BroadWealth LLC (“BroadWealth,” the “Firm,” the “Advisor,” “We,” “Us,” “Our”) is a Registered Investment Adviser with the Commonwealth of Massachusetts and is applying for registration with the U.S. Securities and Exchange Commission.. Jennifer Dowling Dougherty, MSE, MBA, CFA is the sole owner of BroadWealth, an independent, fee-only advisory firm which was founded in Winchester, Massachusetts in April 2019. As of September 30, 2023, BroadWealth reports a total of $53,497,147 in assets under management (“AUM”) with $47,064,096 in discretionary AUM and $6,433,052 in non-discretionary AUM. BroadWealth was formed to address the needs of a select group of high net worth individuals and families (“Clients”) – those who typically have enjoyed highly demanding, rewarding careers balanced with other major responsibilities of children, aging parents, blended families, philanthropy and/or personal pursuits. As their wealth grew over time, so did the proliferation of financial information, products, and opportunities. These increasing complexities collided with the ever-expanding demands on their time, knowledge, and resources. While highly educated and capable of managing their financial affairs, these clients seek relief and greater control in the form of nuanced expertise, dedicated time, and competent coordination to achieve their financial goals and peace of mind. BroadWealth serves as their wealth management home – the central hub and harbor for advice and coordination of services regarding all material aspects of their financial world. We provide counsel that is independent, unbiased, and customized. Each client knows: BroadWealth takes care of your wealth management broadly so that you can focus on you -- your family, your work, your life. 4A. WEALTH MANAGEMENT SERVICES BroadWealth tailors its advisory services to the needs and circumstances of each client and intentionally integrates investment management and advisory services into client’s financial planning. Typically, investment management and financial planning services are provided as part of one integrated, comprehensive offering. Investment Management BroadWealth manages individually tailored investment portfolios on a discretionary basis according to the needs and circumstances of each client. We are fairly unique in that we help clients design and implement strategies for all of the investment assets on their family’s balance sheets, no matter: ● How those assets are owned – whether directly or via a trust, company, or private foundation, or ● Where they are held – whether, for example, with a custodian we recommend, in an employer-sponsored retirement plan, in personal or rental real estate, etc. During our data-gathering process, we determine the client’s objectives, time horizons, risk tolerance, and liquidity needs. We typically review and discuss a client’s prior investment history, as well as family composition and background to inform our work together. Based on this information, we: ● Develop a client's personal investment instructions to provide the overall framework and guidelines for an investment plan with an asset allocation tailored to that client’s situation. ● Create and manage a portfolio per client’s investment instructions and asset allocation targets. FORM ADV PART 2A 12-20-2023 Page 5 Account supervision is guided by the stated objectives of the client (e.g., maximum capital appreciation, growth, income, growth and income, etc.), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Fees pertaining to this service are outlined in Item 5. Our methods of analysis and investment strategies are described in Item 8 of this brochure. Investment Operations Platform Certain aspects of our investment and operational platform are performed by Dynamic Advisor Solutions LLC (“Dynamic”), a large SEC-registered investment advisory firm. Dynamic is separately owned and operated (CRD #151367 at brokercheck.finra.org ). BroadWealth is not affiliated with Dynamic. Dynamic develops, administers, and provides access to a highly integrated technology platform developed exclusively for independent wealth managers and their clients. BroadWealth pays Dynamic directly for use of the platform with portals for both clients and advisors. Additionally, per BroadWealth’s specifications, Dynamic provides the following support and services:
• Back-office services which may include account administration and paperwork, client invoicing, record maintenance, report preparation, marketing assistance, etc.
• Various model portfolios based on different types of investment strategies utilizing equities, bonds, mutual funds, and/or ETFs. BroadWealth maintains discretion and selects portfolio(s) for each client based upon the risk tolerance and investment objectives discussed and confirmed with that client.
• Portfolio management assistance which may include research services, trading and rebalancing, data aggregation, account reconciliation, etc. By engaging Dynamic, our operations are more efficient, thus allowing us to attend to strategic client issues related to investments and planning. With Dynamic, we gain access to valuable technology and resources while retaining the intimacy of a boutique firm focused intently on client needs. Investment Selection – Separate Account Managers BroadWealth may allocate and/or recommend that the client allocate a portion of a client’s investment assets among unaffiliated independent investment managers (“Outside Manager(s)” or “Manager(s)”) in accordance with the client’s designated investment objectives and with whom we have sub-advisory agreements. For example, we have relationships with bond managers to whom we delegate authority. Outside Manager(s) will have day-to- day responsibility for the active discretionary management of the allocated assets. The Firm will continue to render investment supervisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. The Firm generally considers the following factors when recommending Outside Manager(s): management style, performance, reputation, financial strength, reporting, pricing, research capabilities, and fit with the client’s investment objectives. The investment management fee charged by the Outside Manager(s) is in addition to the Firm’s advisory fee as set forth in Item 5. We do not participate in any portion of those fees. Our goal is to minimize the fees our clients pay to subadvisors, consistent with receiving a high level of service. Unaffiliated Private Investment Funds In certain cases, BroadWealth may recommend investment in certain unaffiliated private investment funds. BroadWealth’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client decides to become a private fund investor, FORM ADV PART 2A 12-20-2023 Page 6 the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of BroadWealth calculating its investment advisory fee. BroadWealth’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). All clients considering a private investment generally will receive an Offering Memorandum prepared by the fund sponsor (discussing the fund's investment objectives, risk factors, conflicts, etc.) and typically shall enter into a Subscription Agreement acknowledging the terms and conditions of the fund and/or venture and the corresponding risk factors, including loss of principal and liquidity constraints. BroadWealth will recommend private funds only to those clients for whom it reasonably believes such an investment to be suitable, given the client’s total portfolio, risk parameters, and liquidity needs. BroadWealth shall not exercise any discretion regarding an investment in any private fund. Rather, the ultimate investment decision rests with the client. Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints, and lack of transparency -- a complete discussion of which is set forth in each fund’s offering documents provided to each client for review and consideration. Private investment funds do not provide daily liquidity or pricing. Given the above risk factors, the Firm must determine whether a specific private fund is appropriate for the client – recognizing that, for certain clients, a private fund of any kind may not be suitable – and shall consider:
• Type of offering - including risks, time horizon, and liquidity issues
• Client's investment objective(s)
• Client's current portfolio allocation
• Client’s available cash to commit to the private fund
• Private fund's investment minimum per investor
• Client's current allocation to private investment funds. Valuation of Private Investments: If subsequent account reports prepared by BroadWealth references the private investment funds owned by the client, the value(s) for these private investment funds shall reflect the most recent valuation provided by the fund sponsor. Specifically, if subsequent to purchase, the fund has:
• not provided an updated valuation, the valuation shall reflect the initial purchase price.
• provides an updated valuation, then the statement will reflect that updated value. The most recently available value will continue to be reflected on this report until the fund provides a further updated value. Please note that, as a result of the valuation process, the report may reflect an initial purchase price or an updated value which may be significantly more or less than the actual current value(s) of an investor’s fund holding. Regardless, the client’s advisory fee shall be based upon the value reflected on the report. Investments in Client’s Qualified Employer-Sponsored Retirement Plan Account(s) Upon request, BroadWealth may provide investment advisory services regarding investment assets held in the client’s personal account in a qualified, employer-sponsored retirement plan(s) such as a 401(k), 403(b), or 457. In such event, BroadWealth shall allocate (or recommend that the client allocate) the retirement account assets among the investment options available on the retirement plan’s platform. Generally, the client will be responsible for implementing our recommendations. FORM ADV PART 2A 12-20-2023 Page 7 BroadWealth’s fee for this portion of advisory services must be charged to one of the client’s personal taxable accounts; we cannot receive any fee compensation from a qualified retirement account nor the plan’s sponsor. Please Note: BroadWealth’s services shall be limited to the allocation of the client’s assets among the investment alternatives available through the plan. BroadWealth will not receive any communications from the plan sponsor nor custodian, and it shall remain the client’s exclusive obligation to notify BroadWealth of any changes in investment alternatives, restrictions, or other relevant or material information pertaining to the account(s) in the employer-sponsored plan(s). IRA Rollovers In appropriate circumstances, BroadWealth may recommend that a client roll over an account held in a former employer's retirement plan to an Individual Retirement Account ("IRA") for BroadWealth to manage. When providing investment advice to clients regarding retirement plan accounts or IRAs, BroadWealth is 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. The way BroadWealth makes money creates some conflicts with the client’s interests, so BroadWealth operates under a special

rule that requires it to act in the client’s best interest and not put the firm’s interests ahead of the clients. If the client elects to rollover assets into an IRA account subject to BroadWealth’s management, the account will be subject to BroadWealth’s advisory fee per the client’s Wealth Management Agreement. Conflict of Interest: Any financial advisor’s recommendation to roll over retirement plan assets into an IRA may create a conflict of interest if the additional assets generate additional compensation. When BroadWealth recommends a rollover IRA, the recommendation is given in the client’s best interest and ahead of the Firm’s interests. Further, the client is never under any obligation, contractually or otherwise, to complete a rollover nor to have the rollover IRA assets managed by BroadWealth. Many employers permit former employees to keep their retirement assets in the company plan; many also permit current employees to move assets out of the company plan before retiring or leaving the company. In determining whether to complete an IRA rollover, and to the extent the following options are available, BroadWealth clients should consider their costs and benefits. An employee will typically have four options: 1. Leave the assets in the employer/former employer's plan; 2. Transfer the funds to a new employer’s retirement plan; 3. Cash out and take a taxable distribution from the plan; or 4. Roll the funds into an IRA account. Each of these options has advantages and disadvantages. Before initiating a rollover, clients should consult with their CPA and/or tax attorneys to consider the following relevant factors:
• Range of Investment Options: Do the investment options in the employer’s plan address client’s needs, or are other types of investments needed? Employer-sponsored retirement plans: o Generally have a more limited investment menu than IRAs. o May have unique investment options not available to the public such as employer securities, or previously closed funds.
• Costs: FORM ADV PART 2A 12-20-2023 Page 8 o Explicit Fees: The employer plan may have lower fees than BroadWealth’s fees. Fees also should be considered in light of services, expertise, etc. o Fees Embedded within Funds: What is the cost structure (often called expense ratio) of the share classes available in employer's retirement plan compared to those available in an IRA?
• Risks: BroadWealth’s recommended strategy may entail higher risk than the option(s) provided in client’s plan.
• Services: o Client should understand the various products and services that may be available through a Rollover IRA and the potential costs of those products and services. o The employer plan also may offer financial advice – What is the background of the advisory staff, frequency and method of advice, range of topics covered, etc.? o Client’s existing retirement plan may allow the client to hire an outside investment manager while keeping the assets titled in the plan name.
• Taxes: Shares of company stock held within a 401k plan possibly may be liquidated at a lower capital gains tax rate. Keeping assets titled in a employer plan (if still working beyond age 72) potentially may delay a required minimum distribution (RMD) beyond age 72, thus delaying the taxes due on that RMD.
• Creditor Protection: o An existing 401k plan may offer more liability protection than a rollover IRA. Such legal protection varies by state. Since 2005, IRA assets generally have been protected from creditors in bankruptcies. However, some exceptions may apply. Thus, an attorney should be consulted if concerned about protecting retirement plan assets from creditors.
• Access to funds: o Loans may be available from the employer plan (although generally not to ex- employees); loans are not permitted from an IRA. o IRA assets can be accessed any time, subject, of course, to the same income taxes as distributions from an employer-sponsored retirement account. Clients should understand the differences between an IRA and an employer-sponsored retirement plan (e.g., 401(k), 403(b), etc. ) and evaluate whether a rollover is best under the circumstances. Financial Planning Services BroadWealth provides financial planning services on a broad range of topics which may include, but are not limited to:
• Investment Analysis
• Retirement Planning
• Employee Benefits Optimization
• Tax Planning Strategies
• College Funding Plan
• Estate Planning
• Financial Goals
• Cash Flow Management
• Business Planning
• Insurance Review & Planning
• Debt Management
• Risk and Liability Management
• Records Management The Firm’s Wealth Management fee includes financial planning services to the extent requested by the client. In general, the client and advisor will work together to prioritize the specific areas the financial planning should address, typically in phases over time and iteratively. Implementation of any planning recommendations is entirely at the client’s discretion. The scope of services will change over time based on the client’s evolving needs as agreed during regular discussions between the client and BroadWealth. If a client requires extraordinary planning FORM ADV PART 2A 12-20-2023 Page 9 and/or consultation services (to be determined in the sole discretion of the Firm), the Firm may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written agreement with the client (see Items 4B and 5B below). Please note: BroadWealth’s services are not intended to replace any tax, legal or accounting advice from a tax/legal/accounting professional. The Firm does not serve as a law firm, accounting firm, or insurance agency, and no portion of its services should be construed as legal, accounting or insurance services. Accordingly, the Firm does not prepare estate planning documents or tax returns and does not sell insurance. BroadWealth recommends clients consult with a licensed, qualified professional before initiating any tax planning, estate planning, or insurance/risk management strategies. We will participate in meetings or phone calls between the client and his/her other professional service providers (CPA, attorney, insurance agent, etc.) with the client’s approval. As an accommodation when requested, BroadWealth may recommend the services of qualified professionals for certain non-investment implementation purposes (e.g., attorneys, accountants, insurance agents, etc.). Clients are encouraged to make their own decisions and are under no obligation to engage the services of any such recommended professional. Although we may have experience with these service providers, BroadWealth has not performed due diligence on these service providers and is not responsible for the services provided by these services providers. 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 BroadWealth and/or its representatives. BroadWealth has no financial or business relationship with any such professionals and does not accept nor pay fees or commissions for any type of referral. BroadWealth cannot monitor nor be responsible for the day-to-day activities of the professional service providers or firms. Further, BroadWealth cannot be responsible for the client’s compliance with the requirements of or fulfillment of his/her/its responsibilities to such service providers or regulatory authorities. The other professional service providers will invoice the client separately for services rendered. If the client engages any such professional and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, Third-Party Administrator, etc.), and not BroadWealth, shall be responsible for the quality and competency of the services provided. Please Further Note: BroadWealth believes that it is important for the client to address financial planning issues on an ongoing basis. BroadWealth’s advisory fee, as set forth at Item 5 below, will remain the same regardless of whether or not the client determines to address financial planning issues with BroadWealth. It remains the client’s responsibility to promptly notify BroadWealth of any change in his/her/its financial situation or investment objectives for the purpose of reviewing/evaluating/revising BroadWealth’s previous recommendations and/or services. FORM ADV PART 2A 12-20-2023 Page 10 4B. FINANCIAL CONSULTING & IMPLEMENTATION SERVICES On a stand-alone, separate fee basis, clients can engage BroadWealth for financial consulting and implementation services, which may vary greatly in depth and scope relating to a variety of client’s financial circumstances. We may consult with a client regarding topics that are not covered under our general financial planning services. Examples may include but certainly are not limited to:
• Analysis to prepare for the sale of a business
• Comprehensive support through probate and estate settlement
• Financial due diligence on a potential large transaction
• A comprehensive review and distillation of financial records, accounts, and issues with corresponding recommendations. The scope and cost of our consulting services are defined in writing prior to the engagement. We recommend that clients consult with a licensed, qualified professional before initiating any tax planning, estate planning, or insurance/risk management strategies. We will participate in meetings or phone calls between the client and his/her other professional service providers (CPA, attorney, insurance agent, etc.) with the client’s approval. BroadWealth does not provide legal, accounting or insurance services. The Firm does not serve as a law firm, accounting firm, or insurance agency, and no portion of its services should be construed as legal, accounting or insurance services. Accordingly, the Firm does not prepare estate planning documents or tax returns and does not sell insurance. 4C. RETIREMENT PLAN/PENSION SERVICES Trustee-Directed and Participant-Directed Plans If a client, as a Trustee and/or Sponsor of a qualified retirement plan (a “Plan”) engages us to provide investment advice to the Plan, we will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”). If the Plan is participant-directed, we will assist with the selection of an investment platform on which Plan participants shall make their respective investment choices. To the extent engaged to do so, we may determine and manage the menu of investment strategies available to Plan participants and/or may provide corresponding education to assist the participants with their decision-making process. The terms and conditions of the engagement shall generally be set forth in a separate Retirement Plan/Pension Services Agreement between the Firm, the Plan Sponsor, and the Plan Trustee. 4D. EDUCATIONAL SEMINARS AND SPEAKING ENGAGEMENTS BroadWealth occasionally may provide seminars for groups seeking general advice on investments and other areas of personal finance. Content of these seminars will vary depending upon the needs of the attendees. Seminars are purely educational in nature and do not involve the sale of any investment products. Information presented will not be based on any individual person’s needs, and individualized investment advice will not be provided to attendees during seminars. BroadWealth does not charge attendees fees for these seminars. FORM ADV PART 2A 12-20-2023 Page 11 4E. WRAP FEE PROGRAMS We do not participate in wrap fee programs.