Boston Asset Management, Inc. (“BAM,” “us”, “we”, “our”) is a corporation organized under the laws of the State of Florida on July 13, 1992, and majority owned by Leo J. Govoni along with Elizabeth S. Sauer and Brett J. Walrath. We have been registered investment adviser since February 3, 1993. We are an registered investment adviser notice filed with the states of Florida, New Hampshire, and Massachusetts. We provide the investment advisory products and services described within this document. As of December 31, 2023, we have $103,671,136 of assets under management managed on a discretionary basis and $0 managed on a non-discretionary basis. This Disclosure Brochure provides you with information regarding our qualifications, business practices, and the nature of advisory services that should be considered before becoming our advisory client. Please contact Brett J. Walrath, CCO, if you have any questions about this Brochure. Individuals associated with us will provide our investment advisory services. These individuals are appropriately licensed and qualified to provide advisory services on our behalf with a FINRA Series 7 and 66, or 65, or CFA, CFP, ChFC, CIC, or PFS designation, a college degree, or a combination of the above qualifications. We offer investment advisory services primarily to trustees administering special needs and pooled trusts (created pursuant to 42 U.S.C. Section 1396p (d)(4)(A) and (d)(4)(C)) and other fiduciaries who are obligated to invest and manage assets, but do not have the expertise to meet their obligations (for example, guardians and attorneys). In addition, we offer asset and/or account management services to individuals, estates, business owners, corporations, pension and profit-sharing plans, charitable organizations, and high net worth individuals including professional athletes. Below is a description of the investment advisory services we offer. For more detail on any product or service please reference your investment management agreement or contact your BAM Investment Advisory Representative (“IAR”). Investment Supervisory Services We provide continuous and regular investment advisory services to you in connection with establishing and monitoring of your investment objectives, risk tolerance and time horizon. We will manage advisory accounts on a discretionary basis guided by your stated objectives and restrictions. There are typically

five basic types of investment supervisory accounts: Conservative, Moderately Conservative, Moderate, Moderately Aggressive and Aggressive. BAM tailors its investment advice, account investment strategy and risk tolerance based on a personal interview and/or the completion of a client questionnaire. You have the opportunity to place reasonable restrictions or constraints on the way your account is managed; however, such restrictions will affect the composition and performance of your portfolio. For these reasons, performance of the portfolio will not be identical with our average client. IRA Rollover Recommendations For the purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are a fiduciary 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 client interests. We operate under an exemption that requires we act in the clients’ best interest and not put our or our employees’ interests ahead of the clients. Under this exemption, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that we and our employees give advice that is in the clients’ best interest,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when our and our employees believe it is in the clients’ best interest. Wrap Fee Program BAM does not offer Wrap Accounts.