Lowell, Blake & Associates, Inc. (LBA or firm or we) is a fee-only with its principal place of business located in Boston, Massachusetts. The firm was founded in 1974. Current shareholders include: Nicole F. Gagliardi, Diana B. Malcom, and Jessica C. Welch. Portfolio Management Services LBA manages individually tailored investment portfolios. We provide continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy or investment plan and create and manage a portfolio based on that policy or plan. During our information- gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history and current investment holdings, as well as family composition and background. We manage advisory accounts primarily on a discretionary and non-discretionary basis. For discretionary accounts we obtain limited power of attorney from clients in the investment advisory agreement to effect trades without prior client consent. For these non-discretionary accounts, we will seek prior client consent for every contemplated transaction. Therefore, clients with non-discretionary accounts should understand that any delay in obtaining consent may result in less favorable transaction terms, including higher security price and/or higher commissions and/or limited availability of the securities sought. Account supervision is guided by the stated objectives of the client (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Consulting Services 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, tax, portfolio analysis on a periodic basis, retirement planning, insurance issues, annuity advice, or any other specific topic. Trustee Services In limited circumstances, we offer private trustee services to clients. Services in General Our investment advice is not limited to any specific product or service offered by a broker dealer or insurance company and will primarily include advice regarding the following instruments:
• Domestic and foreign equity securities
• Domestic and foreign fixed income securities Occasionally, we may also advise clients on the following instruments:
• Commercial paper
• Certificates of deposit
• Variable life insurance
• Variable annuities
• No-load or

load-waived mutual funds
• Exchange Traded Funds (ETFs)
• Private placement securities and pooled investment vehicles Tailored Relationships We tailor all of our investment advice to the individual needs of each client. All such recommendations are tailored based on information gathered through client questionnaires, electronic communications and telephone and in-person discussions. 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 LBA does not participate in a wrap fee program. Client Assets As of January 31, 2023, we managed $596,558,143 in assets under management; $544,818,221 managed on a discretionary basis and $51,739,922 managed on a non-discretionary basis.