Boston Hill Advisors, LLC is an SEC registered investment adviser based in North Andover,
Massachusetts. Our firm is organized as a limited liability company under the laws of the
Commonwealth of Massachusetts. We have been providing investment advisory services since 2006.
Joseph J. Trainor and Michael F. Edwards are our principal owners.
As used in this brochure, the words "we", "our" and "us" refer to Boston Hill Advisors, LLC and the
words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you
may see the term Associated Person throughout this brochure. As used in this brochure, our
Associated Persons are our firm's officers, employees, and all individuals providing investment advice
on behalf of our firm.
We provide an extensive range of investment advisory services by integrating wealth management
with solutions that leverage our expertise in financial planning, investment management, educational
seminars, and corporate benefits. We have a disciplined investment process that is results oriented,
and we help formalize our client's vision for their retirement, family, business and/or charity in a holistic
financial plan. Through our investment advisory services, we work with our clients in an effort to build a
customized investment strategy to meet their individualized goals and objectives, and continuously
monitor the integration of the plan with investment results.
I. ASSET MANAGEMENT PROGRAMS
We offer asset management programs consisting of asset allocation strategies. Programs include
investment strategies appropriate for your specific circumstances and objectives. We assist you in
reviewing information about available programs, completing a client questionnaire to determine your
risk tolerance and objectives and selecting an investment strategy. We maintain regular contact with
you and review and monitor your portfolios on an ongoing basis to determine if there have been
changes in your financial situation that may affect the appropriateness of your investment strategy and
to determine whether adjustments to a portfolio are necessary to achieve the chosen investment
strategy. You will receive monthly account statements and quarterly performance statements, as
described in more detail below at the Review of Accounts section.
BHA Managed Accounts
Under our BHA Managed Accounts Program, we manage discretionary fee-only brokerage accounts
for client relationships of $500,000 or more. For such accounts, we act as the advisor on an internally
managed asset allocation program using portfolios of no-load or load-waived mutual funds, ETFs and
individual securities. We are responsible for security selection and asset allocation within these
accounts based on your established risk tolerance. These accounts are held in custody at Charles
Schwab & Co., Inc., TD Ameritrade, Inc. or a custodian chosen by you and agreed to by our firm. You
will enter into a separate custodial agreement with the designated custodian. Refer to the Brokerage
Practices section below for additional disclosures on this topic.
II. RETIREMENT PLAN SERVICES
We provide investment advisory services for tax qualified Simple Individual Retirement Account Plans
and 401(k) Retirement Plans. For plans that offer employees a "menu" of investments for investing
their retirement funds, we will assist the employer in selecting investment options that are suitable to
the full range of investment objectives and risk tolerances of the employees participating in the plan.
We will also assist employees in completing a questionnaire to determine their risk tolerance and
investment objectives and, based on the results of the questionnaire, will assist them in choosing
suitable investments from the available options within the Plan. In addition, we may provide (at no
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charge) assistance to a company in establishing a Simple IRA Plan. We may establish a withholding
arrangement with a custodian for the company, and we can assist interested employees in setting up
individual retirement accounts.
We do not provide retirement plan administration services and we do not maintain any relationships
with or otherwise recommend the use of any third party administrators to provide administration
services for employer sponsored 401(k) plans. We do not receive any compensation from any
custodian, broker-dealer, third-party administrator, or other service provider in relation to our retirement
plan investment advisory services. We recommend that employers utilize Charles Schwab for custodial
and trade execution services, because of the breadth of securities that may be traded on the Charles
Schwab platform and the customer service provided by Charles Schwab to the employer, the
employees and to our firm. However, the employer is free to utilize the services of an alternative
custodian should they so choose. Custodial fees and trade execution fees charged by the custodian
vary depending on the type of securities offered as investment options under the plan and the number
of trades executed within the retirement account. Employers may choose to utilize one of the risk-
adjusted investment models offered by our firm under our BHA Managed Accounts Program (as
described more fully above) however we do not receive any additional fees for use of such investment
models.
III. GENERIC FINANCIAL SEMINARS
We offer financial seminars both directly to the public and through educational institutions and
employers. These seminars entail generic discussions of stocks, bonds,
mutual funds, insurance and
other financial planning and wealth management topics. Fees may or may not be charged for
attendance at the seminars. When fees are charged, they typically consist of a nominal fee to cover
the cost of seminar materials, and generally range from $0.00 to $199.00 per person. These fees are
not negotiable and are payable on the day of the first seminar. At the conclusion of the seminar, you
may choose to receive an individual consultation with an Associated Person of our firm to discuss your
financial needs. There is never a charge for an individual consultation and participants in both the
seminars and individual consultations are not obligated to work with our firm or any of our Associated
Persons for investment advisory services. If you subsequently purchase any securities products or
investment advisory services through our firm, this may result in your paying our firm separate and
additional fees. As part of the financial needs analysis in individual consultations, we generally include
advice to you on matters not involving securities, such as life insurance, and we may participate in
consultations with your other financial advisors, such as your CPA/accountant or attorney.
IV. FINANCIAL PLANNING AND CONSULTING SERVICES
A. Financial Planning Services
We provide financial planning services in the form of the preparation of individualized financial plans.
Financial plans are based upon your individual circumstances and may address such goals as building
wealth, financial education, retirement planning, estate planning, and business planning and insurance
strategies. You may obtain a broad-based financial plan or a focused plan concentrating on certain
specified goals. The plan may include general recommendations about investment strategies.
Generally, the preparation of a financial plan is a one-time service, and any services that you may
obtain from us following the preparation of the plan, including plan updates, constitute separate and
distinct services that may be subject to additional fees.
B. Financial Consulting Services
We offer financial consulting services that focus on a particular investment and/or business issue.
These services typically involve financial planning for businesses or address discrete financial-related
business issues that may arise for an investment advisory client.
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Termination of Services Information
Either party may terminate the contract by providing a written notice to the other party. The
management fee will be pro-rated for the quarter in which the cancellation notice was given and any
unearned fees will be refunded to the client. At our discretion, you may be charged under the
consultation services method (disclosed above) if the length of the relationship is less than 6 months.
Accuracy of Client Information
In providing the contracted services, we are not required to verify any information we receive from you
or from your other professionals (e.g. attorney, accountant, etc.) and we are expressly authorized to
rely on the information you provide. You must promptly notify our firm if your financial situation, goals,
objectives, or needs change for the purpose of reviewing, evaluating, and/or revising our previous
recommendations and/or services.
Types of Investments
We offer advice on mutual funds, exchange traded funds, and a variety of other types of investments
since each client has different needs and different tolerances for risk. We may also advise you on any
type of investment held in your portfolio at the inception of our advisory relationship, or on specific
types of investments at your request.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries 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 your interests, so we operate under a
special rule that requires us to act in your best interest and not put our interest ahead of yours. Under
this special rule's provisions, we must:
Meet a professional standard of care when making investment recommendations (give prudent
advice);
Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
Charge no more than is reasonable for our services; and
Give you basic information about conflicts of interest.
We benefit financially from the rollover of your 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 we believe it is in
your best interest.
Assets Under Management
As of February 14, 2023, we manage $948,301,971 in client assets on a discretionary basis, and
$40,031,045 in client assets on a non-discretionary basis.
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