A. Firm Information
Peddock Capital Advisors, LLC (“PCA” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”)
under the laws of the Commonwealth of Massachusetts. PCA was founded in September 2008 and is primarily
owned and operated by Peter E. Simmons (President and Managing Shareholder) and Matthew E. Simmons
(Chief Operating Officer and Wealth Advisor). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by PCA. For information regarding this
Disclosure Brochure, please contact John DeSimone, Chief Compliance Officer, at (781) 848-0288 or by email at
[email protected].
B. Advisory Services Offered
PCA offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses and retirement plans (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. PCA’s 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.
Wealth Management Services
PCA provides customized wealth management solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary and non-discretionary investment
management and related advisory services, including family office bill pay services and a broad range of
comprehensive consultative services.
Investment Management Services - PCA works closely with each Client to identify their investment goals and
objectives, risk tolerance, and financial situation in order to create a portfolio strategy. PCA will then construct a
portfolio, consisting of mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment
goals. The Advisor may also utilize individual stocks, bonds, derivatives and/or other investments to meet the
needs of its Clients. The Advisor may retain certain legacy investments based on portfolio fit and/or tax
considerations.
Additionally, PCA may render non-discretionary investment management services to Clients relative to variable
life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans
or other products that may not be held by the Client’s primary custodian. In so doing, PCA either directs or
recommends the allocation of client assets among the various investment options that are available with the
product. Client assets are maintained at the specific insurance company or custodian designated by the product.
PCA’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. PCA
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.
PCA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. PCA may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. PCA may recommend specific positions to increase/decrease sector or asset class weightings. The
Advisor may recommend employing cash positions as a possible hedge against market movement. PCA 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.
https://www.peddock.com
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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.
Family Office Services - PCA may also offer family office bill pay services to certain Clients as part of the
Advisor’s wealth management services, pursuant to a wealth management agreement. PCA does accept and
maintain custody of Client accounts that have engaged the Advisor for these services. Please see Item 15 for
more information.
PCA will provide investment advisory services and portfolio management services and will not provide securities
custodial services. All Clients must establish a custody and trading relationship with a “qualified custodian”.
Please see Item 12 – Brokerage Practices.
Consulting Services - PCA will typically provide a variety of consulting services to Clients as a part of the
Advisor’s wealth management services. Clients may also engage with PCA for consulting services as a separate,
stand-alone engagement, pursuant to a written agreement. Services are offered in several areas of a Client’s
financial situation, depending on their goals and objectives.
Generally, such consulting services involve rendering a specific financial consultation based on the Client’s
financial goals and objectives. Consulting seeks to address various needs of the Client’s situation, which may
encompass one or more areas of need, including but not limited to: Wealth Transfers; Philanthropy; Estate
Planning; Trust Administration; Real Estate Transfers; Succession Planning; Educational Funding; Insurance
needs; Retirement Planning; Family Governance; Risk Management.
A financial consultation rendered to the Client will usually include general recommendations for a course of
activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client
start or revise their investment programs, commence or alter retirement savings, establish education savings
and/or charitable giving programs.
PCA may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique
situation. For consulting or ad-hoc engagements, the Advisor may not provide a written summary.
Consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client.
For example, the Advisor has an incentive to recommend that Clients engage the Advisor for wealth
management services or to increase the level of investment assets, as it would increase the amount of advisory
fees paid to the Advisor. 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
PCA 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:
• Investment Oversight Services (ERISA 3(21))
• Investment Due Diligence and Oversight
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
These services are provided by PCA 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 PCA’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 PCA 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 Policy Statement – PCA, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – PCA 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.
• Portfolio Construction – PCA will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
• Investment Management and Supervision – PCA will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
PCA does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by PCA.
E. Assets Under Management
As of December 31, 2022 PCA manages $495,544,938 in Client assets, $480,024,197 of which are managed on
a discretionary basis and $15,520,741 on a non-discretionary basis. PCA also oversees and advises on
$12,243,600 in assets under advisement. Clients may request more current information at any time by contacting
the Advisor.