating your portfolio strategy and asset allocation. Your IAR will provide you with advice and guidance that is based on the information you provide at the time you open your Park Avenue Investment Advisory Program account and as you update or amend your information from time to time. To assist you in managing your account assets, Park Avenue Investment Advisory will provide you with:  Electronic periodic performance reports if electronic delivery is selected; and  Opportunities for you to engage in periodic account reviews with your IAR to address progress toward your investment objectives. You may transfer securities from outside accounts into your Park Avenue Investment Advisory Program account; however, your IAR may recommend that you sell some or all of the securities if he or she believes that holding such securities is not appropriate for the current recommended investment strategy. Any securities held in your account that are classified as Unsupervised Assets are not managed by Park Avenue Investment Advisory or your IAR but may remain in the account at your discretion. Park Avenue Investment Advisory and your IAR do not provide investment advisory services regarding Unsupervised Assets, do not charge an advisory fee on such assets, and do not assume responsibility for their management. Park Avenue Investment Advisory, your IAR, and Investment Managers do not consider Unsupervised Assets when providing investment advice for your Park Avenue Investment Advisory Program account. Your account can be managed in a tax-sensitive manner; however, neither Park Avenue Investment Advisory nor your IAR may provide tax advice or tax management services. You are responsible for any taxable events in all instances. You should always consult with your tax advisor for specific tax advice. Park Avenue Investment Advisory wrap fee Programs are described in a Wrap Fee Brochure which details the investment options and services for each program. Below is a brief description of each Park Avenue Investment Advisory wrap fee Program. To obtain a Wrap Fee Brochure for one of the Programs listed, please request the brochure from your IAR or call Park Avenue Investment Advisory at (800) 879-6934. Park Avenue Investment Advisory Unified Managed Account Program (“UMA Program”) The UMA Program is a discretionary investment advisory program sponsored by Park Avenue Investment Advisory that provides clients access to unaffiliated third-party investment managers. Investment managers provide trading direction to Orion Portfolio Services (“OPS”) consistent with a model portfolio they create and maintain. By executing the Investment Program Agreement, you grant investment managers discretionary authority to buy and sell securities and investments in your account. Based upon your objectives and risk tolerance, your IAR will recommend one or more investment managers to fulfill your overall investment strategy. In a UMA account, a single account contains multiple investment manager models where each model is considered a subaccount or “sleeve” of the account. Investment managers will periodically adjust and rebalance your portfolio to remain consistent with the model’s investment strategy. Investment managers do not provide personalized investment advice to you. In addition to recommending an investment manager(s), your IAR may also, on a discretionary basis, select 12 5/2024 individual securities to fulfill your overall investment strategy. Your IAR will periodically review your account with you. You can impose reasonable restrictions on the management of your account. Park Avenue Investment Advisory may remove an investment manager from the UMA Program at its discretion, at which point you shall be notified. Your IAR will work with you to reposition your assets into an appropriate investment option. If your UMA assets remain with an unapproved investment manager, the assets will remain in-kind and unmanaged until you and your IAR select another Investment Manager or Strategist. Park Avenue Investment Advisory Separately Managed Account Program (SMA Program) The SMA Program is a discretionary investment advisory program sponsored by Park Avenue Investment Advisory that provides you with access to unaffiliated third-party investment managers. By executing the Investment Program Agreement, you grant investment managers discretionary authority to buy and sell securities and investments in your account. Based upon your objectives and risk tolerance, your IAR will recommend one or more investment managers to fulfill your overall investment strategy. In the SMA program, each account contains the model of a single investment manager. Investment managers will periodically adjust and rebalance your portfolio to remain consistent with the model’s investment strategy. Investment managers do not provide personalized investment advice to you. Your IAR will periodically review your account with you. You can impose reasonable restrictions on the management of your account. Park Avenue Investment Advisory may remove an investment manager from the SMA Program at its discretion, at which point you shall be notified. Your IAR will work with you to reposition your assets into an appropriate investment option. If your SMA assets remain with an unapproved investment manager, the assets will remain in-kind and unmanaged until you and your IAR select another investment manager. Park Avenue Investment Advisory Representative as Portfolio Manager Program (“Rep as PM”) Park Avenue Investment Advisory Representative as Portfolio Manager Program (“Rep as PM”) is an asset allocation program managed on a fully discretionary basis. Your IAR acts as the portfolio manager in this Program. Based on your objectives and risk, your IAR builds a portfolio constructed with a variety of securities that satisfy an asset allocation based on your portfolio objectives. Park Avenue Investment Advisory has engaged Astoria Portfolio Advisors LLC (“APA”) as a sub-advisor for the Rep as PM program and APA shall act in such capacity at the client’s election. APA is a SEC Registered Investment Advisor offering a comprehensive range of investment management strategies, research and services for independent investment advisory firms. If the client elects to have APA as the sub-advisor on the account APA will assist the IAR associated with the client by building the investment portfolios and managing those portfolios on an ongoing basis. Please note, APA sub-advises the AXS Astoria Inflation Sensitive exchange traded fund (ticker symbol PPI) which may be purchased in your account. AXS pays APA an annual sub-advisory fee based on the Fund’s average daily net assets. AXS is responsible for paying the entirety of Astoria’s sub-advisory fee. The Fund does not directly pay Astoria. While Park Avenue Investment Advisory does not receive a portion of this payment, this sub-advisory fee from AXS to APA causes a conflict in APA selecting and purchasing the fund in your account as it will increase APA’s sub-advisory fee it collects from AXS. As previously stated, you may impose reasonable restrictions on the management of your account which includes the ability to restrict the purchase of this fund in your account. Orion Advisor Technology, LLC (“Orion”) Park Avenue Investment Advisory has contracted with Orion, through its affiliate Orion Portfolio Solutions (“OPS”), to provide a technology structure and platform to provide a way for clients to efficiently connect with 13 5/2024 third-party investment managers. For the UMA/Strategist and SMA programs, OPS directs trades in your account by taking directions from the third-party portfolio manager/strategist to adjust asset allocations, add, remove or replace securities in the account, and rebalance the account as it deems necessary. For Representative as Portfolio Manager Programs Park Avenue Investment Advisory performs administrative and trading duties at the direction of your IAR. Mutual Fund Share Class Selection in Park Avenue Investment Advisory Programs Park Avenue Investment Advisory makes multiple share classes available from mutual fund sponsors and may not offer the least expensive share class that a mutual fund has available. Other custodians and financial services firms may offer the same mutual fund and make available share classes that have a lower overall cost to the investor than is available through Park Avenue Investment Advisory. An investor who holds a more expensive share class of a mutual fund will pay higher fees over time and earn lower investment returns than an investor who holds a less expensive share class of the same mutual fund. Clients should consult with their IAR as to which share classes are available at Park Avenue Investment Advisory and consider these factors when deciding between types of investments, types of investment products and types of investment accounts. Lending Services Non-Purpose Loan Program Park Avenue Investment Advisory through its Custodians makes non-purpose loans (each an “NPL”) available to clients through agreements the Custodian has with third party financial institutions. You may apply using your account as collateral and must enter into an NPL agreement directly with the financial institution providing the NPL (the “Loan Provider”). These eligible securities accounts may include one or more of your Park Avenue Investment Advisory Program accounts. Your Park Avenue Investment Advisory Program account will be pledged to support any loans extended under the Non-Purpose Loan Program. You will not be permitted to take withdrawals from the account unless there is sufficient collateral otherwise supporting the loans (as determined by Park Avenue Investment Advisory in its sole discretion). If you participate in the NPL Program, you will pay interest to the Loan Provider on the loan value in addition to any Program advisory fees charged in the Park Avenue Investment Advisory Program account being used as collateral. Park Avenue Investment Advisory and its IARs do not receive any portion of the interest paid by clients for non-purpose loans. Funds borrowed and proceeds from any recommended Lending Service may not be used to purchase securities or fund brokerage accounts. Important Considerations relating to Lending Services In certain circumstances, for example to avoid tax consequences or to allow for potential appreciation of assets, your IAR may recommend an NPL in your advisory account. Your IAR will benefit from a NPL because you do not liquidate assets in your account, which would diminish the assets held in the account and the potential fees and commissions that could be earned by your IAR from managing those assets. For example, with a fee-based account, by recommending a NPL to fund some purchase or financial need rather than liquidate securities, Park Avenue Investment Advisory and your IAR continue to earn fees on the full account value and may also earn revenue from the new loans. You must meet certain eligibility requirements and complete loan documentation prior to applying for Lending Services. Specifically, you will be required to execute loan documents with the loan provider. The decision to use Park Avenue Investment Advisory Program account assets as collateral rests with you 14 5/2024 and should only be made if you understand:  the risks of borrowing and the impact of the use of borrowed funds on advisory accounts;  how the use of loans may affect your ability to achieve investment objectives;  the risk that you may lose more than your original investment; and  the possibility you may not benefit from collateralizing your account for a non-purpose loan in a Program account if the performance of your account does not exceed the interest expense being charged on the loan plus the additional advisory fees incurred by your account as a result of the deposit of the loan proceeds. Defaults – Non-purpose loans are full recourse, demand loans and clients with non-purpose loan accounts may need to deposit additional cash or collateral or repay part or all of the loan if the value of the portfolio declines below the required loan-to-value ratio. The Loan Provider may demand repayment at any time. Failure to promptly meet a request for additional collateral or repayment or other circumstances (e.g., a rapidly declining market) could cause the custodian, at its discretion, to liquidate some or all of the collateral account or accounts to meet the loan requirements. Depending on market circumstances, the prices obtained for the securities may be less than favorable. Any required liquidations may disrupt your long-term investment strategies and may result in adverse tax consequences. Park Avenue Investment Advisory does not provide legal or tax advice; you should consult your legal and tax advisors regarding the legal and tax implications of borrowing and using securities as collateral for a loan. You are personally responsible for repaying the loan in full, even if the value of the collateral is insufficient. Neither Park Avenue Investment Advisory nor its IARs will act as investment adviser to you with respect to the liquidation of securities held in a Park Avenue Investment Advisory Program account to meet a non-purpose loan demand. Those liquidations will be executed in the custodian’s capacity as broker- dealer and may, as permitted by law, result in executions on a principal basis in your account. In addition, as creditors, Park Avenue Investment Advisory may have interests that are averse to your interests. Additional limitations and availability may vary by state. There are substantial risks associated with the use of borrowed funds for investment purposes and securities as collateral for a loan. Margin Accounts Clients should be aware that margin borrowing involves additional risks. Margin borrowing will result in increased gain if the value of the securities in the account goes up but will result in increased losses if the value of the securities in the account goes down. Interest will be charged on the amount loaned to purchase the additional securities, and therefore any gains must exceed the interest amount for this to be profitable. The custodian, acting as the client’s creditor, will have the authority to liquidate all or part of the account to repay any portion of the margin loan, even if the timing would be disadvantageous to the client. If an account is approved for trading on margin and the client enters into a margin agreement with the custodian, margin interest will be charged on any credit extended to or maintained in the account. Your advisory fee is not charged on any margin debit balance, rather only on the net equity of the account. Assets Under Management As of December 31, 2023, Park Avenue Investment Advisory maintained $75,377,994 of Regulatory Assets Under Management of which $75,377,994 were managed on a discretionary basis and $0 were managed on a non-discretionary basis. 15 5/2024