PARKVIEW LTD.

Firm Brochure ADV Part 2A Item 1. Cover Page Zurich 10. March 2025 This Brochure (“Form ADV Part 2A”) provides information about the qualifications and business practices of Parkview Ltd. (“Parkview”). Parkview is registered as an investment adviser (“RIA”) with the United States Securities and Exchange Commission (the “SEC”) under the Investment Advisers Act of 1940, as amended (the “Advisers Act”). If you have any questions about the contents of this brochure, please contact us by telephone at +41 44 283 40 80 or by e-mail at info@parkview.ch. CRD 160171 Parkview Ltd Gutenbergstrasse 9 8002 Zurich Switzerland The information in this brochure has not been approved or verified by the SEC or by any state securities authority. Additional information about Parkview is also available on the SEC’s website at www.adviserinfo.sec.gov. There is no specific level of skill or training required to become a registered in- vestment adviser with the SEC. This Brochure provides information for U.S. clients of Parkview; most provi- sions of the Advisers Act and of this Brochure do not apply to Parkview’s non-U.S. clients. Phone: +41 44 283 40 80 Fax:+41 44 283 40 81 Item 2. Material Changes info@parkview.ch www.parkviewgroup.com Since our last annual amendment was filed in March 2024, the following material changes have been made to this disclosure brochure: Item 5: The method of the average Asset under Management calculation for the Asset Management fee calculation changed. Newly, the fixed asset management fee for discretionary and nondiscretionary asset management services is charged quarterly in arrears and is calculated on the basis of the average Net Asset Value (NAV) of all assets managed during a calendar quarter.  Parkview Ltd, CRD 160171 10 March 2025 Item 3. Table of Content Item 1. Cover Page ........................................................................................ 1 Item 2. Material Changes .............................................................................. 1 Item 3. Table of Content ................................................................................ 2 Item 4. Advisory Business .............................................................................. 3 Item 5. Fees and Compensation .................................................................... 4 Item 6. Performance Based Fees and Side-by-Side Management ................... 4 Item 7. Types of Clients ................................................................................. 5 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ............. 5 Item 9. Disciplinary Information .................................................................... 7 Item 10. Other Financial Industry Activities and Affiliations ........................... 7 Item 11. Code of Ethics, Participation in Client Transactions and Personal Trading 8 Item 12. Brokerage Practices ......................................................................... 8 Item 13. Review of Accounts ....................................................................... 10 Item 14. Client Referrals and Other Compensation ...................................... 10 Item 15. Custody ......................................................................................... 10 Item 16. Investment Discretion ................................................................... 11 Item 17. Voting Client Securities .................................................................. 11 Item 18. Financial Information .................................................................... 11 2  Parkview Ltd, CRD 160171 10 March 2025 Item 4. Advisory Business Firm Description and Principal Owners ject to special conditions imposed by individual cli- ents. For example, a client may restrict or prohibit transactions in certain types of securities. Non-Discretionary (i.e., Advisory) Asset Management Services Parkview Ltd. (“Parkview” or “we”), a Swiss corpora- tion based in Zurich, Switzerland, provides investment advisory services to clients with connections to the United States (“U.S.”). Parkview was formed in Zurich on February 23, 2011. Parkview is run by a team of shareholding partners: ▪ Marius André Holzer, Chief Compliance Officer and Chief Operations Officer for both companies; Parkview Ltd, Switzerland and Parkview US LLC, US ▪ Thomas J. Egger CEO Parkview Ltd, Switzerland Under a non-discretionary management mandate, Parkview makes investment recommendations to a client, and the client subsequently makes all invest- ment decisions about the investments held in his or her account. In order to implement a client’s deci- sions, the client may authorize Parkview to place or- ders for the execution of securities transactions for the client’s account. Parkview generally provides ad- vice concerning appropriate asset allocations, evalua- tion of investment managers, identification of risks, and specific investment recommendations. ▪ Marcus R. Epprecht CEO Parkview US LLC, US ▪ Oussama Himani CIO Parkview Limited, Switzerland ▪ Martin Liechti Shareholder Parkview Ltd, Switzerland If explicitly required by a non-discretionary client, Parkview may implement investment ideas which do not pertain to Parkview’s investment universe. Parkview will disclose to the client if an investment idea is not part of Parkview’s investment universe. ▪ Sebastian T. Derungs CFO Parkview Ltd, Switzerland Consulting Services Services Upon request, Parkview advises families on matters relating to family governance, succession planning, philanthropy as well as on matters related to their businesses (strategic advisory, M&A advisory). Wrap Fee Programs Parkview does not participate in wrap fee programs. Assets under Management As of December 31, 2024, Parkview managed approxi- mately $412 million. $ 241 million on a discretionary basis and $171 milion on a non-discretionary basis. Parkview helps entrepreneurs and their families sus- tain wealth across generations by delivering invest- ment advisory, management, and controlling services. The services provided include the provision of discre- tionary portfolio management and continuous advice concerning investment of assets consistent with the circumstances, preferences and objectives of each cli- ent. As part of the information gathering process, Parkview determines the client's individual objectives, time horizon, risk tolerance, and liquidity needs and develops a tailored investment policy. Parkview dis- cusses a client's prior investment history, as well as family composition and background. Parkview’s advice is limited to the types of securities and transactions as set forth in Section 8. Parkview does not render any Legal or Tax advice. Discretionary Asset Management Services Under a discretionary management mandate, Parkview has the authority to supervise and direct the investments of and for each client’s account generally in line with the investment profile agreed with the cli- ent and without prior consultation with the client. Parkview determines which securities are bought and sold for the account and the total amount of the pur- chases and sales. Parkview’s authority may be sub- 3  Parkview Ltd, CRD 160171 10 March 2025 Item 5. Fees and Compensation Other fees you may incur Fees charged by Parkview do not include custodian fees, fees for trade settlement, brokerage commis- sions, taxes or any other fee or taxes imposed by the custodian bank or the broker or National Authorities. The fees also do not include management or other fees charged by funds or other products that client accounts may be invested in from time to time. It is Parkview’s philosophy to generally invest in the least expensive available share class. For its discretionary asset management service and nondiscretionary asset management service, Parkview charges a fee for its services based on a per- centage of the market value of assets under manage- ment. The fixed asset management fee for discretion- ary and nondiscretionary asset management services is charged quarterly in arrears and is calculated on the basis of the average Net Asset Value (NAV) of all as- sets managed during a calendar quarter. The annual fees range from 0.4% to 1%, depending on the size and complexity of the mandate. Item 6. Performance Based Fees and Side-by-Side Management For certain Family Office Service Packages, Parkview offers flat fee arrangements based on scope and com- plexity of the mandate. Performance Based Fee Scheme Parkview may waive, discount and/or negotiate fees at its discretion. Parkview may also charge additional fees for services outside the scope of the services de- scribed above. Any additional fees are disclosed to the client. Parkview also advises clients on foreign currencies and the below fee schedule applies and is negotiable to such advice. Compensation is not payable in advance. Parkview does not manage or advise accounts based on com- missions, subscriptions fees, or hourly rate charges. Parkview relies on custodian banks of its clients to value the assets in the respective client accounts, and Parkview computes its investment advisory fees based on these valuations provided by the custodian. At the end of the quarter Parkview arranges with the custodian for the direct payment of its fee from the respective client accounts. The client’s statement from the custodian will reflect all amounts disbursed from the account, including the amount of any advi- sory fee paid to Parkview. Parkview presently does not charge performance- based fees. However, Parkview may enter into perfor- mance-based fee arrangements with qualified clients in the future subject to individualized agreements with each client. To the extent Parkview enters into a performance or incentive fee arrangement, it will do so in accordance with Section 205(a)(1) and Rule 205- 3 under the Advisers Act. Only clients who meet the following requirements may opt for the performance based fee scheme: (i) clients with at least $ 1,100,000 under management with Parkview; (ii) clients with more than $ 2,200,000 of net worth, excluding the value of the primary residence and certain debt se- cured by the property; or (iii) clients who are qualified purchasers under Section 2(a)(51) of the Investment Advisors Act of 1940, as amended (which generally is defined to include only individuals, companies or trusts with more than $ 5,000,000 in investments). Parkview potentially can receive higher fees with a performance-based compensation structure than from those accounts that pay the asset-based fee schedule described above. To minimize this conflict, Parkview generally will enter into a performance fee arrangement upon the request of a client or in the case of specific investment performance objectives. Side-by-Side Management Consulting Services fees are determined based on the nature of the service provided and the complexity of each client's circumstances. All fees are agreed prior to entering into a contract. The fees for consulting services (which are separate than fees charged for investment advice) are calcu- lated and charged on a fixed fee basis, typically rang- ing from $30,000 to $400,000 per year, depending on size and complexity, and subject to the specific ar- rangement reached with the client. Consulting ser- vice fees are not charged in advance. Conflicts related to side-by-side management of dif- ferent accounts may exist. For example, Parkview may manage more than one account according to the same or a substantially similar investment strategy. Side-by-side management of different types of ac- counts may raise conflicts of interest when two or more accounts invest in the same securities or pursue a similar strategy. These potential conflicts include the favorable or preferential treatment of an account or a group of accounts, conflicts related to the alloca- tion of investment opportunities, particularly with re- spect to securities that have limited availability, such 4  Parkview Ltd, CRD 160171 10 March 2025 Parkview attempts to optimize a client's asset alloca- tion following a previously defined investment policy and then selects the best managers in each asset class based on research (manager due diligence and moni- toring) provided by third parties. Macro-economic trends, cyclical and trending analysis of currencies, sectors, markets, industries, along with asset class re- turn expectations and risk profiles drive the strategic and tactical asset allocation process. In selecting specific securities, Parkview employs a bottom-up approach evaluating the fundamentals of the specific investment, comparisons to benchmarks and to similar securities, and timing. as initial public offerings, and transactions in one ac- count that closely follow related transactions in a dif- ferent account. In addition, the results of the invest- ment activities for one account may differ signifi- cantly from the results achieved for other accounts, particularly as a result of Parkview’s practice to indi- vidually tailor each client’s investment portfolio. Parkview has policies and procedures in place aiming to ensure that all client accounts are treated fairly and equitably. Parkview strives to equitably allocate investment opportunities among relevant accounts over time. In addition, investment decisions for each account are made with specific reference to the indi- vidual needs and objectives of the account. Accord- ingly, Parkview may give advice or exercise invest- ment responsibility or take other actions for some cli- ents (including related persons) that may differ from the advice given, or the timing and nature of actions taken, for other clients. Investment results for differ- ent accounts, including accounts that are generally managed in a similar style, also may differ as a result of these considerations. Some clients may not partici- pate at all in some investments in which other clients participate or may participate to a different degree or at a different time. Parkview offers investment management and advi- sory services typically on the following types of securi- ties and transactions: exchange-listed securities, secu- rities traded over-the-counter, foreign issuers, op- tions (including covered and uncovered positions), corporate debt securities (and other commercial pa- per), certificates of deposit, investment company se- curities such as mutual funds, exchange traded funds, foreign exchange transactions, and futures contracts on intangibles. Item 7. Types of Clients Parkview offers investment management services to international high net worth individuals and families as well as institutional investors (e.g. charitable en- dowments and financial institutions). These investors may use trusts or other entities to control their liquid assets. Such entities in some occasions can become the contracted client of the firm. Parkview also provides services to individual’s invest- ments held within personal retirement accounts (IRA’s). Parkview will also invest in hedge funds or other pri- vate funds on a limited basis. Investments in private funds are available to “accredited investors” or “quali- fied purchasers,” and they typically require investors to lockup their assets for a period of time. These in- vestments may have limited, or no liquidity and they may involve different risks than investing in registered funds and other publicly offered and traded securi- ties. Parkview relies on the valuation and perfor- mance data provided directly from the private funds. Private funds may often be delayed in providing Parkview with the valuation information; therefore, Parkview may likewise be delayed in reporting this in- formation to the client. Parkview will rely on the ac- curacy of a client’s representations in making corre- sponding representations regarding the investment restrictions on behalf of the client’s account in con- nection with certain derivative and other transac- tions. Parkview also requires notification by the client if the client’s representations become inaccurate. Generally, Parkview works with clients with a mini- mum of $10 million of assets under management. Parkview may accept accounts below the minimum requirements or may retain accounts that have dropped below the minimum requirement due to market fluctuation or investment performance. Ac- counts that have family, corporate or other relation- ships may be aggregated for purposes of the mini- mum account size. In certain cases, Parkview may provide asset alloca- tion recommendations that may include real estate holdings. These holdings are acquired through real estate investment trusts (REITs) and other investment vehicles. Parkview does not invest in real properties. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Material Investment Risks Methods of Analysis Clients should bear in mind that investing in securities involves a risk of loss. Among other risks, investments will be subject to market risk, liquidity risk, credit and Parkview offers primarily institutional asset manage- ment. Rather than selecting individual securities, 5  Parkview Ltd, CRD 160171 10 March 2025 counterparty risk, interest rate risk, risk in fluctua- tions of commodity pricing, risk of loss due to political and economic developments in foreign markets, and risks involving movements in the currency markets. Clients should be prepared to bear the risk of losing their investment in securities. Past performance is not an indication as to future re- sults. Depending on the specific investments held within his or her Account, a Client may face the following invest- ment risks: Risks Related to Investments in Funds: For purposes of this discussion, the term “Fund” includes, but is not limited to, a U.S. or non-U.S. unit investment trust, an open-end or closed-end mutual fund, a hedge fund, a private equity fund, a venture capital fund, a real es- tate investment trust, an exchange traded fund (“ETFs”) or any other private alternative or invest- ment fund). Investments in Funds carry risks associ- ated with the particular fund. Each fund and the re- spective manager will charge their own management and other fees, which will result in a Client bearing an additional level of fees and expenses. U.S. mutual funds generally must distribute all gains to investors, including investors who may not have an economic gain from investing in the fund, which can lead to negative tax effects on investors, particularly non-U.S. persons. Investments in certain non-U.S. funds by U.S. persons result in U.S. tax and reporting obligations and failing to comply with such requirements can re- sult in significant penalties. Funds generally have unique risks of loss as described in their offering doc- uments. Market Risk: Market risk refers to the risk of loss aris- ing from general economic and market conditions, such as interest rates, availability of credit, inflation rates, commodity prices, economic uncertainty, changes in laws and national and international politi- cal circumstances. Each Account is subject to market risk, which will affect volatility of securities prices and liquidity. Such volatility or illiquidity could impair prof- itability or result in losses. Risks Related to Investments in Derivatives: Risk Related to Equity Investments: Investments in equity securities generally involve a high degree of risk. Prices are volatile and market movements are difficult to predict. These price movements may result from factors affecting individual companies or indus- tries. Price changes may be temporary or last for ex- tended periods. The value of specific equity invest- ments obviously correlates to the fundamentals of each particular security. Prices of equity investments may fall or fail to appreciate regardless of movements in securities markets. Leverage: Certain investment instruments such as de- rivatives may use leverage to achieve returns. The use of leverage may have the effect of disproportion- ately increasing an account’s exposure to the market for the securities or other assets underlying the deriv- ative position and the sensitivity of an account’s port- folio to changes in market prices for those assets. Leverage will tend to magnify both the positive im- pact of successful investment decisions and the nega- tive impact of unsuccessful investment decisions by Parkview on an account’s performance. Counterparty Credit Risk: When derivatives or certain other instruments are purchased; a client’s account will be subject to the ability and willingness of the other party to the contract (a “Counterparty”) to per- form its obligations under the contract. Although ex- change-traded futures and options contracts are gen- erally backed by a guarantee from a clearing corpora- tion, an account could lose the benefit of a contract in the unlikely event that the clearing corporation be- comes insolvent. A Counterparty’s obligations under a forward contract, over-the-counter option, swap or other over-the-counter derivative contract are not so guaranteed. If the Counter-party to an over-the- counter contract fails to perform its obligations, an account may lose the benefit of the contract and may have difficulty reclaiming any collateral that an ac- count may have deposited with the counterparty. Risks Related to Fixed Income Investments: Invest- ments in fixed income securities (i.e., bonds) repre- sent numerous risks such as credit, interest rate, rein- vestment, liquidity, and prepayment risk, all of which affect the value of the security and volatility of such value. In general, securities with longer maturities are more sensitive to price changes. Additionally, the prices of high yield, fixed-income securities fluctuate more than high quality debt issues. Prices are espe- cially sensitive to developments affecting the com- pany’s business and to changes in the ratings assigned by rating agencies. Prices are often closely linked with the company’s stock prices. High yield securities can experience sudden and sharp price swings due to changes in economic conditions, stock market activ- ity, and large sales by major investors, default, or other factors. Developments in the credit market may have a substantial impact on the companies we may invest in and will affect the success of such invest- ments. In the event of a default, the investment may suffer a partial or total loss. Lack of Correlation: The market value of a derivative position may correlate imperfectly with the market price of the asset underlying the derivative position. To the extent that a derivative position is being used 6  Parkview Ltd, CRD 160171 10 March 2025 Parkview US LLC, to provide investment advisory ser- vices. Parkview US LLC is a registered investment ad- viser with the SEC and wholly owned by Parkview. to hedge against changes in the value of assets in an account, a lack of price correlation between the deriv- ative position and the hedged asset may result in an incomplete hedge. Furthermore, Parkview is affiliated with: • Parkview Europe Ltd, a London based company, which offers analytics and research in the field of macro-econom- ics to its affiliates. • Parkview Cyprus Ltd that provides op- erational back office support to the Parkview group of entities. • Illiquidity: Over-the-counter derivative contracts are usually subject to restrictions on transfer, and there is generally no liquid market for these contracts. Alt- hough it is often possible to negotiate the termination of an over-the-counter contract or enter into an off- setting contract, a Counterparty may be unable or un- willing to terminate a contract with an account, espe- cially during times of market instability or disruption. The markets for many exchange traded futures, op- tions and other instruments are quite liquid during normal market conditions, but this liquidity may dis- appear during times of market instability or disrup- tion. CFEG Parkview Financial Solutions that offers education and consulting ser- vices around investment governance topics. Less Accurate Valuation: The absence of a liquid mar- ket for over-the-counter derivatives increases the likelihood that Parkview will not be able to correctly value these interests. Currency Exposure: Parkview invests in securities and other investments that are denominated in currencies other than U.S. Dollars. Accordingly, the value of such assets may be affected favorably or unfavorably by fluctuations in currency rates. Parkview seeks to hedge the foreign currency exposure, but such hedg- ing strategies may not necessarily be available or ef- fective and may not always be employed. Accounts managed by Parkview are routinely subject to foreign exchange risks and bear a potential risk of loss arising from fluctuations in value between the U.S. Dollar and such other currencies. Parkview will receive services or receive client refer- rals from affiliated entities. Among other things, there may be financial incentives for Parkview to fa- vor affiliated service providers over non-affiliated ser- vice providers. Conflicts of interest may arise from the recommendation or incentive to utilize the ser- vices of affiliated entities in order to maintain services or accounts within the Parkview group and therefore the utilimate compensation earned by the Parkview group. Parkview believes the aforementioned conflict is mitigated in that representatives of Parkview must ensure that any product or service is in the best inter- est of the client. Parkview believes that its affiliates provide quality services commensurate with the fees charged. However, lower fees for comparable ser- vices may be available from other sources. Clients are encouraged to request additional information regard- ing potential conflicts of interest. Parkview and its management personnel neither are registered nor have an application pending to register as, broker-dealers, registered representatives of a broker-dealer, future commissions merchants, com- modity pool operators, commodity trading advisors, or associated persons of the foregoing entities. Non-U.S. Investments: Investments in non-U.S. secu- rities expose the client’s portfolio to risks that in addi- tion to those risks associated with investments in U.S. securities. Such risks include, among other things, trade balances and imbalances, economic policies of various foreign governments, exchange control regu- lations, withholding taxes, potential for nationaliza- tion of assets or industries, and the political instability of foreign nations. Item 9. Disciplinary Information Parkview is licensed as an asset manager by the Swiss Financial Market Supervisory Authority (FINMA) and is supervised by it in accordance with the Feder Finan- cial Institutions Act (FinIA). Parkview has not been involved in any legal or disci- plinary events. Some supervisory responsibilities are delegated to the supervisory organisation authoried by FINMA called FINcontrol Suisse AG. Item 10. Other Financial Industry Activities and Affil- iations Parkview is moreover a member of FINOS – Finanz- ombudsstelle Schweiz. FINOS is an ombudsman ser- As described in Item IV, for certain clients, Parkview works closely with its subsidiary in the United States, 7  Parkview Ltd, CRD 160171 10 March 2025 vice located in Zurich, Switzerland, and provides dis- pute resolution services to affiliated financial service providers and their clients. FINOS is legally recognized pursuant to Art. 84 para. 1 FinSA. and in a manner to avoid any actual or potential con- flict of interest or any abuse of any person’s position of trust and responsibility. Further, these persons should not take inappropriate advantage of their posi- tions with or on behalf of a client. Parkview will provide a copy of the Code of Ethics to any client or prospective client upon request. Item 11. Code of Ethics, Participation in Client Trans- actions and Personal Trading Code of Ethics Participation or Interest in Client Transactions Parkview employees or related persons invest regu- larly alongside the firm’s clients, both to align the in- terest of firm and personnel and firm clients and as an expression of confidence in our portfolio manage- ment efforts. In order to ensure that Parkview per- sonnel never trade ahead of their clients, the firm generally tries to ensure that all trading in specific po- sitions for officer and employee accounts to come af- ter the analogous trades are executed for client ac- counts. Item 12. Brokerage Practices Parkview has adopted a Code of Ethics (the “Code”) and attendant policies and procedures governing per- sonal securities transactions by Parkview and its per- sonnel. The Code also provides guidance and instruc- tion to Parkview and its personnel on their ethical ob- ligations in fulfilling its duties of loyalty, fairness and good faith towards the clients. The overriding princi- ple of Parkview’s Code of Ethics is that all employees of Parkview owe a fiduciary duty to clients for whom Parkview acts as investment adviser or sub-adviser. Accordingly, employees of Parkview are responsible for conducting personal trading activities in a manner that does not interfere with a client’s portfolio trans- actions or take improper advantage of a relationship with any client. The Code contains provisions designed to try to: (i) prevent, among other things, improper trading by Parkview’s employees; (ii) identify conflicts of inter- est; and (iii) provide a means to resolve any actual or potential conflicts of interest in favor of the clients. The Code attempts to accomplish these objectives by, among other things, (i) requiring preclearance of spe- cific trades, which includes documenting any excep- tions to such preclearance requirement; (ii) restricting trading in certain securities that may cause a conflict of interest, as well as (iii) periodic reporting regarding transactions and holdings of employees. Parkview does not have custody or possession of cli- ent assets; each of Parkview’s clients maintains cus- tody of its assets at one or more custodians (usually Swiss based banks). Each custodian bank acts as a broker-dealer itself and/or maintains relationships with designated broker-dealers (including potentially an affiliate of the custodian bank). Parkview effectu- ates security transactions through the custodian, or the broker or dealer designated by the custodian bank selected by the client. Parkview does not guar- antee best execution or the best commissions be- cause Parkview does not control these factors. Parkview operates exclusively on this directed broker- age basis whereby the client and/or the client’s choice of custodian bank selects the broker-dealer to be used for securities transactions. Therefore, clients should be aware of the following: The Code contains sections including, but not limited to, the following key areas: (i) restrictions on personal investing activities; (ii) gifts and business entertain- ment; and (iii) outside business activities. ▪ Parkview does not negotiate commission rates The Code also provides for the Parkview’s execution of supervisory policies and procedures, and the re- view and enforcement processes of such policies and procedures. Parkview has designated a Chief Compli- ance Officer responsible for maintaining, reviewing and enforcing Parkview’s Code of Ethics and corre- sponding policies and procedures. with broker-dealers with whom orders are placed either directly or via the custodian bank because the broker-dealer is determined by the custodian bank and/or the client. The applicable commis- sions and fees charged for securities transactions are agreed upon between the client and the cus- todian bank when the client accepts the applica- ble commission schedule published by the custo- dian bank or otherwise agrees. ▪ Commission charges will vary among clients and best execution may not be guaranteed by Parkview. The fundamental position of Parkview is that, in ef- fecting personal securities transactions, personnel of Parkview must place at all times the interests of cli- ents ahead of their own pecuniary interests. All per- sonal securities transactions by these persons must be conducted in accordance with the Code of Ethics 8  Parkview Ltd, CRD 160171 10 March 2025 and the respective broker used in the block trade. Also note, since most Swiss custodian banks ware- house securities orders until filled, there may be de- lays in settlement between client Accounts depending on the practice of the respective custodian bank and/or broker. Decision Making Process; Balancing the Interests of Multiple Client Accounts Because the client selects the custodian and thereby the broker-dealer to be used for securities transac- tions involving its account, different clients may have accounts at the same custodian bank, or a single cli- ent may have multiple accounts at different custodian banks. Therefore, a client may pay an executing bro- ker a higher commission for a securities transaction than might be charged by another broker-dealer exe- cuting the same transaction or than the commission charged by the broker-dealer executing a similar transaction for another client of Parkview. Commis- sion charges may also vary between clients. It also is possible that the broker-dealer used for transactions may not be a registered broker-dealer under the U.S. Securities Exchange Act of 1934, as amended (the “Exchange Act”). Block Trades In making the decision as to which securities are to be purchased or sold and the amounts thereof, Parkview is guided by the general guidelines set up at the in- ception of the adviser-client relationship in coopera- tion with the client and a periodic review of the asset allocation. These general guidelines cover such mat- ters as the relative proportion of debt and equity se- curities to be held in the portfolio, the degree of risk which the client wishes to assume and the types and amounts of securities to be held in the portfolio. Parkview’s authority may be further limited by spe- cific instructions from the client, which may restrict or prohibit transactions in certain securities. Parkview US generally will combine orders into block trades when purchasing the same security for multi- ple client Accounts. Such aggregated orders (“block trades”) will be pre-allocated among the participating client Accounts. When selecting the participating ac- counts, a variety of factors such as suitability, invest- ment objectives and strategy, risk tolerance and / or the ability to invest additional funds will be taken into consideration. In determining the portion for each participating account further factors such as account’s size, diversification, asset allocation and position weightings as well as any other appropriate factors might be of relevance. Participating accounts in a block trade placed with the same broker or the same custodian bank generally will receive an average price and transaction costs will be shared on a proportion- ate basis and as determined in the agreement with the custodian. This can either be a sharing on a pro rata basis, or covered with a “ticket fee”, or based on the implemented digression model, whereas costs de- crease in relation to the purchased quantity and in- clude the application of a minimum rate, when shared costs are below a defined amount. Partial fills of transactions will be allocated on a pro rata share ba- sis. Parkview may manage numerous accounts with simi- lar or identical investment objectives or may manage accounts with different objectives that may trade in the same securities. Despite such similarities, portfo- lio decisions relating to client investments and the performance resulting from such decisions may differ from client to client. Parkview will not necessarily purchase or sell the same securities at the same time or in the same proportionate amounts for all eligible clients, particularly if different clients have selected different investment profiles, have materially differ- ent amounts of capital under management with Parkview or different amounts of investable cash available. In certain instances, such as purchases of less liquid publicly traded securities (as some small cap securities frequently are) or oversubscribed pub- lic offerings, it may not be possible or feasible to allo- cate a transaction pro rata to all eligible clients, espe- cially if clients have materially different sized portfo- lios. Therefore, not all clients will necessarily partici- pate in the same investment opportunities or partici- pate on the same basis. Use of Soft Dollars Parkview may maintain soft dollar arrangements, and to the extent it does it will only do so in accordance with the conditions of the safe harbor provided by Section 28(e) of the Exchange Act. Section 28(e) is a “safe harbor” that permits an investment manager to use brokerage commissions or “soft dollars” to obtain research and brokerage services that provide lawful Because Parkview’s clients maintain accounts at dif- ferent custodian banks and because these custodian banks mandate the use of a specific broker, often Parkview US places more than one block trade for the same security with more than one broker. Parkview US transmits such block trades to more than one bro- ker in a random pattern (i.e., Parkview US does not fa- vor one custodian bank or broker over another with respect to the order in which block trade orders are sent). The average price realized on a securities or- der placed with different brokers will vary from bro- ker to broker, and clients generally will receive differ- ent average prices and transaction costs for the same security order depending upon the custodian bank 9  Parkview Ltd, CRD 160171 10 March 2025 and appropriate assistance in the investment deci- sion-making process. The consequences and the required corrective measures may be different depending upon the na- ture of the error or the account affected. Item 13. Review of Accounts All client accounts are reviewed at least quarterly in an effort to ensure that they remain aligned with the client’s investment policy and are positioned appro- priately given current market conditions as part of Parkview’s general investment process. Research services within Section 28(e) may include, but are not limited to, research reports (including market research); certain financial newsletters and trade journals; software providing analysis of securi- ties portfolios; corporate governance research and rating services; attendance at certain seminars and conferences; discussions with research analysts; meetings with corporate executives; consultants’ ad- vice on portfolio strategy; data services (including ser- vices providing market data, company financial data, certain valuation and pricing data and economic data); and advice from brokers on order execution. Item 14. Client Referrals and Other Compensation Parkview may pay fees for client referrals. Such ar- rangements comply with the conditions and require- ments of Rule 206(4)-1 under the Investment Advisers Act of 1940. Parkview may receive client referrals from its affili- ated entities, including but not limited to CFEG Parkview Financial Solutions GmbH. Parkview does not pay a referral fee to its affiliated entities. How- ever, there may be financial incentives for Parkview to favor affiliated service providers over non-affiliated service providers as described further in Item 10. Brokerage services within Section 28(e) may include, but are not limited to, services related to the execu- tion, clearing and settlement of securities transac- tions and functions incidental thereto (i.e., connectiv- ity services between an investment adviser and a bro- ker-dealer and other relevant parties such as custodi- ans); trading software operated by a broker-dealer to route orders; software that provides trade analytics and trading strategies; software used to transmit or- ders; clearance and settlement in connection with a trade; electronic communication of allocation instruc- tions; routing settlement instructions; post trade matching of trade information; and services required by the SEC or a self-regulatory organization such as comparison services, electronic confirms or trade af- firmations. Trade Errors Although Parkview’s goal is to execute trades seam- lessly in the manner intended by the client and con- sistent with its investment decisions, Parkview recog- nizes that errors can occur for a variety of reasons. Parkview’s policy in dealing with such errors is to: ▪ Identify any errors in a timely manner. Parkview may receive remuneration from third par- ties in connection with its investment advisory ser- vices. Such remuneration can include referral fees, marketing fees, discounts, finder’s fees, service fees, including shareholder service fees, 12b-1 fees or bo- nus commissions paid by mutual funds, privately of- fered funds, insurance products, variable annuities or other investment products paid to Parkview for rec- ommending an investment, for investing client funds in such product or for marketing assistance or the performance of certain administrative tasks associ- ated with making an investment. Such remuneration received by Parkview from third parties belongs to the client and if retained by Parkview will reduce the fee payable by the client to Parkview. ▪ Correct all errors so that any affected account is placed in the same position it would have been in had the error not occurred. ▪ Parkview’s employees or associated persons may be invited to attend seminars and meetings with the costs associated with such meetings borne by a spon- soring brokerage firm or other party extending the in- vitation. Incur all costs associated with correcting an error (or to pass the costs on to the broker, depending on which party is at fault). Costs from corrective actions are not to be passed on to a client. Item 15. Custody ▪ Evaluate how the error occurred and assess if any changes in any processes are warranted or if any continuing education is required. Parkview typically is given authority to have its fees directly deducted from a client’s account. Conse- quently, Parkview is deemed to have custody of such funds. Parkview has established procedures to en- 10  Parkview Ltd, CRD 160171 10 March 2025 Proxy Voting Parkview generally does not have the authority to vote client proxies. Clients make arrangements di- rectly with their custodian to vote proxies for securi- ties or where proxy or other solicitation materials have to be sent to. If Parkview inadvertently receives any proxy materials on behalf of a client, Parkview will promptly forward such materials to the client. sure the client’s account is held at a qualified custo- dian in a separate account for each client. The client establishes the bank account directly and therefore is aware of the qualified custodian’s name, address and the manner in which investments are maintained. Ac- count statements are prepared by the custodian bank and delivered directly to the client or the client’s rep- resentative at least quarterly. Generally, these state- ments include a listing of all valuations and all trans- actions occurring during the period. Clients should carefully review these statements and when they have questions contact either Parkview or the custo- dian bank. The custodian bank also provides the cli- ent with all required year-end tax information. Parkview will exercise investment authority for cer- tain corporate actions (such as, but not limited to, tenders, rights offerings, splits, etc.) in connection with discretionary accounts. For advisory clients, cor- porate actions are discussed with them prior to the event taking place. Clients who have questions about proxies may con- tact Parkview for further information. Class Actions Parkview does not direct client participation in class action lawsuits. Parkview also may provide performance information to advisory clients about the client’s performance, which may also include a reference to a relevant mar- ket index or benchmark. Parkview may provide re- ports analyzing the sources of each account’s perfor- mance, including customary performance attribution and risk measurement statistics such as standard de- viations, Sharpe ratios, deviations from benchmark returns, and investments that had the largest positive and negative impacts on performance. Item 16. Investment Discretion Parkview will determine whether to return any docu- mentation inadvertently received regarding clients’ participation in class actions to the sender, or to for- ward such information to the appropriate clients. Parkview accepts discretionary authority to manage client accounts as described above. Parkview will not advise or act on behalf of clients in any legal proceeding, including bankruptcies or secu- rities shareholder class action litigation involving se- curities held or previously held in client accounts. Ac- cordingly, Parkview is not responsible for responding to, or forwarding to clients, any class action settle- ment offers relating to securities currently or previ- ously held in the client account. Item 18. Financial Information Clients rarely restrict the authority by which Parkview may act; however, each client has the opportunity to communicate any form of limitation in writing. In the context of a discretionary mandate, Parkview makes investment decisions without consulting the client by utilizing its limited power of attorney for the manage- ment of the account maintained at the custodian bank selected by the client. In the context of a non- discretionary mandate, Parkview’s investment discre- tion is limited to an advisory role and Parkview does not implement investment decisions without the ap- proval of the client. Parkview never has discretionary authority to select a qualified custodian for a client’s account. Parkview has not been the subject of a bankruptcy petition at any time. As of the date of this brochure we do not believe it is reasonably likely that any fu- ture liability will impact our ability to meet our con- tractual commitments to our clients. Item 17. Voting Client Securities 11