Description of Services Park Piedmont Advisors is a Registered Investment Adviser primarily located in Chicago, Illinois with offices in New York, New York, Oakland, California, Springfield, New Jersey and Waretown, New Jersey. We are organized as a limited liability company under the laws of the State of Illinois and we have been providing investment advisory services since 2003. We provide investment advice to individuals, families, businesses and retirement plans. Nicholas Levinson and Thomas Levinson are the owners of the firm.
The following paragraphs describe our services and fees. As used in this brochure, the words "we", "our" and "us" refer to Park Piedmont Advisors and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person or Investment Adviser Representative ("IAR") throughout this brochure. As used in this brochure, our Associated Persons or Investment Adviser Representatives are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Portfolio Management Services Our investment advice consists primarily of developing appropriate asset allocations for each client, and then implementing this allocation advice using primarily indexed investments. We use mostly indexed mutual funds and exchange traded funds (ETFs) for our indexed investments. These indexed investments are designed to track/match the results of the various parts of the markets in which we are investing. We do not engage in market timing, or individual stock or bond analysis. We do not provide financial planning services, but we do give specific advice on such financial goals as retirement, education, and large capital purchases, at no additional charge to our investment advisory clients (fees are discussed in Item 5). Our asset allocation advice depends on each client's specific circumstances, financial goals, and ability to take investment risk. Asset allocation refers to the percentage mix of investments between safer, income producing investments, and riskier stock and high yield investments. We meet with each client periodically to make sure their allocation continues to be appropriate for their needs, and make changes as called for. We monitor investment portfolios on an ongoing basis, and rebalance portfolios as indicated by changes in market conditions that materially change your initial asset allocations and/or changes in your specific financial circumstances.
We manage $861,968,712 as of December 31, 2023. Of this total, $391,633,493 was discretionary and $470,335,219 was nondiscretionary. We also manage $48,883,228 in client assets on a non- continuous basis. When our firm has discretion we are able to make changes in your investments without your prior approval. When we do not have discretion, we must receive your approval prior to making changes in your investments. Whether accounts are discretionary or not discretionary, we cannot remove money or securities from your accounts without your specific written approval. (With your written approval, we are allowed to debit our investment advisory fees from your accounts.) (Fees are discussed in Item 5.) Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. We do not participate in wrap fee programs.
4 Our advisory services are also offered to defined benefit

plans, profit sharing plans and other plans subject to the Employee Retirement Income Securities Act. Our advice may include formation of an investment policy statement, as needed, asset allocation advice, portfolio management services, and investment performance monitoring.
In some cases, we may provide asset allocation advice on accounts not held at our recommended custodian, Charles Schwab (CS). In such cases, we will monitor these accounts on a periodic basis and provide you recommendations, as necessary. It is your responsibility to implement any recommendations we provide.
Advisory Services to Retirement Plans We offer investment advisory services to workplace retirement plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include plan-level advice regarding fund selection and investment options, education services and individualized investment advice to plan participants, investment performance monitoring, and/or ongoing investment reviews. These investment advisory services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification;
•Asset allocation;
•Risk tolerance; and
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents.
Either party to the investment advisory agreement may terminate the agreement upon written notice to the other party in accordance with the terms of the agreement for services. The investment advisory fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent 5 advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal advice);
•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.