We specialize in the following types of services: comprehensive portfolio management, asset
management, financial planning and consulting, and 3(21) Investment Consulting and 3(38)
Investment Management. All material conflicts of interest are disclosed below regarding our firm,
our representatives or our employees, which could be reasonably expected to impair the rendering
of unbiased and objective advice.
We are dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a corporation formed in the State of Massachusetts in
February 2008. Our firm has been in business as an investment adviser since 2010 and is wholly
owned by Robert Keenan Gustafson.
Description of the Types of Advisory Services We Offer
Comprehensive Portfolio Management
Our Comprehensive Portfolio Management service encompasses asset management as well as
providing financial planning/financial consulting to clients. It is designed to assist clients in meeting
their financial goals through the use of financial investments. We conduct at least one, but
sometimes more than one meeting (in person if possible, otherwise via telephone conference) with
clients in order to understand their current financial situation, existing resources, financial goals,
and tolerance for risk. In these meetings, we gather relevant information on the client’s available
money on hand needed in an emergency, existing debt structure on their home and other assets,
individual and group insurances (ie: life, disability, long term care, home, auto and liability), wills
and trusts, state and federal tax returns, ownership arrangements of assets, investments
statements, retirement planning (ie: IRAs, Roth IRAs, pensions, profit sharing plans, 401(k) plans,
etc), employee stock options and grants, and social security. Based on what we learn, we propose
an investment approach to the client. We may propose an investment portfolio, consisting of
exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the
client’s agreement to the proposed investment plan, we work with the client to establish or transfer
investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are
under our management, we review such accounts on a regular basis. We may periodically rebalance
or adjust client accounts under our management. If the client experiences any significant changes to
his/her financial or personal circumstances, the client must notify us so that we can consider such
information in managing the client’s investments.
Asset Management:
We emphasize continuous and regular account supervision. As part of our asset management service,
we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds
(“ETFs”), options, mutual funds and other public and private securities or investments. The client’s
individual investment strategy is tailored to their specific needs and may include some or all of the
previously mentioned securities. Each portfolio will be initially designed to meet a particular
investment goal, which we determine to be suitable to the client’s circumstances. Once the appropriate
portfolio has been determined, we review the portfolio periodically and if necessary, rebalance the
portfolio based upon the client’s individual needs, stated goals and objectives. Each client has the
opportunity to place reasonable restrictions on the types of investments to be held in the portfolio.
Clients entering into our Asset Management service are generally required to complete and pay for a
financial plan, apart from their Asset Management services. This is a one time fee, and thereafter such
clients are entitled to the annual updates to their financial plan that are described in our
Comprehensive Portfolio Management offering in addition to the Asset Management services.
Our firm utilizes the sub-advisory services of a third party investment advisory firm or individual
advisor to aid in the implementation of an investment portfolio designed by our firm. Before
selecting a firm or individual, our firm will ensure that the chosen party is properly licensed or
registered. Our firm will not offer advice on any specific securities or other investments in connection
with this service. We will provide initial due diligence on third party money managers and ongoing
reviews of their management of client accounts. In order to assist in the selection of a third party
money manager, our firm will gather client information pertaining to financial situation, investment
objectives, and reasonable restrictions to be imposed upon the management of the account.
Our firm will periodically review third party money manager reports provided to the client at least
annually. Our firm will contact clients from time to time in order to review their financial situation
and objectives; communicate information to third party money managers as warranted; and, assist
the client in understanding and evaluating the services provided by the third party money manager.
Clients will be expected to notify our firm of any changes in their financial situation, investment
objectives, or account restrictions that could affect their financial standing.
Asset Management Services through American Funds:
As part of this service, we manage portfolios consisting of mutual funds available through American
Funds (“AF”), a family of funds available from the Capital Group. We will not evaluate any type of
security other than mutual funds offered by AF. Portfolios will be designed to meet a particular
investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio
has been determined, portfolios are continuously and regularly monitored, and if necessary,
rebalanced based upon the client’s individual needs, stated goals and objectives. Each client has the
opportunity to place reasonable restrictions on the types of investments to be
held in the portfolio.
Investment strategies available through this service are limited to mutual funds offered through the
AF family of funds.
Financial Planning and Consulting:
We provide a variety of financial planning and consulting services to individuals, families and other
clients regarding the management of their financial resources based upon an analysis of client’s
current situation, goals, and objectives. Generally, such financial planning services will involve
preparing a financial plan or rendering a financial consultation for clients based on the client’s
financial goals and objectives. This planning or consulting may encompass one or more of the
following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning,
Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate
Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit
Evaluation, Business and Personal Financial Planning.
Our written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients. For example,
recommendations may be made that the clients begin or revise investment programs, create or
revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or
establish education or charitable giving programs. It should also be noted that we refer clients to an
accountant, attorney or other specialist, as necessary for non-advisory related services. For written
financial planning engagements, we provide our clients with a written summary of their financial
situation, observations, and recommendations. For financial consulting engagements, we usually do
not provide our clients with a written summary of our observations and recommendations as the
process is less formal than our planning service. Plans or consultations are typically completed
within six (6) months of the client signing a contract with us, assuming that all the information and
documents we request from the client are provided to us promptly. Implementation of the
recommendations will be at the discretion of the client.
3(21) Investment Consulting:
This service consists of assisting employees with monitoring and reviewing their company's
participant-directed retirement plan. As the needs of the clients dictate, areas of advising could
include:
• Market overview addressing the major markets, indices, sectors and the economic statistics
that are affecting them;
• An in-depth portfolio summary, including fund and benchmark returns, style analysis and
overall portfolio return;
• Assist with selection and monitoring of investment options at the plan level;
• A detailed examination of each mutual fund investment option within the plan, including
performance numbers versus the category and index, manager style drift, risk/return,
standard deviation, Sharpe ratio, upside and downside capture and fund allocation. This
Agreement does not guarantee the future performance or results of any investment option
recommended or reviewed.
Adviser will conduct strategic planning sessions to review current performance (annual reports)
and establish future objectives and strategies for the Plan.
In performing the foregoing Services, Adviser acknowledges that it will be acting as a 3(21)
fiduciary to the plan pursuant to Employee Retirement Income Security Act of 1974, as amended
(“ERISA”) and the Investment Advisers Act of 1940. However, Client acknowledges that Adviser
does not maintain discretionary authority over the administration of the Plan, the establishment of
the Plan’s investment policy or the selection of the Plan’s investment platform. Adviser does not
have the authority to interpret the Plan or determine eligibility of participants and is not the Plan
Administrator as defined in ERISA. Additionally, Adviser will not have any authority and does not
assume any responsibility with respect to firm’s stock or self-directed brokerage accounts.
3(38) Investment Management:
Our firm represents that it is a registered investment adviser and qualifies as an investment
manager under Section 3(38) of ERISA, and that it is a fiduciary to the Plan within the meaning of
ERISA. Adviser is authorized by the client to exercise its best judgment in investing, selling and
reinvesting the cash and securities in the Account in its discretion. Adviser will not hold any assets
of the Plan, all of which will be held by an independent custodian selected by client.
We shall have discretion over the establishment of the Plan’s investment policy, the prudent
selection, monitoring, removal and replacement of the Plan’s investment options. Adviser agrees
that it will be serving as a fiduciary to the Plan under ERISA in performing these functions.
We shall provide investment education to Plan participants regarding the selection of Model
Portfolios and will survey each plan participant to assess the individual’s risk profile that will assist
in the selection of an appropriate portfolio.
Tailoring of Advisory Services
We offer individualized investment advice to clients utilizing the following services offered by our
firm: Comprehensive Portfolio Management and Asset Management. Additionally, we offer general
investment advice to clients utilizing the following services offered by our firm: Financial Planning
and Consulting, 3(21) Investment Consulting and 3(38) Investment Management.
We usually do not allow clients to impose restrictions on investing in certain securities or types of
securities due to the level of difficulty this would entail in managing their account.
Participation in Wrap Fee Programs
We do not offer wrap fee programs.
Regulatory Assets Under Management
As of December 31, 2023, we manage $232,634,678 on a discretionary basis and $4,520,030 on a
non-discretionary basis.