A. Firm Information
Massachusetts Wealth Management, LLC ("MWM" or the "Firm") was organized in December 2011
as a limited liability company under the laws of the Commonwealth of Massachusetts ("Massachusetts").
MWM's registration as an investment adviser with Massachusetts became effective in January 2012.
The Firm transitioned to registration as an investment adviser with the Securities and Exchange
Commission1, which became effective in November 2017.
The Firm's Principal Owner and President is Mr. Samuel J. Conte II, who also serves as MWM's Chief
Compliance Officer. Mr. Conte has over 30 years of financial industry experience. Mr. Conte's role is
supported by the Firm's Executive Vice President, Ms. Diana Nickerson. Ms. Nickerson has been
supporting Mr. Conte for over 19 years, leveraging her expertise in day-to-day operations and overall
business knowledge. Her commitment to delivering exceptional service is reflected in her dedication to
ensuring that each client receives the level of service they deserve.
B. Description of Services
MWM provides Discretionary Investment Management Services ("DIMS") to individuals, high net
worth, trusts, retirement plans, charitable foundations, and endowments (collectively, "client" or
"clients").
Discretionary Investment Management Services
MWM provides customized Discretionary Investment Management Services, which involve consistent
communication and collaboration with clients to deliver discretionary investment management solutions
tailored to their specific needs. The Firm works closely with each client to determine their investment
objectives and risk tolerance to construct the optimal asset allocation. Asset allocation consists of
allocating client assets amongst various asset classes to seek the optimal return for a given level of risk.
Once the optimal asset allocation is agreed upon, the Firm will construct a portfolio comprising equity
(including exchange-traded funds), fixed-income securities, and cash equivalents. The types of fixed-
income securities purchased will be dependent on tax status and risk tolerance. Cash equivalents may
include money market funds, T-Bills, municipal notes, certificates of deposit, and other
fixed-income
securities that typically mature in one year or less. When constructing a portfolio, MWM will generally
recommend purchasing individual securities (e.g., equity, debt), and a smaller portion invested in
exchange-traded funds. However, the Firm also provides advice on a wide range of securities when
positions are transferred into a discretionary investment management account managed by MWM.
Recommendations to sell mutual funds, and other securities may take into consideration the level of
portfolio diversification and tax consequences.
The Firm's investment strategies are primarily long-term focused, but the Firm may buy, sell, or re-
allocate positions held for less than one year to meet the client's objectives or due to market conditions.
After constructing a portfolio, MWM will continuously monitor the portfolio to ensure it is on track to meet
the goals and objectives based on the client's agreed risk tolerance.
Please see "Item 5 – Fees and Compensation" for the fees associated with Discretionary Investment
Management Services.
C. IMS Tailored to the Individual Needs of Each client and Imposition of Reasonable Restrictions
Investment management service offerings allow tailored solutions and reasonable restrictions. Based
on a client's risk tolerance and goals, MWM will develop a custom-tailored solution to help clients meet
1 Registration as an investment adviser with the Securities and Exchange Commission is not intended to imply any level of skill or
training.
their individual needs. Reasonable restrictions may include reducing or restricting the allocation to
specific asset classes (e.g., equity, debt, real estate, etc.) or sectors (e.g., the tobacco industry, auto
industry, technology). Clients may also prefer holding certain positions for tax purposes or an
overweighting in ESG-related securities (environmental, social, governance).
D. Wrap Fee Programs
The Firm does not participate i n o r offer wrap fee programs.
E. Assets Under Management
As of December 31, 2023, MWM managed $226,293,782 in client assets on a discretionary basis.
Further details can be found in "Item 16 – Investment Discretion."