Overview
- Headquarters
- Hudson, MA
- Total Firm Assets
- $211 million
- Average High-Net-Worth Client Portfolio Size
- $1.8 million
Fee Structure
Primary Fee Schedule (APEX INVESTMENT GROUP DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.25% |
| $500,001 | $2,000,000 | 0.85% |
| $2,000,001 | $5,000,000 | 0.70% |
| $5,000,001 | $10,000,000 | 0.45% |
| $10,000,001 | $20,000,000 | 0.35% |
| $20,000,001 | and above | Negotiable |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,500 | 1.05% |
| $5 million | $40,000 | 0.80% |
| $10 million | $62,500 | 0.62% |
| $50 million | Negotiable | Negotiable |
| $100 million | Negotiable | Negotiable |
Clients
- High-Net-Worth Share of Firm Assets
- 47.01%
- Number of High-Net-Worth Clients
- 56
- Total Client Accounts
- 1,201
- Discretionary Accounts
- 1,092
- Non-Discretionary Accounts
- 109
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 333593
Additional Brochure: APEX INVESTMENT GROUP DISCLOSURE BROCHURE (2026-06-23)
View Document Text
Apex Investment Group, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: June 23, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of Apex Investment Group, LLC (“Apex Investment Group” or the “Advisor”). If you have any questions about the
content of this Disclosure Brochure, please contact the Advisor at 774-351-0805.
Apex Investment Group is a registered investment advisor with the U.S. Securities and Exchange Commission
(“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state
securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about Apex Investment Group to assist you in determining whether to retain
the Advisor.
Additional information about Apex Investment Group and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 333593.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Apex Investment Group. For convenience, the Advisor has combined these documents into a single
disclosure document.
Apex Investment Group believes that communication and transparency are the foundation of its relationship with
clients and will continually strive to provide you with complete and accurate information at all times. Apex Investment
Group encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions
you may have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the last annual filing on March
25, 2026.
• The Advisor has updated its Wealth Management fees. Please see Item 5 for more information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes
in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure
or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 333593. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at 774-351-0805.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 6
D. Wrap Fee Programs ....................................................................................................................................................... 6
E. Assets Under Management ............................................................................................................................................ 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ............................................................................................................................................. 7
B. Fee Billing ....................................................................................................................................................................... 8
C. Other Fees and Expenses ............................................................................................................................................. 8
D. Advance Payment of Fees and Termination .................................................................................................................. 8
E. Compensation for Sales of Securities ............................................................................................................................ 9
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9
Item 7 – Types of Clients ....................................................................................................................................... 9
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10
A. Methods of Analysis ..................................................................................................................................................... 10
B. Risk of Loss .................................................................................................................................................................. 10
Item 9 – Disciplinary Information ....................................................................................................................... 12
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 12
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 12
A. Code of Ethics .............................................................................................................................................................. 12
B. Personal Trading with Material Interest ........................................................................................................................ 13
C. Personal Trading in Same Securities as Clients .......................................................................................................... 13
D. Personal Trading at Same Time as Client ................................................................................................................... 13
Item 12 – Brokerage Practices ............................................................................................................................ 13
A. Recommendation of Custodian[s] ................................................................................................................................ 13
B. Aggregating and Allocating Trades .............................................................................................................................. 14
Item 13 – Review of Accounts ............................................................................................................................ 14
A. Frequency of Reviews .................................................................................................................................................. 14
B. Causes for Reviews ..................................................................................................................................................... 14
C. Review Reports ............................................................................................................................................................ 14
Item 14 – Client Referrals and Other Compensation ........................................................................................ 15
A. Compensation Received by Apex Investment Group ................................................................................................... 15
B. Compensation for Client Referrals ............................................................................................................................... 16
Item 15 – Custody ................................................................................................................................................ 16
Item 16 – Investment Discretion ......................................................................................................................... 16
Item 17 – Voting Client Securities ...................................................................................................................... 16
Item 18 – Financial Information .......................................................................................................................... 16
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 18
Privacy Policy ...................................................................................................................................................... 30
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 3
Item 4 – Advisory Services
A. Firm Information
Apex Investment Group, LLC (“Apex Investment Group” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under
the laws of the Commonwealth of Massachusetts. Apex Investment Group was founded in October 2024 and is
owned and operated by Pedro M. Silva (Partner and Chief Compliance Officer) and Joseph E. Bakaysa (Partner).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by Apex Investment Group.
B. Advisory Services Offered
Apex Investment Group offers wealth management services to individuals, high net worth individuals, trusts, estates,
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. Apex Investment Group'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
The Advisor provides customized wealth management services for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and financial planning
services. These services are listed below.
Investment Management Services – The Advisor provides discretionary investment management services. The
Advisor works closely with each Client to identify their investment goals, objectives, risk tolerance and financial
situation in order to create a portfolio strategy. Apex Investment Group will then construct an investment portfolio,
consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals.
The Advisor may also utilize individual stocks, bonds or structured products to meet the needs of its Clients. The
Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio
strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client.
The Advisor ’s investment strategies are 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.
The Advisor 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.
The Advisor evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. The Advisor may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. The Advisor 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. The Advisor 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 the Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
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
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 4
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.
At no time will the Advisor 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 the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services – The Advisor provides a variety of financial planning and consulting services to Clients
as part of its wealth management services. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. Generally, such financial planning services involve rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
personal savings, education savings, insurance needs and other areas of a Client’s financial situation.
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.
The Advisor may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. Plans or consultations are typically completed within six (6) months of contract date, assuming all
information and documents requested are provided promptly.
Financial planning and 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
investment management services or to increase the level of investment assets with the Advisor, 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.
Use of Independent Managers
The Advisor may recommend that Clients utilize one or more unaffiliated investment managers or investment
platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the
Client’s needs and objectives. In certain instances, the Client may be required to authorize and enter into an
investment management agreement with the Independent Manager[s] that defines the terms in which the
Independent Manager[s] will provide its services. The Advisor will perform initial and ongoing oversight and due
diligence over each Independent Manager to ensure the strategy remains aligned with Clients’ investment objectives
and overall best interests. The Advisor will also assist the Client in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Client, prior to entering into an agreement with
an Independent Manager, will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure
(or a brochure that makes the appropriate disclosures).
Retirement Plan Advisory Services
The Advisor provides 3(21) or 3(38) 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
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 5
Investment Policy Statement (“IPS”) Design and Monitoring
•
• Ongoing Investment Recommendation and Assistance
• Performance Reports
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by the Advisor 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 the Advisor’s fiduciary status, the specific services to be rendered and all
direct and indirect compensation the Advisor reasonably expects under the engagement.
Financial Institution Consulting Services
Apex Investment Group provides investment consulting services to brokerage customers (herein “Brokerage
Customers”) of Mutual Securities, Inc. (herein “MSI”) who provide written consent requesting to receive the Advisor’s
consulting services, pursuant to a written agreement with Apex Investment Group. Consulting services are strictly on
products Clients have purchased through Mutual Securities, Inc. Please see Item 10 – Other Financial Industry
Activities and Affiliations for additional details.
C. Client Account Management
Prior to engaging Apex Investment Group to provide wealth management services, each Client is required to enter
into a written agreement 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 – Apex Investment Group, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Apex Investment Group 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 – Apex Investment Group will develop a portfolio for the Client that is intended to meet
the stated goals and objectives of the Client.
•
Investment Management and Supervision – Apex Investment Group will provide investment management
and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Apex Investment Group does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Apex Investment Group.
E. Assets Under Management
As of December 31, 2025 Apex Investment Group manages $211,108,269 in Client assets, $205,375,671 of which
are managed on a discretionary basis, and $ 5,732,598 are managed on a non-discretionary basis. In addition, the
Advisor has $ 16,457,207 in assets under advisement. Clients may request more current information at any time by
contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 6
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid monthly or quarterly (“Billing Period”) in advance of each calendar Billing Period
pursuant to the terms of the wealth management agreement. Wealth management fees are based on the market value
of assets under management at the end of the prior calendar Billing Period. Wealth management fees are based on the
following tiered schedule:
Assets Under Management ($) Annual Rate (%)
$0-$500,000
$500,001 - $2,000,000
$2,000,001 - $5,000,000
$5,000,001 - $10,000,000
$10,000,001 - $20,000,000
$20,000,001+
1.25%
0.85%
0.70%
0.45%
0.35%
Negotiable
Certain clients may be on a legacy fee arrangement that may differ from the one above. The wealth management fee
in the first Billing Period of service is prorated from the inception date of the account[s] to the end of the first Billing
Period. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the
aggregate assets under management with the Advisor. All securities held in accounts managed by Apex Investment
Group will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.
Use of Independent Managers
As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. The Advisor will only earn its wealth management fee as described above. Independent
Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an
increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements
are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent
Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.00%
annually.
Retirement Plan Advisory Services
Retirement plan advisory fees are charged an annual asset-based fee of up to 1.25%. Fees may be billed monthly
or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the retirement plan advisory agreement.
Retirement plan fees are based on the market value of assets under management at the end of the Billing Period.
Fees may be negotiable depending on the size and complexity of the Plan but shall not exceed the fee range stated
above.
Financial Institution Consulting Services
Apex Investment Group receives a consulting fee based on the assets under MSI’s management from Brokerage
Customers who have provided written consent to MSI to receive the consulting service from Apex Investment Group.
The consulting fee is calculated from the assets under MSI’s management as of the end of a calendar quarter period
multiplied by the annualized rate of 19 basis points. The initial fee is paid only after the completion of one full calendar
quarter period following the date of the executed agreement with MSI.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 7
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from
the Client’s account[s] at the beginning of the respective Billing Period. The amount due is calculated by applying the
Billing Period rate (number of days in the period divided by the number of days in the year) to the total assets under
management with Apex Investment Group at the end of the prior Billing Period. Clients will be provided with a statement,
at least quarterly, from the Custodian reflecting deduction of the wealth management fee. Clients are urged to also
review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the
Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be
deducted by Apex Investment Group to be paid directly from their account[s] held by the Custodian as part of the wealth
management agreement and separate account forms provided by the Custodian.
Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Client’s overall fees may include The Advisor’s
wealth management fee (as noted above) plus investment management fees and/or platform fees charged by the
Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume
responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s].
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan,
depending on the terms of the retirement plan advisory agreement.
Financial Institution Consulting Services
MSI shall pay Apex Investment Group for its consulting services on or before thirty (30) days past the end of each
calendar quarter.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Apex Investment Group, in connection
with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge
securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms
and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds
and other types of investments. The fees charged by Apex Investment Group are separate and distinct from these
custody and execution fees.
In addition, all fees paid to Apex Investment Group for wealth management services are separate and distinct from
the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for
the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a
possible distribution fee. A Client may be able to invest in these products directly, without the services of Apex
Investment Group, but would not receive the services provided by Apex Investment Group which are designed,
among other things, to assist the Client in determining which products or services are most appropriate for each
Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s]
and the fees charged by Apex Investment Group to fully understand the total fees to be paid. Please refer to Item 12
– Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
Apex Investment Group may be compensated for its Wealth management services in advance of the Billing Period in
which services are rendered. Either party may terminate the wealth management agreement, at any time, by providing
advance written notice to the other party. The Client may also terminate the wealth management agreement within five
(5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 8
incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable
by the Client. Upon termination, the Advisor will refund any unearned, prepaid wealth management fees from the
effective date of termination to the end of the Billing Period. The Client’s wealth management agreement with the Advisor
is non-transferable without the Client’s prior consent.
Use of Independent Managers
In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest or a
Client should wish to terminate their relationship with the Independent Manager, the terms for the termination will be set
forth in the respective agreements between the Client or the Advisor and the Independent Manager. The Advisor will
assist the Client with the termination and transition as appropriate.
Retirement Plan Advisory Services
The Advisor may be compensated for its services at the beginning of the Billing Period before services are rendered
pursuant to the terms of the retirement plan advisory agreement. Either party may request to terminate a retirement
plan advisory agreement, at any time, by providing advance written notice to the other party. The Client shall be
responsible for fees up to and including the effective date of termination. If the fees are billed in advance, the Advisor
will refund any unearned, prepaid retirement plan advisory fees from the effective date of termination to the end of
the Billing Period. The Client’s retirement plan services agreement with the Advisor is non-transferable without the
Client’s prior consent.
Financial Institution Consulting Services
Either party may terminate the consulting agreement by providing thirty (30) days advance written notice to the other
party. The Advisor will be entitled to fees up to the date of termination.
E. Compensation for Sales of Securities
Apex Investment Group does not buy or sell securities to earn commissions and does not receive any compensation
for securities transactions in any Client account, other than the wealth management fees noted above.
Insurance Agency Affiliation
Certain Advisory Persons are licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person may earn commission-based compensation for selling insurance products,
including insurance products offered to Clients. Insurance commissions earned by the Advisory Person are separate
and in addition to investment advisory fees. This practice presents a conflict of interest as an Advisory Person who
is also an insurance professional will have an incentive to recommend insurance products to the Client for the purpose
of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractual
or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see
Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
Apex Investment Group does not charge performance-based fees for its wealth management services. The fees
charged by Apex Investment Group are as described in Item 5 above and are not based upon the capital appreciation
of the funds or securities held by any Client.
Apex Investment Group does not manage any proprietary investment funds or limited partnerships (for example, a
mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its
Clients.
Item 7 – Types of Clients
Apex Investment Group offers wealth management services to individuals, high net worth individuals, trusts,
estates, retirement plans, corporations and charities. Apex Investment Group generally does not impose a
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 9
minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Apex Investment Group employs fundamental and technical analysis methods in developing investment strategies
for its Clients. Research and analysis from Apex Investment Group are derived from numerous sources, including
financial media companies, third-party research materials, Internet sources, and review of company activities,
including annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists
generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed.
Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and
trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in
using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the
trend will eventually reoccur, there is no guarantee that Apex Investment Group will be able to accurately predict such
a reoccurrence.
As noted above, Apex Investment Group generally employs a long-term investment strategy for its Clients, as
consistent with their financial goals. Apex Investment Group will typically hold all or a portion of a security for more
than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of
Clients. At times, Apex Investment Group may also buy and sell positions that are more short-term in nature,
depending on the goals of the Client and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. Apex Investment Group will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client
will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
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The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later. There is also a risk that
Authorized Participants are unable to fulfill their responsibilities. Authorized Participants are one of the major parties
involved with ETF creation/redemption mechanism in the markets. The Authorized Participants play a critical role in
the liquidity of ETFs and essentially have the exclusive right to change the supply of ETF shares in the market. If the
Authorized Participants does not fulfill this expected role, there could be an adverse impact on liquidity and the
valuation of an ETF.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
Structured Products
Structured products are securities derived from another asset, such as a security or a basket of securities, an index,
a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in
the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk
associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal
protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment
other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s
ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely
impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal
invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal
guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An
investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon
bond, or option. There may be little or no secondary market for the securities and information regarding independent
market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been
approved for listing on an exchange. Tax treatment of structured products may be different from other investments
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 11
held in the account (e.g., income may be taxed as ordinary income even though payment is not received until
maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Apex Investment Group or its management
persons. Apex Investment Group values the trust Clients place in the Advisor. The Advisor encourages Clients to
perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of
the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 333593.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliation
As noted in Item 5, certain Advisory Persons are licensed insurance professionals. Implementations of insurance
recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the Advisory
Person will receive customary commissions and other related revenues from the various insurance companies whose
products are sold. Advisory Persons are not required to offer the products of any particular insurance company.
Commissions generated by insurance sales do not offset investment advisory fees. This presents a conflict of interest
in recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by the Advisor or Advisory Persons.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more
Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an
Independent Manager. In such arrangements, the Independent Manager or the Advisor may assume responsibility
for calculating the Client’s fees and deduct all fees from the Client’s account[s].
Financial Institution and Consulting Services
Apex Investment Group has an agreement with MSI to provide investment consulting services to certain Brokerage
Customers, as noted in Item 4 above. MSI compensates Apex Investment Group for providing consulting services to.
Brokerage Customers who have purchased products through MSI. This consulting arrangement does not include
assuming discretionary authority over Brokerage Customers’ brokerage accounts or the monitoring of securities.
These consulting services offered to Brokerage Customers includes a general review of Brokerage Customers’
investment holdings, which will result in Apex Investment Group’s Advisory Persons making specific securities
recommendation or offering general investment advice.
This relationship presents conflicts of interest. Conflicts are mitigated by Brokerage Customers consenting to receive
consulting services from Apex Investment Group. In addition, Apex Investment Group will not accept or bill for
additional compensation on asset under MSI’s management, beyond the consulting fees disclosed in Item 5 above.
Advisory Persons of the Advisor will not engage or hold itself as a registered representative of MSI, as Advisory
Persons are not affiliated with or registered to conduct commission-based activities under a broker-dealer.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Apex Investment Group has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary
commitment to each Client. This Code applies to all persons associated with Apex Investment Group (“Supervised
Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 12
Advisor’s duties to each Client. Apex Investment Group and its Supervised Persons owe a duty of loyalty, fairness
and good faith towards each Client. It is the obligation of Apex Investment Group’s Supervised Persons to adhere
not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code
covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please
contact the Advisor at 774-351-0805.
B. Personal Trading with Material Interest
Apex Investment Group allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients. Apex Investment Group does not act as principal in any
transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company.
Apex Investment Group does not have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Apex Investment Group allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase
or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through
policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-
public information controls); gifts and entertainment; outside business activities and personal securities reporting.
When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated
by Apex Investment Group requiring reporting of personal securities trades by its Supervised Persons for review by
the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to
detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Apex Investment Group allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded
afterwards. At no time will Apex Investment Group, or any Supervised Person of Apex Investment Group,
transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Apex Investment Group does not have discretionary authority to select the broker-dealer/custodian for custody and
execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client
assets and authorize Apex Investment Group to direct trades to the Custodian as agreed upon in the wealth
management agreement. Further, Apex Investment Group does not have the discretionary authority to negotiate
commissions on behalf of Clients on a trade-by-trade basis.
Where Apex Investment Group does not exercise discretion over the selection of the Custodian, it may recommend
the Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended
Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not
recommended by Apex Investment Group. However, the Advisor may be limited in the services it can provide if the
recommended Custodian is not engaged. Apex Investment Group may recommend the Custodian based on criteria
such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the
Client, and its reputation and/or the location of the Custodian’s offices.
The Advisor will generally recommend that Clients establish their account[s] with Fidelity Clearing & Custody
Solutions and related entities of Fidelity Investments, Inc. (collectively “Fidelity”) or Charles Schwab & Co., Inc.
(“Schwab”), each a FINRA-registered broker-dealer and member SIPC. Fidelity or Schwab will serve as the Client’s
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 13
“qualified custodian”. The Advisor maintains an institutional relationship with both Fidelity and Schwab, whereby the
Advisor receives economic benefits. Please see Item 14 – Client Referrals and Other Compensation below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters
into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other
services. Apex Investment Group does not participate in soft dollar programs sponsored or offered by any
broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian.
Please see Item 14 below.
2. Brokerage Referrals - Apex Investment Group does not receive any compensation from any third party in
connection with the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Apex Investment Group will
place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts
are traded within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of
any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of
a security into one Client account from another Client’s account[s]). Apex Investment Group will not be obligated to
select competitive bids on securities transactions and does not have an obligation to seek the lowest available
transaction costs. These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. Apex Investment Group will execute its transactions through
the Custodian as authorized by the Client. Apex Investment Group may aggregate orders in a block trade or trades
when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading
day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by
the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other
written statement. This must be done in a way that does not consistently advantage or disadvantage any particular
Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Pedro M. Silva, Chief Compliance
Officer of Apex Investment Group. Formal reviews are generally conducted at least annually or more frequently
depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually.
Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major
changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify Apex Investment Group if changes occur in
the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews
may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s
website so that the Client may view these reports and their account activity. Client brokerage statements will include
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 14
all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with
periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Apex Investment Group
Apex Investment Group may refer Clients to various unaffiliated professionals (e.g. attorneys, accountants, estate
planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Apex Investment
Group may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform - Fidelity
As noted in Item 12, The Advisor has established an institutional relationship with Fidelity to assist the Advisor in
managing Client account[s]. As part of the arrangement, Fidelity also makes available to the Advisor certain research
and brokerage services, including research services obtained by Fidelity directly from independent research
companies. The Advisor may also receive additional services and support from Fidelity. As a result of receiving such
services the Advisor has an incentive to continue to use or expand the use of Fidelity's services. The Advisor
examined this potential conflict of interest when it chose to enter into the relationship with Fidelity and has determined
that the relationship with Fidelity remains in the best interests of the Advisor’s Clients in connection with its fiduciary
obligations, including its duty to seek best execution. Please see Item 12 above.
The Advisor receives access to software, vendors, and related support without cost or at a discount because the
Advisor renders wealth management services to Clients that maintain assets at Fidelity The software and related
systems support benefit the Advisor and indirectly benefit the Clients. However, all services provided may not be
utilized for all Clients.
In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients
should be aware, however, that the receipt of these economic benefits from Fidelity creates a conflict of interest as
these economic benefits may influence the Advisor's recommendation of Fidelity as a Custodian over another
custodian that does not furnish similar software, systems, back-office support, and/or other economic benefits.
Notwithstanding the conflicts noted herein, the Advisor firmly believes that Fidelity provides the Client and the Advisor
with excellent value and support.
Participation in Institutional Advisor Platform - Schwab
The Advisor has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like the Advisor. As a registered investment
advisor participating on the Schwab Advisor Services platform, the Advisor receives access to software and related
support without cost because the Advisor renders Wealth management services to Clients that maintain assets at
Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided
by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests
of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates
a conflict of interest since these benefits can influence the Advisor's recommendation of Schwab over a custodian
that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back office support services as part of its relationship with
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
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Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to the Advisor that may not benefit
the Client, including: educational conferences and events, start-up support, consulting services and discounts for
various service providers. Access to these services creates a financial incentive for the Advisor to recommend
Schwab, which results in a potential conflict of interest. The Advisor believes, however, that the selection of Schwab
as Custodian is in the best interests of its Clients.
B. Compensation for Client Referrals
Certain Clients may be referred to the Advisor by affiliated or unaffiliated individuals or other registered investment
advisors (herein each a "Promoter"). A Promoter will typically receive compensation for the successful referral of a
Client to the Advisor. Referral payments will typically be an ongoing payment which represents a portion of the fee
collected from the Client. The Advisor will compensate a Promoter in accordance with Rule 206(4)-1 of the
Investment Advisers Act of 1940 and any corresponding state securities requirements. The Advisor will only make
referral payments if allowable under these regulations. All referral compensation is paid solely from the advisory
fees earned and collected by the Advisor. The referral fee will not result in any increased or additional charge to the
Client.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions.
Item 16 – Investment Discretion
Apex Investment Group generally has discretion over the selection and amount of securities to be bought or sold in
Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may
be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed
to by Apex Investment Group. Discretionary authority will only be authorized upon full disclosure to the Client. The
granting of such authority will be evidenced by the Client's execution of a wealth management agreement containing
all applicable limitations to such authority. All discretionary trades made by Apex Investment Group will be in
accordance with each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Apex Investment Group does not accept proxy-voting responsibility for any Client. Clients will receive proxy
statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however,
the Client retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Apex Investment Group, nor its management, have any adverse financial situations that would reasonably
impair the ability of Apex Investment Group to meet all obligations to its Clients. Neither Apex Investment Group, nor
any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. Apex Investment Group is
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 16
not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance
fees of $1,200 or more for services to be performed six months or more in the future.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
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Form ADV Part 2B – Brochure Supplement
for
Joseph E. Bakaysa
Partner
Effective: June 23, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Joseph
E. Bakaysa (CRD# 5427559) in addition to the information contained in the Apex Investment Group, LLC (“Apex
Investment Group” or the “Advisor”, CRD# 333593) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Apex Investment Group Disclosure
Brochure or this Brochure Supplement, please contact us at 774-351-0805.
Additional information about Mr. Bakaysa is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5427559.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 18
Item 2 – Educational Background and Business Experience
Joseph E. Bakaysa, born in 1983, is dedicated to advising Clients of Apex Investment Group as a Partner. Mr.
Bakaysa earned a Bachelor of Science in Finance from Bentley University in 2005. Additional information regarding
Mr. Bakaysa’s employment history is included below.
Employment History:
Partner, Apex Investment Group, LLC
Investment Advisor Representative, The Patriot Financial Group LLC
Registered Representative, Cetera Financial Specialists
Registered Representative, Securities America, Inc.
Relationship Manager, Citizen Bank
01/2025 to Present
07/2018 to 12/2024
12/2022 to 12/2023
07/2018 to 12/2022
12/2013 to 07/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Bakaysa. Mr. Bakaysa has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Bakaysa.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Bakaysa.
However, we do encourage you to independently view the background of Mr. Bakaysa on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
5427559.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Bakaysa is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Bakaysa’s role with Apex Investment Group. As an insurance professional, Mr. Bakaysa will
receive customary commissions and other related revenues from the various insurance companies whose products
are sold. Mr. Bakaysa is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Bakaysa or the Advisor. Mr. Bakaysa spends approximately 5% of his time per month
in this capacity.
Item 5 – Additional Compensation
Mr. Bakaysa has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Bakaysa serves as a Partner of Apex Investment Group and is supervised by Pedro Silva, the Chief Compliance
Officer. can be reached at 774-351-0805. Apex Investment Group has implemented a Code of Ethics, an internal
compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Apex
Investment Group. Further, Apex Investment Group is subject to regulatory oversight by various agencies. These
agencies require registration by Apex Investment Group and its Supervised Persons. As a registered entity, Apex
Investment Group is subject to examinations by regulators, which may be announced or unannounced. Apex
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 19
Investment Group is required to periodically update the information provided to these agencies and to provide various
reports regarding the business activities and assets of the Advisor
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 20
Form ADV Part 2B – Brochure Supplement
for
Pedro M. Silva
Partner and Chief Compliance Officer
Effective: June 23, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Pedro
M. Silva (CRD# 4721125) in addition to the information contained in the Apex Investment Group, LLC (“Apex
Investment Group” or the “Advisor”, CRD# 333593) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Apex Investment Group Disclosure
Brochure or this Brochure Supplement, please contact us at 774-351-0805.
Additional information about Mr. Silva is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4721125.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 21
Item 2 – Educational Background and Business Experience
Pedro M. Silva, born in 1975, is dedicated to advising Clients of Apex Investment Group as a Partner and Chief
Compliance Officer. Mr. Silva earned a BA Psychology; BA Sociology from Clark University in 1997. Additional
information regarding Mr. Silva’s employment history is included below.
Employment History:
Partner and Chief Compliance Officer, Apex Investment Group, LLC
Investment Advisor Representative, The Patriot Financial Group, LLC
Financial Advisor, Cetera Financial Specialists
Financial Advisor, Securities America
Financial Advisor, LPL Financial
01/2025 to Present
02/2015 to 12/2024
12/2022 to 12/2024
06/2018 to 12/2022
02/2009 to 07/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Silva. Mr. Silva has never been involved
in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or
administrative proceedings against Mr. Silva.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Silva.
However, we do encourage you to independently view the background of Mr. Silva on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4721125.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Silva is also a licensed insurance professional. Implementations of insurance recommendations are separate and
apart from Mr. Silva’s role with Apex Investment Group. As an insurance professional, Mr. Silva will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr. Silva
is not required to offer the products of any particular insurance company. Commissions generated by insurance sales
do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of
the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Silva or
the Advisor. Mr. Silva spends approximately 5% of his time per month in this capacity.
Mr. Silva is also a Musician, Composer, and Producer. Mr. Silva spends approximately 10% of his time per month in
this capacity.
Item 5 – Additional Compensation
Mr. Silva has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Silva serves as the Chief Compliance Officer of Apex Investment Group. Mr. Silva can be reached at 774-351-
0805. Apex Investment Group has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Apex Investment Group. Further, Apex
Investment Group is subject to regulatory oversight by various agencies. These agencies require registration by Apex
Investment Group and its Supervised Persons. As a registered entity, Apex Investment Group is subject to
examinations by regulators, which may be announced or unannounced. Apex Investment Group is required to
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 22
periodically update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 23
Form ADV Part 2B – Brochure Supplement
for
Gregory S. Norris, CFP®
Investment Advisor Representative
Effective: June 23, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Gregory
S. Norris, CFP® (CRD# 1668830) in addition to the information contained in the Apex Investment Group, LLC (“Apex
Investment Group” or the “Advisor”, CRD# 333593) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Apex Investment Group Disclosure
Brochure or this Brochure Supplement, please contact us at 774-351-0805 or by email at info@apexinvest.org.
Additional information about Mr. Norris is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1668830.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 24
Item 2 – Educational Background and Business Experience
Gregory S. Norris, CFP®, born in 1951, is dedicated to advising Clients of Apex Investment Group as an Investment
Advisor Representative. Mr. Norris earned his Bachelor of Arts in History from the University of Rochester in 1973.
Mr. Norris also earned his MBA from the University of Rochester in 1979. Additional information regarding Mr. Norris’s
employment history is included below.
Employment History:
05/2025 to Present
07/2018 to 07/2025
10/2017 to 07/2025
Investment Advisor Representative, Apex Investment Group, LLC
Registered Representative, Purshe Kaplan Sterling Investments, Inc.
President, Chief Executive Officer, and Chief Compliance Officer, Barrell
Investment Group, Inc.
CERTIFIED FINANCIAL PLANNER® Professional
I am certified for financial planning services in the United States by Certified Financial Planner Board of Standards,
Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL PLANNER® professional or a CFP®
professional, and I may use these and the other certification marks (the “CFP Board Certification Marks”) that Certified
Financial Planner Board of Standards Center for Financial Planning, Inc. has licensed to CFP Board in the United
States. The CFP® certification is voluntary. No federal or state law or regulation requires financial planners to hold
the CFP® certification. You may find more information about the CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics. To
become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university and complete CFP
Board-approved coursework at a college or university through a CFP Board Registered Program. The
coursework covers the financial planning subject areas CFP Board has determined are necessary for the
competent and professional delivery of financial planning services, as well as a comprehensive financial plan
development capstone course. A candidate may satisfy some of the coursework requirement through other
qualifying credentials. CFP Board implemented the bachelor’s degree or higher requirement in 2007 and the
financial planning development capstone course requirement in March 2012. Therefore, a CFP® professional
who first became certified before those dates may not have earned a bachelor’s or higher degree or
completed a financial planning development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal financial planning
process, or 4,000 hours of apprenticeship experience that meets additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP® Professionals
Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and Standards of Conduct
(“Code and Standards”), which sets forth the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements to remain
certified and maintain the right to continue to use the CFP Board Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a commitment to CFP
Board, as part of the certification, to act as a fiduciary, and therefore, act in the best interests of the client, at
all times when providing financial advice and financial planning. CFP Board may sanction a CFP®
professional who does not abide by this commitment, but CFP Board does not guarantee a CFP®
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 25
professional's services. A client who seeks a similar commitment should obtain a written engagement that
includes a fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to maintain
competence, demonstrate specified levels of knowledge, skills, and abilities, and keep up with developments
in financial planning. Two of the hours must address the Code and Standards.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Norris. Mr. Norris has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Norris.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud;
false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or
extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or
disciplinary events to disclose regarding Mr. Norris.
However, we do encourage you to independently view the background of Mr. Norris on the Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 1668830.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Norris is also a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. Norris’s role with Apex Investment Group. As an insurance professional, Mr. Norris will receive
customary commissions and other related revenues from the various insurance companies whose products are sold.
Mr. Norris is not required to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Norris or the Advisor. Mr. Norris currently does not engage in offering insurance products.
Item 5 – Additional Compensation
Mr. Norris has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Norris serves as an Investment Advisor Representative of Apex Investment Group and is supervised by Pedro
Silva, the Chief Compliance Officer. Mr. Silva can be reached at 774-351-0805.
Apex Investment Group has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Apex Investment Group. Further, Apex
Investment Group is subject to regulatory oversight by various agencies. These agencies require registration by Apex
Investment Group and its Supervised Persons. As a registered entity, Apex Investment Group is subject to
examinations by regulators, which may be announced or unannounced. Apex Investment Group is required to
periodically update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 26
Form ADV Part 2B – Brochure Supplement
for
Edmond C. Griffin, CFA®
Partner
Effective: June 23, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Edmond C. Griffin, CFA®, (CRD# 8287233) in addition to the information contained in the Apex Investment Group,
LLC (“Apex Investment Group” or the “Advisor”, CRD# 333593) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the Apex Investment Group
Disclosure Brochure or this Brochure Supplement, please contact us at 7743510805 or by email at
info@apexinvest.org.
Additional information about Mr. Griffin is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 8287233.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 27
Item 2 – Educational Background and Business Experience
Edmond C. Griffin, CFA®, born in 1978, is dedicated to advising Clients of Apex Investment Group as a Partner. Mr.
Griffin earned an MBA from the Tuck School of Business at Dartmouth College in 2008. Mr. Griffin also earned a
Bachelor of Science in Economics from Vanderbilt University in 2000. Additional information regarding Mr. Griffin’s
employment history is included below.
Employment History:
Partner, Apex Investment Group, LLC
Portfolio Manager, Wellington Management
Equity Analyst, BlackRock
Equity Research Associate, State Street Research & Management
06/2026 to Present
02/2008 to 05/2026
03/2003 to 06/2006
03/2001 to 03/2003
Chartered Financial Analyst™ (“CFA®”)
The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and awarded
by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour examinations over
two to four years. The three levels of the CFA® Program test a wide range of investment topics, including ethical
and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio
management and wealth planning. Also, CFA® charter holders must have at least four years of acceptable
professional experience in the investment decision-making process and must commit to abide by, and annually
reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of Professional Conduct. CFA® is a
trademark owned by CFA® Institute.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Griffin. Mr. Griffin has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Griffin.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Griffin.
However, we do encourage you to independently view the background of Mr. Griffin on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
8287233.
Item 4 – Other Business Activities
Mr. Griffin is dedicated to the investment advisory activities of Apex Investment Group’s Clients. Mr. Griffin does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Griffin is dedicated to the investment advisory activities of Apex Investment Group’s Clients. Mr. Griffin does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Griffin serves as a Partner of Apex Investment Group and is supervised by Pedro Silva, the Chief Compliance
Officer. Mr. Silva can be reached at 7743510805.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 28
Apex Investment Group has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Apex Investment Group. Further, Apex
Investment Group is subject to regulatory oversight by various agencies. These agencies require registration by
Apex Investment Group and its Supervised Persons. As a registered entity, Apex Investment Group is subject to
examinations by regulators, which may be announced or unannounced. Apex Investment Group is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 29
Privacy Policy
Effective: June 23, 2026
Our Commitment to You
Apex Investment Group, LLC (“Apex Investment Group” or the “Advisor”) is committed to safeguarding the use of
personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor,
as described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. Apex Investment Group (also referred to as
"we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the management or
servicing of our relationship with you.
Apex Investment Group does not sell your non-public personal information to anyone. Nor do we provide such
information to others except for discrete and reasonable business purposes in connection with the servicing and
management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how
we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number
Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s
personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 30
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
to: processing
No
Not Shared
Yes
Yes
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide agreed
upon services to you, consistent with applicable law, including but not
limited
transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
Apex Investment Group does not disclose, and does not intend to disclose,
personal information with non-affiliated third parties to offer you services.
Certain laws may give us the right to share your personal information with
financial institutions where you are a customer and where Apex Investment
Group or the client has a formal agreement with the financial institution.
We will only share information for purposes of servicing your
accounts, not for marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and persons
that we believe to be your authorized agent[s] or representative[s].
No
Not Shared
Information About Former Clients
Apex Investment Group does not disclose and does not intend to disclose,
non-public personal information to non-affiliated third parties with respect
to persons who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at 774-351-0805.
Apex Investment Group, LLC
145 Main St, Hudson, MA 01749
Phone: 774-351-0805 I Fax: 774-351-0802
https://www.apexinvest.org/
Page 31