Flagship Wealth Advisors, LLC (hereinafter FWA) is a registered investment advisor located in the
Commonwealth of Massachusetts, which is organized as a Limited Liability Company (LLC) under the laws of
Massachusetts. Flagship was founded in 1998, and is owned and operated Paul V. Ryan Jr., (Principal and Chief
Compliance Officer). FWA employees include independent contractors who have affiliated with FWA as Advisory
Representatives to offer the advisory services programs described in this brochure. This Disclosure Brochure
provides information regarding qualifications, business practices, and the advisory services provided by Flagship.
FWA offers discretionary and non-discretionary advisory services on a fee basis as discussed at Item 5 below to
individuals, high-net worth individuals, trusts, estates, corporations, and 401(k) plans and IRAs of individuals
and their family members, and other business entities. Through a discussion of a client’s personal
circumstances, goals and objectives, we establish a personalized investment policy statement. Before engaging
Registrant to provide investment advisory services, clients are generally required to enter into an Investment
Advisory Agreement with Registrant setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the fee that is due from the client. To
commence the investment advisory process, Registrant will ascertain each client’s investment objective(s) and
then allocate the client’s assets consistent with the client’s designated investment objective(s). Once allocated,
Registrant provides ongoing supervision of the account(s).
For individual retail (i.e., non-institutional) clients, Registrant’s annual investment advisory fee shall
generally (exceptions can occur-see below) include investment advisory services, and, to the extent
specifically requested by the client, financial planning and consulting services. In the event that the client
requires extraordinary planning and/or consultation services (to be determined in the sole discretion of
Registrant), Registrant may determine to charge for such additional services, the dollar amount of which
shall be set forth in a separate written notice to the client.
There is no difference between how FWA manages wrap fee accounts and non-wrap fee accounts. However, if a
client determines to engage FWA on a wrap fee basis (per the wrap program sponsored by Osaic Wealth-see
below), the client will pay a single fee for bundled services (i.e. investment advisory, brokerage, and custody).. If
the client determines to engage FWA on a non-wrap fee basis the client will select individual services on an
unbundled basis, paying for each service separately (i.e. investment advisory, brokerage, custody).
VISION2020 Wealth Management Platform – Advisor Managed Portfolios Program
The Wealth Management Platform – Advisor Managed Portfolios Program (“Advisor Managed Portfolios”)
provides comprehensive investment management of your assets through the application of asset allocation
planning software as well as the provision of execution, clearing and custodial services through Pershing, LLC
(“Pershing”).
Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting, fund profiling and
performance data, and portfolio optimization and re-balancing tools. Utilizing these tools and based on your
responses to a risk tolerance questionnaire (“Questionnaire”) and discussions that we have together regarding,
among other things, investment objective, risk tolerance, investment time horizon, account restrictions, and overall
financial situation, we construct a portfolio of investments for you.
Portfolios may consist of mutual funds, exchange traded funds, equities, options, debt securities, variable annuity
sub-accounts and other investments.
Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally, you have the
opportunity to place reasonable restrictions on the types of investments to be held in the portfolio.
For further Advisor Managed Portfolios details please see the Advisor Managed Portfolios Wrap Fee Program
Brochure. We provide this brochure to you prior to or concurrent with your enrollment in Advisor Managed
Portfolios. Please read it thoroughly before investing.
Commented [JAL1]: If planning is inclusive
VISION2020 Wealth Management Platform – Model Portfolios Program
The Wealth Management Platform - Model Portfolios Program (“Model Program”) offers Clients managed asset
allocation models (“Asset Allocation Models”) of mutual funds, exchange traded funds (“ETFs”) or a combination
thereof diversified across various investment styles and strategies. The Asset Allocation Models are constructed by
managers (“Program Managers”) such as Russell Investment Management Company, SEI Investments Management
Corporation and Morningstar Associates, LLC.
Based upon the risk tolerance of each Client, the Model Program utilizes a system that selects a specific
Asset Allocation Model. After the Asset Allocation Model is chosen, we, with the assistance of the Model
Program sponsor, will open a Model Program account. Your assets will be invested in the specific
investments contained within the recommended Asset Allocation Model. You have the opportunity to place
reasonable restrictions on investments held within the Model Program account.
For further Model Program details, including a full list of Program Managers, please see the Model
Program Wrap Fee Program Brochure. We provide this brochure to you prior to or concurrent with your
enrollment in the Model Program. Please read it thoroughly before investing.
Personal Financial Planning
You can be furnished assistance in your overall financial planning. The process of developing a strategic financial
plan involves a review and analysis of income, expenses and all current assets followed by the development and
refinement of a personal financial and investment strategy based upon the needs of you and your family. This
information normally would cover present and anticipated assets and liabilities, including insurance, savings,
investments, and current or anticipated employee benefits and retirement plans. We may also create a cash flow
analysis or work with and advise you as to cash flow modifications that we feel are necessary in order to fund
certain long-term objectives such as the purchase of a home, the liquidation of your mortgage, the education of your
children and grandchildren and/or your retirement funding. Finally, we may discuss issues related to your charitable
and estate planning.
The program developed for you will usually include general recommendations for a course of activity or specific
actions to be taken by you. For example, recommendations may be made that you establish or modify an individual
retirement account, increase or decrease funds held in savings accounts, invest funds in securities and/or obtain or
revise insurance coverage. FWA generally recommends investment in mutual funds and exchange traded funds
rather than individual securities.
Upon request, we will refer you to an accountant or attorney for development of your estate plan or charitable
programs.
Other financial planning services that we may provide include ongoing financial counseling, account review and
other advisory services related to investments.
FWA does not render legal advice or prepare any legal documents for you. Your personal attorney will be solely
responsible for providing legal advice, legal opinions, legal determinations and legal documents. Your personal tax
adviser or accountant will be solely responsible for any tax or accounting services provided to you.
This planning and advisory assistance is not automatically provided on a continuing basis, but only upon your
request.
Financial planning services to be provided to you will be outlined on the client agreement that you sign with us.
Retirement Planning and Consulting
Trustee Directed Plans. FWA can be engaged to provide discretionary investment advisory services to
ERISA retirement plans, whereby the Firm shall manage Plan assets consistent with the investment objective
designated by the Plan trustees. In such engagements, FWA will serve as an investment fiduciary as that term
is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). FWA will generally
provide services on an “assets under management” fee basis per the terms and conditions of an Investment
Advisory Agreement between the Plan and the Firm.
Client Retirement Plan Assets. If requested to do so, FWA can provide investment advisory services relative to the
client’s 401(k) plan assets maintained by the client in conjunction with the retirement plan established by the client’s
employer. In such event, FWA shall recommend that the client allocate the retirement account assets among the
investment options available on the 401(k) platform. Registrant’s ability shall be limited to the allocation of the
assets among the investment alternatives available through the plan. The client is exclusively responsible for making
all transactions. FWA’s ability shall be limited to making recommendations regarding the allocation of the assets
amon the investment alternatives available through the plan. FWA will not receive any communications from
the plan sponsor or custodian, and it shall remain the client’s exclusive obligation to notify FWA of any changes in
investment alternatives, restrictions, etc. pertaining to the retirement account. Unless expressly indicated by the
FWA to the contrary, in writing, the client’s 401(k) plan assets shall be included as assets under management for
purposes of FWA calculating its advisory fee. FWA does not maintain passwords to client retirement accounts.
Miscellaneous
Limitations of Financial Planning and Non-Investment Consulting/Implementation Services.
To the extent requested by the client, FWA will generally provide financial planning and related consulting
services regarding non-investment related matters, such as tax and estate planning, insurance, etc. on a separate
and additional fee basis per the terms and conditions of a Financial Planning and Consulting Agreement. Please
Note: We do not serve as an attorney or accountant, and no portion of our services should be construed as same.
Accordingly, although FWA may, in its sole discretion, determine to provide tax preparation services as a courtesy
to clients, FWA does not prepare estate planning documents. To the extent requested by a client, we may
recommend the services of other professionals for certain non-investment implementation purpose (i.e. attorneys,
accountants, insurance, etc.), including representatives of FWA in their separate individual capacities as
representatives of Osaic Wealth, Inc. (“Osaic”), an SEC registered and FINRA member broker-dealer and as
licensed insurance agents of the Firm’s affiliated licensed insurance agency, FWA, LLC. The client is under no
obligation to engage the services of any such recommended professional. The client retains absolute discretion
over all such implementation decisions and is free to accept or reject any recommendation from FWA and/or its
representatives. Please Note: If the client engages any recommended unaffiliated professional, and a dispute arises
thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged
professional. Please Also Note-Conflict of Interest: The recommendation by a FWA representative that a client
purchase a securities or insurance commission product from a FWA representative in his/her individual capacity
as a representative of Osaic and/or as an insurance agent, presents a conflict of interest, as the receipt of
commissions may provide an incentive to recommend investment products based on commissions to be received,
rather than on a particular client’s need. No client is under any obligation to purchase any securities or insurance
commission products from a FWA representative. Clients are reminded that they may purchase securities and
insurance products recommended by FWA through other, non-affiliated broker-dealers and/or insurance agencies.
FWA’s Chief Compliance Officer, Paul V. Ryan, Jr. remains available to address any questions that a client
or prospective client may have regarding the above conflict of interest.
Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer
typically has four options regarding an existing retirement plan (and may engage in a combination of these options):
(i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan,
if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv)
cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If
FWA recommends that a client roll over their retirement plan assets into an account to be managed by FWA, such a
recommendation creates a conflict of interest if FWA will earn new (or increase its current) compensation as a result
of the rollover. If FWA provides a recommendation as to whether a client should engage in a rollover or not (whether
it is from an employer’s plan or an existing IRA), FWA is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an
account managed by FWA, whether it is from an
employer’s plan or an existing IRA. FWA’s Chief Compliance Officer, Paul Ryan, remains available to
address any questions that a client or prospective client may have regarding the potential for conflict of
interest presented by such rollover recommendation.
Variable Annuity Management: As part of the program noted above, FWA may provide advice related to the sub
account of variable annuities. FWA allocates client investment assets on a discretionary basis among the investment
sub accounts of variable annuity products previously purchased by the client. Once allocated, FWA provides ongoing
monitoring and review of sub account performance and manages the sub accounts consistent with the Client Profile.
FWA includes the variable products assets as part of “assets under management” for the purposes of calculating its
annual advisory fee (see Fee Table in section 5 Transaction
charges generally do not apply to purchases, redemptions,
or other changes in sub accounts). Use of Mutual and Exchange Traded Funds: Most mutual funds and exchange
traded funds are available directly to the public. Thus, a prospective client can obtain many of the funds that may be
utilized by FWA independent of engaging FWA as an investment advisor. However, if a prospective client
determines to do so, he/she will not receive FWA’s initial and ongoing investment advisory services. Please Note:
In addition to FWA’s investment advisory fee described below, and transaction and/or custodial fees discussed below,
clients will also incur, relative to all mutual fund and exchange traded fund purchases, charges imposed at the fund
level (e.g. management fees and other fund expenses). ANY QUESTIONS: FWA’s Chief Compliance Officer,
Paul V. Ryan, Jr. remains available to address any questions that a client or prospective client may have
regarding the above.
Custodian Charges-Additional Fees: As discussed below in Item 12, when requested to recommend a broker-
dealer/custodian for client accounts, FWA generally recommends that Osaic/Pershing serve as the broker-
dealer/custodian for client investment management assets. Broker-dealers such as Osaic/Pershing charge transaction
fees for effecting securities transactions. In addition to FWA’s investment advisory fee referenced in Item 5 below,
unless the client has engaged FWA on a wrap fee basis in conjunction with the Osaic Program (see above), the client
will also incur transaction fees to purchase securities for the client’s account (i.e., mutual funds, exchange traded
funds, individual equity and fixed income securities, etc.).
Portfolio Activity: FWA has a fiduciary duty to provide services consistent with the client’s best interest. As part
of its investment advisory services, FWA will review client portfolios on an ongoing basis to determine if any
changes are necessary based upon various factors, including, but not limited to, investment performance, fund
manager tenure, style drift, market conditions, account additions/withdrawals, and/or a change in the client’s
investment objective. Based upon these factors, there may be extended periods of time when FWA determines that
changes to a client’s portfolio are neither necessary nor prudent. Of course, as indicated below, there can be no
assurance that investment decisions made by FWA will be profitable or equal any specific performance level(s).
Please Note: Non-Discretionary Service Limitations. Clients that determine to engage FWA on a non-
discretionary investment advisory basis must be willing to accept that FWA cannot effect any account transactions
without obtaining prior consent to any such transaction(s) from the client. Thus, in the event that FWA would like
to make a transaction for a client’s account, and client is unavailable, FWA will be unable to effect the account
transaction (as it would for its discretionary clients) without first obtaining the client’s consent.
Please Note: Cash Positions. FWA continues to treat cash as an asset class. As such, unless determined to the
contrary by FWA, all cash positions (money markets, etc.) shall continue to be included as part of assets under
management for purposes of calculating FWA’s advisory fee. At any specific point in time, depending upon
perceived or anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), FWA may maintain cash positions for defensive purposes. In addition, while assets
are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in
time, FWA’s advisory fee could exceed the interest paid by the client’s money market fund. ANY QUESTIONS:
FWA’s Chief Compliance Officer, Paul Ryan, remains available to address any questions that a client or
prospective may have regarding the above fee billing practice.
Cash Sweep Accounts. Account custodians generally require that cash proceeds from account transactions or cash
deposits be swept into and/or initially maintained in the custodian’s sweep account. The yield on the sweep account
is generally lower than those available in money market accounts. To help mitigate this issue, Registrant shall
generally purchase a higher yielding money market fund available on the custodian’s platform with cash proceeds
or deposits, unless Registrant reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-
day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will
occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to, the
amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication
from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from
the account.
Please Note: The above does not apply to the cash component maintained within the Registrant’s actively managed
investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep
account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment
manager, and cash balances maintained for fee billing purposes. Please Also Note: The client shall remain
exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances
maintained in any of the Registrant’s unmanaged accounts.
Platform. Registrant may provide its clients with access to an online platform hosted by “eMoney Advisor”
(“eMoney”). The eMoney platform allows a client to view their complete asset allocation, including those assets that
Registrant does not manage (the “Excluded Assets”). Registrant does not provide investment management,
monitoring, or implementation services for the Excluded Assets. Unless otherwise specifically agreed to, in writing,
Registrant’s service relative to the Excluded Assets is limited to reporting only. Therefore, Registrant shall not be
responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that
maintain management authority for the Excluded Assets, and not Registrant, shall be exclusively responsible for
such investment performance.
Without limiting the above, the Registrant shall not be responsible for any implementation error (timing, trading,
etc.) relative to the Excluded Assets. The client may choose to engage Registrant to manage some or all of the
Excluded Assets pursuant to the terms and conditions of an advisory agreement between Registrant and the client.
The eMoney platform also provides access to other types of information and applications including financial
planning concepts and functionality, which should not, in any manner whatsoever, be construed as services, advice,
or recommendations provided by Registrant. Finally, Registrant shall not be held responsible for any adverse results
a client may experience if the client engages in financial planning or other functions available on the eMoney
platform without Registrant’s assistance or oversight.
Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of
Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG
investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers
how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships
with its employees, customers, and the communities in which it operates); and Governance (i.e., company
management considerations). The number of companies that meet an acceptable ESG mandate can be limited when
compared to those that do not and could underperform broad market indices. Investors must accept these limitations,
including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded
funds are limited when compared to those that do not maintain such a mandate. As with any type of investment
(including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can
be no assurance that investment in ESG securities or funds will be profitable or prove successful. Registrant does
not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If
implemented, Registrant shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded
fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities
meet a socially responsible mandate.
Cybersecurity Risk. The information technology systems and networks that Registrant and its third-party service
providers use to provide services to Registrant’s clients employ various controls, which are designed to prevent
cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions
in Registrant’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public
Commented [JAL2]: If you use emoney, Byallaccounts or
some other aggregator.
Commented [JAL3R2]: Where clients can view their
assets including on held away platforms
Commented [JAL4]: Consider this if you use ESG
investing.
personal information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents that could
ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to
respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or
interruption to systems. Although Registrant has established procedures to reduce the risk of cybersecurity incidents,
there is no guarantee that these efforts will always be successful, especially considering that Registrant does not
directly control the cybersecurity measures and policies employed by third-party service providers. Clients could
incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of
securities in which those clients invest, broker-dealers qualified custodians, governmental and other regulatory
authorities, exchange and other financial market operators, or other financial institutions
Client Obligations. In performing our services, FWA shall not be required to verify any information received from
the client or from the client’s other professionals and is expressly authorized to rely thereon. Moreover, it remains
each client’s responsibility to promptly notify FWA if there is ever any change in his/her/its financial situation or
investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or
services.
Investment Risk. Different types of investments involve varying degrees of risk, and it should not be assumed that
future performance of any specific investment or investment strategy (including the investments and/or investment
strategies recommended or undertaken by FWA) will be profitable or equal any specific performance level(s).
Disclosure Brochure. A copy of FWA’s written Privacy Policy and Brochure as set forth on Part 2A shall be
provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement,
Financial Planning, and/or Retirement Plan Services Agreement.
FWA shall provide investment advisory services specific to needs of each client. Prior to providing investment
advisory services, an investment adviser representative will discuss with each client, their particular investment
objective(s). FWA shall allocate each client’s investment assets consistent with their designated investment
objectives(s). The client may, at any time, impose reasonable restrictions on the securities or types of securities
used in the asset allocation. Clients shall notify FWA in writing if they would like to impose such restrictions.
Wrap Program-Potential Conflict of Interest. FWA provide services on both an unbundled and bundled (wrap
fee) basis. When the client engages FWA on an unbundled basis, the client pays two distinct fees: (1) an investment
advisory fee for the services provided by FWA; and (2) transaction fees for investment transactions executed for
the account-see additional discussion relative to transaction fee below. If the client engages FWA on a wrap fee
basis, it will do so per the terms and conditions of the wrap program sponsored and administered by Osaic (the
“Osaic Program”). Under the Osaic Program, and the other for transactions, the client, with certain exceptions as
referenced in the corresponding wrap fee brochure prepared by Osaic (the “Osaic Brochure”), receives both
investment advisory services and the execution of securities brokerage transactions, custody and reporting services
for a single specified fee. When managing a client’s account on a wrap fee basis, FWA shall receive as payment
for its investment advisory services, the balance of the wrap fee after all other costs incorporated into the wrap fee
have been deducted. Participation in a wrap program may cost the client more or less than purchasing such services
separately. The terms and conditions for participation in the Osaic Program are more fully discussed in the Osaic
Brochure. The client is presented with both a copy of the Osaic Brochure, and the corresponding Osaic Program
agreement for review and execution, prior to engaging FWA to manage the client’s assets in accordance with the
Osaic Program. See separate Osaic Brochure. Account transactions are made based upon current and anticipated
market conditions and the client’s corresponding investment objective and needs, and without regard to transaction
costs. Please Note: Because wrap program transaction fees and/or commissions are being paid by FWA to the
account custodian/broker-dealer, FWA has an economic incentive to minimize the number of trades in the client’s
account. ANY QUESTIONS: FWA’s Chief Compliance Officer, Paul V. Ryan, Jr. remains available to
address any questions that a client or prospective client may have regarding a wrap fee arrangement and
the corresponding conflict of interest.
As of March 21, 2024 FWA’s total assets under management are $405,731,725 managed on a discretionary
basis and $15,554,537 managed on a non-discretionary basis.