A. Firm Information
1620 Investment Advisors, Inc. (“1620 Investment Advisors” or the “Advisor”) is a registered investment advisor
with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Corporation in 1999
under the laws of the Commonwealth of Massachusetts and is primarily owned by Todd A. Johnston (President
and Chief Compliance Officer) and Michelle R. Johnston (Treasurer). This Disclosure Brochure provides
information regarding the qualifications, business practices, and advisory services provided by 1620 Investment
Advisors.
B. Advisory Services Offered
1620 Investment Advisors offers investment advisory services to individuals, high net worth individuals, families,
trusts, estates, retirement plans, corporations, and charitable organizations. (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. 1620 Investment Advisors’ fiduciary commitment is further described in the Advisor’s Code of
Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading.
Investment Management Services
1620 Investment Advisors provides customized investment advisory solutions for its Clients. This is achieved
through ongoing personal Client contact and interaction while providing discretionary investment management
and related advisory services. In order to create an investment strategy, 1620 Investment Advisors works with
each Client to identify their investment goals and objectives, risk tolerance, and assesses their personal financial
situation. The Advisor will construct a portfolio for each Client that utilizes one or more of the Advisor’s model
portfolios, or a customized portfolio, depending on the needs of the Client. The Advisor may also utilize other
types of investments, as appropriate, to meet the needs of particular Clients.
The Advisor will generally place Clients into either a “Balanced Accounts” strategy or a “Fixed Income Accounts”
strategy. “Balanced Accounts” portfolios consist of individual equity securities, diversified mutual funds, and/or
exchange-traded funds, fixed income funds, and individual fixed income securities. “Fixed Income Accounts”
portfolios will be constructed using individual fixed income securities or fixed income funds and have no equity
exposure.
1620 Investment Advisors’s investment approach is primarily long-term focused, but the Advisor may buy, sell or
re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to
market conditions. 1620 Investment Advisors will construct, implement, and monitor the portfolio to ensure it
meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio,
subject to acceptance by the Advisor.
1620 Investment Advisors evaluates and selects investments for inclusion in Client portfolios only after applying
its internal due diligence process. 1620 Investment Advisors may recommend, on occasion, redistributing
investment allocations to diversify the portfolio. 1620 Investment Advisors may recommend specific positions to
increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible
hedge against market movement. 1620 Investment Advisors may recommend selling positions for reasons that
include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific
security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk
tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk
tolerance.
At no time will 1620 Investment Advisors accept or maintain custody of a Client’s funds or securities, except for
the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their designated
account[s] at the Custodian, pursuant to the terms of the Client investment advisory agreement. For additional
information, please see Item 12 – Brokerage Practices.
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Retirement 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 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 or to roll over
the assets to an IRA, or recommend a similar transaction including 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.
Research and Sub-Advisory Services
1620 Investment Advisors may offer its research services to, and/or serve as an investment sub-advisory for,
other financial service firms.
Consulting Services
1620 Investment Advisors may provide financial consulting services for certain Clients, pursuant to a written
agreement. Various services are offered to Clients based on their goals, objectives and financial situation.
Financial analysis, planning and consulting recommendations may pose a potential conflict between the interests
of the Advisor and the interests of the Client. Clients are not obligated to implement any recommendations made
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through
the Advisor.
Retirement Plan Advisory Services
1620 Investment Advisors 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:
• Vendor analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Oversight (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) assistance
These services are provided by 1620 Investment Advisors 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 1620 Investment 1620 Investment Advisor’s
fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor
reasonably expects under the engagement.
C. Client Account Management
Prior to engaging 1620 Investment Advisors to provide investment advisory services, each Client is required to
enter into one or more agreements with the Advisor that define the terms, conditions, authority and
responsibilities of the Advisor and the Client. These services may include:
• Establishing an Investment Strategy – 1620 Investment Advisors, in connection with the Client, will
develop a strategy that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – 1620 Investment Advisors will develop a strategic asset allocation that is targeted to
meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
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• Portfolio Construction – 1620 Investment Advisors will develop a portfolio for the Client that is intended to
meet the stated goals and objectives of the Client.
• Investment Management and Supervision – 1620 Investment Advisors will provide investment
management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
1620 Investment Advisors does not manage or place Client assets into a wrap fee program. Investment
management services are provided directly by 1620 Investment Advisors.
E. Assets Under Management
As of December 31, 2023, 1620 Investment Advisors manages $181,420,555 in Client assets, $177,155,061 of
which are managed on a discretionary basis and $4,265,494 on a non-discretionary basis. Clients may request
more current information at any time by contacting the Advisor.