MVIA offers a variety of advisory services, which include financial planning, consulting, investment management, and wealth management services. Prior to MVIA rendering any of the foregoing advisory services, clients are required to enter into one or more written agreements with MVIA setting forth the relevant terms and conditions of the advisory relationship (the "Advisory Agreement").
As of January 2018, MVIA is an SEC-registered investment adviser offering financial planning, investment and wealth management solutions. MVIA is a Limited Liability Company (LLC) and wholly- owned subsidiary of Martha's Vineyard Savings Bank (MVSB). While this brochure generally describes the business of MVIA, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm's officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on MVIA's behalf and is subject to the Firm's supervision or control.
As of December 31, 2023 the Firm had $244,273,355 in discretionary assets under management. Financial Planning and Consulting Services MVIA offers clients a broad range of financial planning and consulting services, which includes any or all of the following functions:
•Business Planning
•Cash Flow Forecasting
•Trust and Estate Planning
•Financial Reporting
•Investment Consulting
•Insurance Planning
•Retirement Planning
•Risk Management
•Charitable Giving
•Distribution Planning
•Tax Planning
•Manager Due Diligence In performing these services, MVIA is not required to verify any information received from the client or from the client's other professionals (e.g., attorneys, accountants, etc.,) and is expressly authorized to rely on such information. MVIA recommends certain clients engage the Firm for additional related services, its Supervised Persons or affiliates, in their individual capacities as insurance agents or registered representatives of a broker-dealer and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists for the Firm to recommend that clients engage MVIA or its affiliates to provide (or continue to provide) additional services for compensation, including investment and wealth management services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by MVIA under a financial planning or consulting engagement. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising MVIA's recommendations and/or services.
Investment and Wealth Management Services MVIA manages client investment portfolios on a discretionary basis. In addition, MVIA provides certain clients with wealth management services which include a range of comprehensive financial planning and consulting services, as well as management of investment portfolios.
4 MVIA primarily allocates client assets among various mutual funds, exchange-traded funds ("ETFs"), individual debt and equity securities, alternatives and independent investment managers ("Independent Managers") in accordance with their stated investment objectives. In constructing client portfolios, MVIA considers an array of investment vehicles across multiple asset classes, geographies and market capitalizations. We utilize both internally managed strategies as well as external money managers to complete our full suite of investment solutions. Our external managers provide access to both traditional strategies and alternative strategies with access to real estate, private equity, and liquid alternatives. Where appropriate, the Firm also provides advice about any type of legacy position or other investment held in client portfolios. Clients can engage MVIA to manage and/or advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, MVIA directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company or the custodian designated by the product's provider.
MVIA tailors its advisory services to meet the needs of its individual clients and seeks to ensure, on a continuous basis, that client portfolios

are managed in a manner consistent with those needs and objectives. MVIA consults with clients on an initial and ongoing basis to assess their specific risk tolerance, time horizon, liquidity constraints and other related factors relevant to the management of their portfolios. Clients are advised to promptly notify MVIA if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients can impose reasonable restrictions or mandates on the management of their accounts if MVIA determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm's management efforts.
Use of Independent Managers As mentioned above, MVIA selects certain Independent Managers to actively manage all or a portion of its clients' assets. The specific terms and conditions under which a client engages an Independent Manager may be set forth in a separate written agreement with the designated Independent Manager. In addition to this, clients may also receive the written disclosure documents of the respective Independent Managers engaged to manage their asset.
MVIA evaluates a variety of information about Independent Managers, which includes the Independent Managers' public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers' investment strategies, past performance and risk results in relation to its clients' individual portfolio allocations and risk exposure. MVIA also takes into consideration each Independent Manager's management style, returns, reputation, financial strength, reporting, pricing and research capabilities, among other factors.
Differences in compensation paid by Independent Managers may create an incentive for Advisory Representatives to recommend one Manager over another. The Manager must be appropriately licensed as an Investment Adviser with the SEC or states in which they conduct business.
MVIA's approach to comprehensive investment management begins with an assessment of your personal investment objectives. After this assessment, we create custom portfolios, which can include individual equities, individual fixed income securities, mutual funds, ETFs, and/or limited partnerships invested in alternatives, which may include hedge funds, private equity, real estate, and commodities.
5 The overall asset allocation is determined by the personal investment objectives as described above; the appropriate risk tolerance is then defined based on that assessment, and typically falls within one of the following 4 categories: - Aggressive - Growth - Moderate - Conservative In implementing the solution for these customized portfolios, certain MVIA proprietary investment strategies may be used to fulfill certain allocations.
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.