INTRODUCTION St. Germain Investment Management, Inc. is a Massachusetts corporation, and is registered with the United States Securities and Exchange Commission (SEC) as an investment adviser under the Investment Advisers Act of 1940. St. Germain Investment Management, Inc. is a wholly owned subsidiary of D.J. St. Germain Co., Inc. D.J. St. Germain Co., Inc. also has 100% ownership of an affiliated subsidiary, St. Germain Securities, Inc., which is registered as a Broker Dealer with FINRA and the MSRB. St. Germain Investment Management, Inc. was incorporated in August of 2010, and succeeded the IA business of D.J. St. Germain Co., Inc., which was founded in 1924. October Mountain Financial Advisors, located in Lee, MA, is a d/b/a of St Germain Investment Management, Inc. In 2019, D.J. St Germain Co., Inc. acquired the assets of Gage-Wiley & Co., Inc. (established 1933), a FINRA registered Broker Dealer, and its affiliated registered investment adviser, New England Capital (NEC). New England Capital operates as a d/b/a of St Germain Investment Management, Inc. D.J. St. Germain Co., Inc. is the primary owner of St. Germain Investment Management, Inc.
Officers include Michael Matty, as President, Timothy Suffish as Director, and John “Trey” Fortier as Treasurer.
Assets under management (as of December 31, 2023) are: U.S. Dollar Amount Discretionary: Non-Discretionary: Total: This Form ADV, Part II and narrative provides clients with information regarding St. Germain Investment Management, Inc. and its advisory services that should be considered before becoming a client of St. Germain Investment Management, Inc. This narrative also provides information about the qualifications and business practices of St. Germain Investment Management, Inc. The information in this narrative has not been approved or verified by the SEC or by any state securities authority. Additional information about St. Germain Investment Management, Inc. is also available on the Internet at www.adviserinfo.sec.gov by accessing Part 1 of St. Germain Investment Management, Inc.'s Form ADV or by accessing the firm’s Part 3 Customer Relationship Summary. You can search this site by a unique identifying number, known as a CRD number. The CRD number for St. Germain Investment Management, Inc. is 155186. $2,649,897,368 $49,141,277 $2,699,038,645 INVESTMENT MANAGEMENT SERVICES St. Germain Investment Management, Inc. primarily provides discretionary investment management (portfolio management) services for individuals, businesses, non-profit charitable organizations, and institutional clients, as well as financial planning services. Investment Management Process Investment management services are based on each client's individual goals and circumstances. Our investment advisors and/or financial planners consult with individual clients to help identify a specific investment strategy that aligns with each client’s financial profile and long-term goals, and will take into consideration a client’s personal financial circumstances, investment objectives, cash flow needs, liquidity requirements, investment time horizon, and risk profile. Investment strategies are typically incorporated into a model portfolio format, which targets a range of asset allocation and security selection models created to achieve primary investment objectives, including long-term growth, growth and income, balanced, equity income, income, and others. Individual client portfolios may have variances from models based on individualized circumstances, risk profile, client restrictions, tax considerations, or the timing of when the account is established. Both quantitative and qualitative criteria are utilized in determining asset allocation and security selection decisions, and ongoing oversight of each portfolio. Asset allocation and/or security selections will be adjusted from time to time in order to better achieve the intended investment objectives of each portfolio. St. Germain Investment Management, Inc.’s portfolio management services are organized and made available to clients in the following ways: Separately Managed Accounts (SMA) These accounts are actively managed, diversified portfolios of individual securities constructed in a manner consistent with the investment objectives of the client. Portfolio holdings may include common stocks, securities convertible into common stocks, preferred stocks, corporate debt obligations, municipal bonds, United States Government or agency bonds. Exchange traded funds (ETFs) and no-load or load-waived mutual funds, foreign and domestic, may be used for efficiency and diversification purposes when suitable. Stock options, variable annuities, or other assets not listed may be used by agreement and approval of the Advisor and the client. Portfolios are managed on a discretionary basis. Asset allocation and individual security selection decisions are made as determined to be consistent with client investment objectives. These portfolios are typically reserved for accounts with a minimum of $250,000. Mutual Fund/ETF Managed Portfolios These are diversified

portfolios of no-load or load-waived mutual funds and exchange traded funds (ETFs) constructed in a manner consistent with the investment objectives of the client. Portfolio positions may include actively managed or passive index funds, domestic and foreign. Investment theme or sector-specific funds may be used, including funds that fall into the category of “ESG” investing, which integrate Environmental, Social, and Governance factors into the investment process and decision making. ESG investing is a term often used interchangeably with “SRI” (Socially Responsible) and Sustainable Investing. In certain circumstances portfolio positions may also include individual securities listed under SMA (above), subject to approval of St Germain Investment Management, Inc. and suitability with the client profile and investment objectives. Portfolios are managed on a discretionary basis, with asset allocation and/or fund selection decisions made as determined to be consistent with client investment objectives. These portfolios are typically reserved for accounts of $100,000 or more. Wrap Fee Advisory Programs Wrap Fee Accounts are investment accounts where a single “wrapped” fee covers all management, brokerage, and administrative expenses. It should be noted that this fee does not include fees and expenses that represent the imbedded internal costs of mutual funds or exchange traded funds that may be held in the portfolio. St. Germain Investment Management, Inc. does not directly sponsor or manage wrap fee accounts, but provides them to our clients through service agreements we hold with clearing firms and custodians that custody our clients assets. These may include wrap fee advisory services sponsored by Wells Fargo Advisors, LLC, Charles Schwab, BNY Mellon Pershing, and Morningstar Managed Portfolios Program. As discussed in Item 14 below, St. Germain Investment Management receives revenue from these providers pursuant to these arrangements, posing a conflict of interest. Based upon a review of a client’s financial profile, investment objectives, and risk tolerance, along with other pertinent information, St Germain Investment Management, Inc. identifies an appropriate asset allocation and investment management strategy suitable for the client, and then matches that strategy with a wrap fee program suitable to the client’s investment objective. St. Germain Investment Management, Inc. evaluates and monitors the wrap fee program to ensure compliance and consistency with the client’s objectives. Specific wrap fee programs available from the wrap fee sponsors vary in scope, strategy, and costs, and require a separate application process that is specific to each program. St. Germain Investment Management, Inc. guides clients through the application process, and provides clients with all necessary information and disclosures related to the wrap program, including full disclosure related to all fees, investments risks, and suitability. St. Germain Investment Management, Inc. offers access to wrap fee accounts to clients who prefer the wrap fee structure, or to provide access to investment strategies that are otherwise unavailable through our in-house offerings. Minimum account size is $100,000. Financial Planning Through personal discussions in which goals and objectives based on a client's particular circumstances are established, St. Germain Investment Management, Inc. may develop a customized financial plan for clients, in addition to managing their investment portfolio. Working collaboratively with clients, we provide guidance in establishing clearly defined personal financial objectives, and specific strategies for achieving those goals. Areas addressed in the financial planning process are those most relevant to the individual client, and may include areas such as budgeting and cash flow planning, asset and liability assessments, retirement planning, Social Security, pension and retirement income strategies, debt management, tax planning, risk management and insurance, long term care, estate planning, philanthropic strategies, investment analysis and portfolio reviews. We encourage clients to work closely with their attorney, accountant and other appropriate advisors as needed. Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. All investment recommendations are generic in nature, but tailored to client needs determined by the financial plan. St. Germain Investment Management, Inc. may provide additional general business and securities consulting services to clients as part of its financial planning services. These services may include, but are not limited to, advice on business planning, business successions and mergers, insurance needs, coordination of the structures of business plans and companies, meetings with client lawyers to assist with estate planning and accountants to assist with tax planning. Fees for Financial Planning services are typically covered by our management fees. We reserve the right to charge separately for such services as conditions may warrant.