Heritage Financial Services, LLC (hereinafter referred to as "Heritage") is a fee-based adviser that provides asset management and financial planning services.
A. Charles S. Bean III incorporated Heritage Financial Services under the laws of the state of Massachusetts in 1996 and it became a limited liability company in January 2014. Heritage was registered with the state of Massachusetts from September 2000 until July 2005. Heritage filed for investment adviser registration with the SEC in July of 2005. Heritage is majority owned by Heritage Financial Services, Inc. Charles S. Bean III is the sole owner of Heritage Financial Services, Inc., and serves as Founder and Chairman of Heritage Financial Services, LLC. He has been in the financial services industry since 1990. Sammy A. Azzouz is the President and CEO of Heritage Financial Services, LLC. Additional business information about Chuck, Sammy and Heritage's advisory representatives is disclosed in our Supplemental Brochure.
B. Heritage offers Asset Management and Financial Planning services, the Selection of Independent Money Managers, and Educational Seminars/Webinars, as fully described below: These services may be general in nature or focused on particular areas of interest or need depending upon each client's unique circumstances.
Asset Management and Financial Planning Services An initial free, no obligation meeting is offered to introduce Heritage's services and fees. Once there is mutual agreement and desire to consider working together, we will request a number of documents to help understand your overall financial situation.
Heritage will gather financial information and history from you such as your financial and retirement goals, investment objectives, investment time horizon, tolerance for risk, financial needs, cash flow analysis, education needs, savings tendencies, and other applicable financial information. All information gathered from you is confidential.
After evaluating the information gathered by Heritage, we will present our analysis and recommendations for steps to be taken to work toward your financial goals. Our analysis and recommendations are based on your financial situation at the time and on the financial information you disclose to Heritage. Certain assumptions will be used with respect to anticipated tax rates, future rates of return and inflation as well as the use of past trends and performance of the market and the economy. We will customize your investment portfolio taking into consideration your limitations or restrictions, and your personal financial goals and objectives. We identify a range of possible investment objectives with varying asset class exposures driven by our capital market assumptions to assist us in general portfolio construction to build an investment solution based on your specific needs, risk tolerance, and objectives. If you are satisfied with our recommendations and decide to engage Heritage for asset management and financial planning services, we will have you sign an Investment Advisory Agreement. After we implement the initial portfolio allocation and with your written approval as indicated in the Investment Advisory Agreement, we will provide continuous and ongoing management of your account using our own discretion to determine any changes to the account. Unless otherwise expressly requested by you, Heritage will manage the account and will make changes to the allocation as deemed appropriate by Heritage. Heritage will determine the securities to be purchased and sold in the account and will alter the securities holdings from time to time, without prior consultation with you. These transactions may cause taxable events. Since our investment strategies and advice for each client are based upon their specific financial situation, the investment advice we provide to you may be different or conflicting with the advice we give to other clients regarding the same security or investment.
4 Past performance is in no way an indication of future performance. Heritage cannot offer any guarantees or promises that your financial goals and objectives will be met. Furthermore, you should continue to review and update your plan with Heritage as changes occur with the assumptions used and/or there are changes in your financial situation, goals, or objectives. If your financial situation or investment goals or objectives change, you should notify Heritage promptly. You are advised that the financial advice offered by Heritage may be limited and is not meant to be legal or accounting advice. Based on your specific needs or situation, you may need to seek the services of other professionals such as a banker, an insurance adviser, attorney and/or accountant. You should consult with the attorney, accountant or professional of your choosing to understand legal, tax or other implications of the financial advice provided. Our primary goal is to help our clients identify and pursue their financial goals, thereby enhancing the overall quality of their lives.
Heritage primarily uses institutional open-end mutual funds, closed-end interval funds, and exchange- traded funds (ETFs). However, managed accounts are not exclusively limited to mutual funds and closed-end interval funds, and may include stocks and bonds, certificates of deposits, government securities, money markets, annuities, REITs and other securities. Mutual funds are offered in various share classes. Share classes are priced differently and have varying levels of internal costs. Share classes, other than institutional share classes, involve higher internal costs that over time will cost you more. Institutional share classes, which tend to have low annual expenses, often have higher trading costs. Selecting the lowest cost share class for a client does not mean the least expensive share class.
Heritage considers the anticipated holding period, cost structure, and administrative and transaction costs associated with the product when selecting a share class and will select the lowest cost share class funds available that are appropriate to the specific client situation. We also review the mutual funds held in accounts that come under our management to determine whether a more beneficial share class is available, considering cost, tax implications, and the impact of contingent deferred sales charges. However, there is no way to predict the future and there are occasions where a holding is liquidated sooner or held longer than initially anticipated resulting in higher costs to the client.
When consistent with investment objectives, we also recommend qualified purchasers invest in private placement securities (limited partnerships), which may include debt, equity, and/or pooled investment vehicles. Heritage will receive no additional compensation from investments in private placement securities but will continue to receive asset management fees for those assets under management.
Heritage also offers asset allocation services and investment recommendations to clients regarding variable annuity products, 529 college savings plans, and/or individual employer-sponsored retirement and deferred compensation plans. We either direct or recommend the allocation of assets among the various mutual fund and investment choices offered by the variable annuity, 529 plan or retirement/deferred compensation plan. Your assets are maintained at either the specific fund company or insurance company that issued the variable annuity or 529 plan or at the custodian designated by the sponsor of your retirement/deferred compensation plan.
Heritage Generations Group For younger generation clients, which primarily includes children (i.e., the second generation) or other family members of clients that typically do not require the same level of investment complexity as their parents due to their current financial needs, Heritage offers Heritage Generations Group, a custom service offering that offers the same financial planning and investment services detailed above but may be delivered via Betterment for Advisors digital wealth management platform ("platform") which includes automated investment management services to assist clients in meeting their financial goals.
5 Heritage has engaged Betterment LLC ("Betterment"), a registered investment advisor, to serve as a

sub-advisor to certain clients, executing asset allocation and manager selection decisions made by the investment team at Heritage Financial in accordance with the overall investment objectives that are consistent with the client's financial plan. Clients using the platform authorize Heritage to implement our proprietary, diversified portfolio models using low-cost exchange traded funds ("ETFs") tailored to the client's specific needs. Information about the client's portfolio is available on the platform, which includes their investment style and objectives. Clients can also edit their risk profile or complete a new risk questionnaire directly on the platform. In addition, Betterment services include asset custody and website and mobile applications that allow clients easy access and transaction capabilities online.
Heritage Generations Group Clients using the Betterment for Advisors automated investment management platform will engage with Heritage by execution of its Investment Advisory Agreement and agree to the terms and conditions set forth by Betterment in a separate agreement between the client and Betterment. Betterment offers it investment sub-advisory services through wrap fee program that includes custody and trading services provided by its affiliate, MTG, LLC dba Betterment Securities ("Betterment Securities"), a registered broker-dealer and member of FINRA and SIPC. Additional information regarding Betterment's services is described in Betterment's ADV Part 2A Selection of Independent Money Managers Heritage may recommend that certain clients authorize the active discretionary management of a portion of their assets to certain independent investment managers ("Independent Managers") based on the client's stated objectives. Factors that we take into consideration when making our recommendation include, but are not limited to, the following: methods of analysis, performance, fees, your financial needs, investment goals, risk tolerance, and investment objectives. The terms and conditions under which clients engage the Independent Manager will be set forth in a separate written agreement between Heritage, the client and the Independent Manager. If you decide to engage an Independent Manager, we will provide you with the Independent Manager's disclosure statement. Heritage will provide ongoing monitoring of your account and we will review the account performance. We will receive an annual advisory fee which is based upon a percentage of the market value of the assets being managed by the Independent Manager. Heritage is authorized to terminate or change Independent Managers when, in our sole discretion, we believe that termination or change is in your best interest. Fees charged by Independent Managers will be exclusive of, and in addition to, our fee. Some Independent Managers may impose more strict account requirements than Heritage. As a result, we may adjust account requirements and/or billing policies to facilitate your relationship with the Independent Manager. Heritage is acting as a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code, as applicable to retirement investors and complies with "impartial conduct standards". These are consumer protection standards that ensure advisers adhere to fiduciary norms and basic standards for fair dealing. This means Heritage must give advice that is in the best interest of the retirement investor, charge no more than reasonable compensation and make no misleading statements about investment transactions, compensation and conflicts of interest.
Upon review of clients' employer sponsored retirement plan or other qualified retirement plans, Heritage may recommend clients roll over their employer sponsored retirement plan assets or other qualified retirement plan assets to an IRA, keep the assets in their employer-sponsored retirement or other qualified retirement plan, or review other options available to the client. Before making a recommendation, Heritage will consider some or all of the following factors: retirement alternatives to a rollover, including leaving the money in the current plan, if permitted; investment choices available in 6 the retirement plan(s) and an IRA; the fees and expenses charged under each option; tax consequences, if any; required minimum distributions and age requirements; and protection of assets from creditors and legal judgments. Should Heritage recommend a client rollover their employer sponsored plan or other qualified retirement plan to an IRA managed by Heritage, or recommend the client maintain their assets in the employer sponsored retirement plan or other qualified retirement plan and engage Heritage to manage the assets in the plan, compensation will be earned by Heritage. This presents a conflict of interest because Heritage has an incentive to recommend a client roll plan assets into an IRA that Heritage will manage or to engage Heritage to manage the retirement plan while maintained at the client's employer sponsored retirement plan or other qualified retirement plan for the purpose of generating fee based compensation rather than solely based upon client needs. Heritage attempts to mitigate this conflict of interest by informing clients that they are under no obligation to rollover their assets to a Heritage managed IRA, to use a specific custodian, or to engage Heritage to manage the assets in the plan.
Data Aggregation Services In some situations, Heritage will use third party data management platforms to facilitate management of held away assets. The data management platforms aggregate account information from virtually any online portal where a client account is held and feeds this data into Heritage's portfolio management and financial planning tools. The platforms allow us to avoid being considered to have custody of your funds since we do not have direct access to your log-in credentials to affect trades. We are not affiliated with these platforms in any way and receive no compensation from them for using their platforms. Heritage will assist you in establishing the connection of your held away accounts to the third-party data management platform. Once your account(s) is connected to the platform, Heritage will review the current account allocation. When deemed necessary, Heritage will rebalance (or recommend client rebalance) the account considering your investment goals and risk tolerance. You will not pay an additional fee to have your held away accounts aggregated by the third-party data management platform.
Educational Seminars/Webinars Heritage may host educational seminars on Social Security, and webinars on industry trends and market commentary which may include a guest speaker. Heritage does not charge a fee for seminars or webinars; they are all complimentary.
C. Heritage will tailor the advisory services to your individual needs. You can impose restrictions and/or limitations on investing in certain individual securities or types of securities. We will ask you to complete a client data gathering form and risk tolerance questionnaire to assist us with obtaining information about your financial situation and history. We will conduct an interview and data gathering session to continue the due diligence process. The information gathered by Heritage will assist us in providing you with the requested services and customize the services to your financial situation. Depending on the services you have requested, we will request various financial information and history from you including, but not limited to:
•Financial needs, financial and retirement goals, investment objectives, investment time horizon, bank, investment and retirement statements, other assets and income and expenditures as well as tax returns, education needs, savings tendencies, and any other financial information required by our firm to provide the investment advisory services you have requested. D. Heritage does not participate in any wrap fee programs.
7 E. As of December 31, 2023, we have approximately $2,499,708,338 of client assets under our discretionary management. We also maintain $161,561,879 of assets under our advisement for which we provide monitoring and/or advisory services, but for which we do not retain trading authority.