Item 5: Additional Compensation ................................................................................................. 32
Item 6: Supervision ....................................................................................................................... 32
Firm Description and Types of Advisory Services
Assabet Advisors, LLC (“Assabet,” “we” “us,” “ours” or the “Firm”) began business as a
registered investment advisor in September 2003. We have sought to provide customized
investment solutions to clients using a largely scientific approach to investing.
Wayne M. Ushman is the owner of Assabet.
We provide investment management and consulting services. Before entering into an advisory
relationship with us, a client is required to enter into one or more written agreements with us
(together the “Agreement”) which describe the terms and conditions governing the provision of
services. Neither Assabet nor the client may assign the Agreement without the consent of the
other party. A transaction that does not cause a change of actual control is not considered an
assignment.
Types of Advisory Services
We reserve the right to advise clients on any other type of investment that it deems
appropriate based on the client’s stated goals and objectives. We may also provide advice on
any type of investment held in a client’s portfolio at the inception of the advisory relationship
or on any investment on which the client requests advice.
Investment Management Services
Our investment advisory services are generally limited to the discretionary management of
investment portfolios on behalf of our clients, consistent with the individual objectives of the
portfolio owners. We may, under certain circumstances, offer non-discretionary management
services. As a part of the investment management relationship, we may discuss non-investment
related financial decisions or concerns with clients, recommending other advisors such as
attorneys, accountants or insurance specialists.
We allocate client investment assets primarily among mutual funds, exchange-traded funds
(“ETFs”) and individual debt securities in accordance with the investment objectives of the
client. We may, on rare occasion, recommend that clients who are “accredited investors” as
defined under Rule 501 of the Securities Act of 1933, as amended, invest in private placement
securities which may include debt, equity, and/or pooled investment vehicles as consistent with
the client’s investment objectives.
We also may offer non-discretionary investment management services to clients concerning
variable life or annuity products they may own, their individual employer-sponsored retirement
plans, and/or 529 plans or other products that are not held by the client’s primary custodian. In
doing so, we recommend the allocation of client assets among various investment options
available through the product, leaving it up to the client to make ultimate decisions or to
implement the recommendations.
We respond to client needs by customizing our advisory services. We typically consult with
clients at the initiation of the client relationship, and on an ongoing way, to create an
Investment Policy Statement (“IPS”) to record the factors guiding the investment
strategy as
well as the respective duties of Assabet and the client during the relationship. The IPS will
include such information as the investment time horizon, the portfolio’s primary purpose and
objective, the client’s risk tolerance, acceptable investment vehicles, and general asset
allocation targets.
ERISA Retirement Plan Advice
We provide investment advice to sponsors of ERISA retirement plans. At the plan level, we are
the responsible plan fiduciary for the analysis, selection, and monitoring of the investment
portfolio for each plan participant.
Tailored Relationships
We tailor investment advisory services to the individual needs of the client. Clients are advised
to promptly notify us whenever there are changes in their financial situation or investment
objectives. Clients may impose reasonable restrictions on the upon our management services.
All limitations and restrictions placed on accounts must be presented to us in writing.
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
We do not participate in a Wrap Fee Program.
Client Assets
As of December 31, 2022, we had $126,155,317 in assets under management. Of that amount,
$123,235,078 were managed on a discretionary basis and $2,920,239 on a non-discretionary
basis.