Information about the Firm We are an independent and privately-owned registered investment advisor founded in Boston in 1964. Our sole business is serving high-net-worth individuals and families of substantial wealth, as well as foundations, business entities, and endowments. Principal owners of our Firm are Christopher A. de Roetth (50%) and Account Management Holdings, LLC (50%). Ownership of Account Management Holdings, LLC are Christopher A. de Roetth (66%) and Elisabeth (de Roetth) Abbe (33%). Advisory Services Factors considered during security selection for each client include the level of investment assets, current asset allocation, liquidity of investment and other assets, investment time horizon, asset concentration, cash flow needs, income level, employment situation, contingent assets, risk tolerance, and tax situation. An initial asset allocation and investment strategy is developed from this review and analysis. We continually monitor the investment strategy along with the client’s broader evolving financial situation so that adjustments can be made in the context of a constantly changing capital markets environment. We are accustomed to working with clients’ other service providers including other asset managers, financial planners, trustees, lawyers, and accountants. We are focused primarily on public North American equities. We consult with clients regarding their financial needs and risk tolerance. Generally speaking, the bulk of our equity investments are in what we believe are stable, growing enterprises with the potential for capital appreciation. We may offer advice on U.S. equity (common and preferred stocks), international equities, American depository receipts, debt securities of the U.S. government and its agencies, municipal bonds, corporate bonds, floating rate and variable rate obligations, inflation- protected debt securities, structured notes, mutual funds, exchange traded funds and notes (ETFs/ETNs), derivatives, hedge strategies, option strategies, private equity analysis, and oil & gas limited partnerships. Individual Advice; Restrictions on Investing Clients may impose restrictions on investing in certain industry sectors and types of securities purchased. Fiduciary Statement We are fiduciaries under the Investment Advisers

Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act, (“ERISA”) and/or the Internal Revenue Code, (“IRC”), as applicable, which are laws governing retirement accounts. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs We do not sponsor or recommend Wrap Fee Programs. Assets Under Management As of December 31, 2022 we managed $92,337,990 regulatory assets under management on a discretionary basis.