Firm Descrip on U.S. Boston has been in business since 1969 and became a broker dealer registered with the SEC on July 1, 1970. U.S. Boston became an investment adviser registered with the SEC in March 2024. Principal Owners U.S. Boston Corporation is 100% owner of the Firm. Willard L. Umphrey, the founder of the Firm, owns 94% of U.S. Boston Corporation. John McClellan heads the Investment Advisory Practice. He joined U.S. Boston in 2016 after more than 30 years in strategy consulting, private equity, and entrepreneurial and turn‐around management. Advisory Services U.S. Boston’s mission is to help our clients achieve their life goals through thoughtful, customized investment planning and management. U.S. Boston’s services generally include portfolio review, analysis, and construction; asset allocation and security selection; and account monitoring. At the commencement of the client relationship, each client will sign an investment management agreement that defines the terms, conditions, authority and responsibilities of the Advisor and the Client with the Advisor. U.S. Boston will discuss the client’s objectives, risk tolerance, and any restrictions, and establish an investment policy that reflects the client’s needs and provides the Firm with sufficient discretion to properly invest the client’s assets. We may modify our primary investment strategies to accommodate the particular needs and preferences of the client. The client’s specific objectives, strategy, and restrictions will be set forth in the agreement. We develop an investment strategy that is customized to each client’s unique situation and objectives. At the start of a new relationship, U.S. Boston will learn about our client's life aspirations, financial circumstances, investment objectives, current and expected future liquidity requirements, and any special interests or limitations that they may wish U.S. Boston to follow. We will review and evaluate the client’s current investment portfolio and historical investment strategy, and carefully consider what aspects remain appropriate, and which should be changed. In considering changes to historical investment strategies, we assess the tax ramifications of potential changes, and strive for tax efficiency in future asset allocations. During the initial stages and on a regular basis thereafter, U.S. Boston discusses the importance of diversification and balance in portfolio design, and assesses the client’s appropriate level of tradeoff between targeted portfolio return and the risks associated with achieving that target. U.S. Boston believes that the primary driver of portfolio performance – returns relative to risk – is asset allocation. Thus, our dialogues with clients are structured to inform a target asset allocation that is consistent with their investment objectives. This target allocation is monitored on an ongoing basis, and modified periodically to reflect the changing requirements of the clients, as well as changing market dynamics, relative performance of asset classes, and availability of new asset classes. Asset Management After a thorough discussion of the tradeoffs of the alternative strategies, we assist in choosing a desired asset allocation for each client. Within the asset allocation classes, we believe that broad diversification of assets is critical to long‐term portfolio performance and risk management. We do not believe, for our typical client, that a portfolio composed of individual stocks or bonds can provide appropriate diversification cost‐effectively. Therefore, we recommend the use of a broad range of mutual funds or ETFs that each select securities from within their chosen areas of focus and expertise, e.g., U.S. or international, large cap or small cap, value strategies or growth strategies, etc. The investment vehicles we recommend are selected based on any or all of the following criteria:  Manager style, philosophy, and consistency of track record  Historical performance o Rela ve to appropriate benchmark o In down markets vs up markets (upside capture / downside protec on analysis)  Risk and vola lity  Assets under management / Manager tenure  Management fee structure o No‐load / Load‐waived mutual funds o Transac on fee / Asset‐based pricing Once investment vehicles are approved by the client, we allocate the portfolio based upon the strategic asset allocation. The process is the same for the reinvestment and/or repositioning of assets within an account thereafter. Asset allocation levels are targets only, and actual asset allocations may vary considerably from the targets. Some factors that may cause divergence from targets include relative asset performance, sector‐specific disruptions or opportunities, tax consequences of rebalancing, and changing client preferences. Each client will have the opportunity to place guidelines on the types of investments to be held in their respective portfolio. If a client already holds an investment that is perceived to be in a restricted category, such a security will be sold with the client’s consent and can trigger a taxable event for the client. Certain clients may be restricted from investing in certain securities or are limited in the securities available. For example, a client may be limited by the choices offered through their company’s 401(k) Plan. We understand these restrictions and modify our recommendations accordingly. Por olio Monitoring Services Portfolio monitoring services are available to clients who receive portfolio management services from an unrelated third party, or who manage their own portfolios. U.S. Boston will generate a monitoring report, which will compare investment performance against appropriate industry benchmarks, if available. This service is designed as a tool to assist clients in evaluating their portfolios. Re rement Accounts When the Advisor provides investment advice to clients regarding ERISA retirement accounts

or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or Section 4975 of the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. When deemed to be in the client’s best interest, the Advisor will provide investment advice to a client regarding: a distribution from an ERISA retirement account; a rollover of the ERISA plan to an IRA; rollovers from one ERISA sponsored Plan to another; one IRA to another IRA, or from one type of account to another account (e.g., commission‐based account to fee‐based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Re rement Plan Advisory Services U.S. Boston provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Evalua on and recommenda on of investment choices to be offered within the Plan (ERISA Sec on 3(21)  Evalua on and recommenda on of service providers for Plan opera ons
• Ongoing investment monitoring assistance  Upon request (and for an addi onal fee), provide advice to Individual Plan par cipants These services are provided by U.S. Boston, serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of U.S. Boston’s fiduciary status, the specific services to be rendered, and all direct and indirect compensation the Advisor reasonably expects under the engagement. Wrap Fee Programs U.S. Boston does not participate in or receive compensation from wrap fee programs in conjunction with the Investment Advisory Services described below. Financial Planning Services Our financial planning services are provided on an ongoing basis for clients who establish an ongoing relationship. We can also provide, for clients who intend to manage their own ongoing portfolio decisions, a comprehensive financial plan, as a consulting service. We provide a detailed questionnaire and supporting tools to assist with this process, and we carefully review documents supplied by the client. The plan would include a detailed analysis of the client’s resources, financial goals, and objectives. In general, the financial plan may address any or all the following areas: Personal: Family records, budgeting, personal liability, debt management, and review of financial goals and objectives. Tax & Cash Flow: Income tax and cash flow analysis and planning for current and future years. We will illustrate the impact of various cash flow strategies on a client’s current income tax and future tax liability. Retirement: Analysis of current and future resources and retirement objectives to help the client achieve their retirement goals. Investments: Analysis of investment alternatives and their effect on a client’s portfolio. Insurance & Disability: Life and excess liability insurance coverage analysis, long term care and disability income analysis. Estate: Planning for an orderly distribution of assets at death, minimizing taxes, income needs of surviving dependents and consideration of client objectives. We gather the required information through in‐depth personal interviews. Information gathered includes the following:
• Future goals
• Current financial status
• Current and an cipated sources of income, e.g.: o Employment‐related compensa on o Investment income o Pensions and Social Security o Expected inheritances
• Current and an cipated spending requirements
• Current assets
• Current and an cipated liabili es
• Any an cipated changes in financial status
• A tudes toward risk
• Educa on expenses for dependents and descendants
• Charitable giving
• Second home purchases
• Gi ing strategies for estate planning We will typically present the plan to the client within 60 days of the contract date, provided that all of the information needed to prepare the plan has been promptly provided by the client. Implementation of the financial plan recommendations is entirely at the client’s discretion, and the client is not obligated to implement the plan through U.S. Boston. Should a client choose to implement the recommendations contained in the financial plan report, we recommend that the client work closely with their attorney, accountant, insurance agent, other investment advisor and/or other specialist, as appropriate for their unique situation. A client may choose, after receipt of the plan, to enter into an ongoing advisory relationship with U.S. Boston. Following completion of the initial comprehensive financial plan, we will assist in the implementation of the plan. We continually monitor changes to the client’s financial circumstances and update the financial plan accordingly. Strategic advisory consul ng In addi on to the financial planning areas listed above, we will also consult with clients regarding life decisions. These include, but are not limited to:
• Strategic advisory consul ng for family businesses, e.g., evalua on of expansion plans and acquisi ons, succession planning, planning and assis ng in sale of business. Assets Under Management U.S. Boston is a newly registered financial advisor. We will update our assets under management 120 days from the effective date of our registration.