Information about the Firm We are an independent and privately-owned registered investment advisor founded in Boston in 1979. Our sole business is serving high-net-worth individuals and families of substantial wealth, as well as foundations, business entities, and endowments. Our team of seasoned investment management and wealth planning specialists gives each client customized strategies and solutions for preserving and growing their irreplaceable assets. Our principal owners are Michael W. Delduchetto and Marc H. Ohler. Advisory Services Investment Management Services We believe our primary investment criterion is the safety of each client’s irreplaceable assets while maximizing risk-adjusted returns over a multi-year horizon. Our disciplined investing style employs a consistent and rigorous analytical work ethic where equal amounts of time are spent on risk assessment as well as return. Many clients utilize our investment experience to help develop, plan and implement prudent investment strategies across assets that we both manage and those that we do not manage. These services often include tax-efficient investing, strategic gifting, concentrated asset strategies, risk management, and cash flow analysis. We are accustomed to working with clients’ other service providers including other asset managers, financial planners, trustees, lawyers, and accountants. We develop a specifically tailored investment strategy for each individual client and portfolio through a rigorous analysis of the client’s financial needs and appropriate risk profile. Factors considered 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 offer expertise for client investment management accounts as follows:
• Customized Multi-Asset portfolios utilizing our macro-economic research, and equity and fixed income analytics to produce diversified high-quality portfolios tailored to each client’s individual needs.
• Custom Equity Investing in mainly mid and large-capitalization companies.
• Custom Fixed Income investing in corporate, municipal and government bonds, and cash/liquidity management strategies. We may offer management and counsel 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, exchange traded funds and notes (ETFs/ETNs), derivatives, hedge strategies, option strategies, private equity analysis, oil & gas limited partnerships, and family business ownership. While we do not seek to invest in mutual funds for discretionary managed accounts, some clients may hold mutual funds in their accounts as a legacy inherited asset or as part of a non- discretionary account that we manage. We may also help select other independent managers for clients upon request. These assets are typically held as part of a client’s non-discretionary account. Integrated Financial Planning Services As clients request, we will provide advice in the form of a written financial plan and through ongoing execution and monitoring of the plan. We gather required information through in- depth personal interviews. Meetings are expected to be held on a regular basis. Each meeting will focus, as necessary, on retirement planning, investments, estate planning, and insurance needs. Information gathered includes a client’s current financial status, future goals and attitudes towards risk. Related documents supplied by the client are carefully reviewed, including tax returns, current financial specifics (i.e., W2s or 1099s), information on current retirement plans, insurance information, mortgage information, insurance policies, statements reflecting current investments in the client’s retirement and non-retirement accounts, copies of wills and trusts, as well as any other document that may be deemed pertinent by us. Upon receipt of such documents, we will review the client’s current financial situation and make recommendations based on the client’s current situation, financial expectations, investment objectives, risk tolerance and investment time horizon. A written financial plan will then be prepared and presented to the client along with an outline of suggestions to improve the client’s current financial situation together with suggested steps to help the client reach their investment goals. In general, the written financial plan will address any or all of the following areas of concern: Personal: Family records, budgeting, personal liability, estate information and financial goals. Tax & Cash Flow: Income tax and spending analysis and planning for past, current and future years. We will illustrate the impact of various investments on a client’s current income tax and future tax liability. Death

& Disability: Cash needs at death, income needs of surviving dependents, estate planning and disability income analysis. Retirement: Analysis of current strategies and investment plans to help the client achieve his or her retirement goals. Investments: Analysis of investment alternatives and their effect on a client’s portfolio. Implementation of financial plan recommendations is entirely at the client’s discretion. Financial planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. In performing our services, we will not be required to verify any information received from the client or from the client’s other professionals, and we are expressly authorized to rely thereon. If requested by the client, we may recommend the services of other professionals for implementation services. The client is under no obligation to engage the services of any such recommended professional. As part of the integrated financial planning services that we offer, a client may also opt to have us provide asset allocation and portfolio monitoring services. At a client’s request investments chosen can be mutual funds offered by a selection of mutual fund families. These mutual funds will be purchased on a “no-load” or “load-waived” basis or exchange-traded funds (ETFs). As part of the integrated financial planning services that we offer, a client may also opt to have us provide money manager search and monitoring services. A selection of managed account programs is also available through our relationships with outside money managers. The programs and fees will be described in detail in the individual money manger’s Form ADV Part 2 and related schedules. The management fee charged by the money manager recommended to the client is separate from the fee charged by us and is disclosed in the money manager’s disclosure document (Form ADV Part 2). Clients can also receive investment advice on a more limited basis. This may include advice on only an isolated area(s) of concern such as estate planning, retirement planning, reviewing a client’s existing portfolio, or any other specific topic. Additionally, we provide advice on non- securities matters. Generally, this is in connection with the rendering of estate planning, insurance, and/or annuity advice. Individual Advice; Restrictions on Investing The core of our business is the creation and management of customized multi-asset and high- quality custom portfolios. Each portfolio is customized according to client-specific objectives and is managed by our team of portfolio managers. We are experienced in handling the distinct needs of high-net-worth individuals, complex families, trusts, foundations, and endowments. Clients may impose restrictions on investing in certain industry sectors and types of securities purchased. Such restrictions must be provided to us in writing. 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, 2023, we have $606,399,680 of regulatory assets under management. Of these, $600,616,326 are managed on a discretionary basis and $5,783,354 are managed on a non-discretionary basis.