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Item 1: Cover Page
Ashwood Advisors, LLC
Form ADV Part 2A
Investment Adviser Brochure
5 North Meadows Road
Medfield MA, 02052
Phone: (508) 359-9442
Fax: (508) 359-2494
www.geremiainvestments.com
April 2026
This Brochure provides information about the qualifications and business practices of Ashwood
Advisors, LLC (“we,” “us,” “our”). If you have any questions about the contents of this Brochure,
please contact Stephen Geremia, Managing Member and Chief Compliance Officer, at (508)
359-9442 or sgeremia@geremiainvestments.com.
Additional information about our Firm is also available at www.adviserinfo.sec.gov. The
information in this Brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any state securities authority.
We are a registered investment adviser. Please note that use of the term “registered
investment adviser” and a description of the Firm and/or our employees as “registered” does
not imply a certain level of skill or training. For more information on the qualifications of the
Firm and our employees who advise you, we encourage you to review this Brochure and the
Brochure Supplement(s).
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Item 2: Summary of Material Changes
In this Item of Ashwood Advisors, LLC’s (“Ashwood,” or the “Firm,” “we,” “us,” “ours,”) Form
ADV 2, we are required to discuss any material changes that have been made to Form ADV
since the last Annual Amendment.
Material Changes since the Last Update
Since the filing of our Annual Amendment on March 31, 2025, we have the following material
changes to report:
• We rewrote Forms ADV 2A and 2B, and as such, will deliver these documents in their
entirety to all clients.
Annual Update
You will receive a summary of any material changes to our Form ADV brochure within 120 days
of our fiscal year end. We may also provide updated disclosure information about material
changes on a more frequent basis. Any summaries of changes will include the date of the last
annual update of the ADV.
The Supplement to our Form ADV Brochure (Form ADV Part 2B) provides you with information
regarding our employees that provide investment advice.
Full Brochure Available
Our Form ADV may be requested at any time, without charge by contacting Stephen Geremia,
Managing Member and Chief Compliance Officer, at (508) 359-9442 or
sgeremia@geremiainvestments.com. Additional information about the Firm is also available via
the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website also provides information
about any employees affiliated with the Firm who are registered as investment advisor
representatives.
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Item 3: Table of Contents
Item 1: Cover Page .......................................................................................................................... 1
Item 2: Summary of Material Changes ........................................................................................... 2
Item 4: Advisory Business ............................................................................................................... 4
Item 5: Fees and Compensation ..................................................................................................... 7
Item 6: Performance-Based Fees and Side-by-Side Management ............................................... 11
Item 7: Types of Clients ................................................................................................................. 12
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ......................................... 13
Item 9: Disciplinary Information ................................................................................................... 16
Item 10: Other Financial Industry Activities and Affiliations ........................................................ 17
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading . 18
Item 12: Brokerage Practices ........................................................................................................ 20
Item 13: Review of Accounts ......................................................................................................... 22
Item 14: Client Referrals and Other Compensation ..................................................................... 23
Item 15: Custody ........................................................................................................................... 24
Item 16: Investment Discretion .................................................................................................... 25
Item 17: Voting Client Securities .................................................................................................. 26
Item 18: Financial Information ..................................................................................................... 27
Form ADV Part 2B – Investment Advisor Brochure Supplement ................................................. 28
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Item 4: Advisory Business
Firm Information
This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications,
business practices, and the advisory services provided by Ashwood Advisors, LLC (“Ashwood,”
or “the Firm”, “we”, “us”, “ours”).
We were founded in 1999 and are owned and operated by Stephen Geremia, Managing
Member and Chief Compliance Officer.
Types of Advisory Services
Financial Planning
We offer financial planning services, which may include a review of all aspects of a client’s
current financial situation, including the following components: cash management, risk
management, insurance, education funding, goal setting, retirement planning, estate and
charitable giving planning, tax planning, and capital needs planning. Clients understand that
when we are engaged to address only certain components, the client’s overall financial and
investment issues may not be taken into consideration.
We meet with the client to review risk tolerance, financial goals and objectives, and time
horizons. Additional meetings may include a review of additional financial information; sources
of income, assets owned, existing insurance, liabilities, wills, trusts, business agreements, tax
returns, investments, and personal and family obligations.
The financial plan may include both long and short-term considerations, depending upon the
individual scenario. Upon completion a plan is presented to the client and the client is provided
with recommendations that are deemed to be compatible with the client’s stated goals and
objectives. An implementation schedule is reviewed with the client to determine which steps
will be pursued, and with whom the steps may be accomplished. The client is under no
obligation to utilize the Firm to implement the advice or plan. Clients may choose all or certain
components of advice and recommendations and can implement the recommendations
through the service providers of their choice.
Wealth Management
We provide continuous advice to clients regarding investment of client funds based on the
individual needs of the client. Through personal discussions in which goals and objectives based
on a client’s particular circumstances are established, we develop a client’s personal investment
policy and create and manage a portfolio based on that policy. We will manage advisory
accounts on a discretionary basis only. Account supervision is guided by the stated objectives of
the client (i.e., maximum capital appreciation, growth, income, growth, and income, etc.).
We will create a portfolio consisting of one or all of the following: individual equities, bonds,
other investment products, no-load or load-waived mutual funds, and ETFs. We will allocate the
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client’s assets among various investments taking into consideration the overall management
style selected by the client. Mutual funds will be selected on the basis of any or all of the
following criteria: the fund’s performance history; the industry sector in which the fund invests;
the track record of the fund’s manager; the fund’s investment objectives; the fund’s
management style and philosophy; and the fund’s management fee structure. Portfolio
weighting between funds and market sectors will be determined by each client’s individual
needs and circumstances.
We may also provide advice about any type of legacy position or investment otherwise held in
client portfolios.
Consulting
We also offer investment advice on a more limited basis. This may include advice on reviewing
a client’s existing portfolio only an isolated area(s) of concern such as estate planning,
retirement planning, or any other specific topic. Additionally, we may provide advice on non-
securities matters; generally, in connection with the rendering of estate planning, insurance,
and/or annuity advice.
Advice is provided through consultation with the client and may include determination of
financial objectives, identification of financial problems, cash flow management, tax planning,
insurance review, investment management, education funding, retirement planning, and estate
planning.
Tailored Relationships
We tailor investment advisory services to the individual needs of the client. Our clients are
allowed to impose restrictions on the investments in their account. All limitations and
restrictions placed on accounts must be presented to us in writing.
Wrap Fee Programs
We do not sponsor, manage, or participate in a Wrap Fee Program.
Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries 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.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
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• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Assets Under Management
As of December 31, 2025, we managed $126,948,136 in client assets; $71,710,879 managed on
a discretionary basis, and $55,237,257 on a non-discretionary basis.
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Item 5: Fees and Compensation
We base our fees on hourly charges, fixed fees, and a percentage of assets under management,
which are described below.
Compensation – Financial Planning /Consulting
Financial Planning/Consulting fees will generally be charged on an hourly basis no more than
$500 per hour. Fees are due and payable as services are rendered.
Compensation – Wealth Management Services
Wealth Management fees are charged a fee as follows:
Assets Under Management
$0- $49,999
$50,000 to $499,999
Annual Fee
1.8125%
1.0625%
$500,000 to $999,999
0.8125%
$1,000,000 to $3,000,000
0.5625%
$3,000,001 and above
Negotiated
For example (based on quarterly billing period):
A client with $1,200,000 under management would pay $1,687.50 on a quarterly basis.
Assets Under Management
Quarterly fee
Annual Fee
$1,200,000
$1,687.50
$6,750.00
At our discretion, client accounts from one household may be consolidated with client accounts
from other households to aggregate account values for fee calculations. The annual fee may
then be based on an aggregate value of all accounts within the combined household.
Fees are billed quarterly in arrears based on the amount of assets managed as of the close of
business on the last business day of the quarter, as further described below.
Account values in the Commonwealth reporting system will be used for our firm’s quarterly fee
calculations for advisory accounts custodied at National Financial Services (NFS). Although
account holdings and asset valuations should generally match, month-end market values
reflected in Commonwealth's Practice 360 reporting system sometimes differ from those
provided by NFS on their month-end statements. The three most common reasons why these
values may differ are (i) differences in the manner in which accrued interest is calculated, (ii)
differences in the date upon which "as of" dividends and capital gains are reported, and (iii)
differences in whether settlement date valuations or trade date valuations are used.
If you have any questions or believe there are material discrepancies between your NFS
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custodial statement and Commonwealth's reporting system, please contact us. The
Commonwealth report valuations are available online via your Investor360 account or you may
request a copy from your advisory representative. If the account is established or closed during
the middle of a month, the client will pay a pro-rated portion of the fee based upon the number
of days the account was under the Firm’s management.
Calculation and Payment
The specific manner in which we charge fees is established in a client’s written agreement with
us. Clients may elect to be invoiced directly for fees or to authorize us to directly debit fees
from client accounts.
Upon termination of any account, any prepaid, unearned fees will be promptly refunded, and
any earned, unpaid fees will be due and payable.
In no case will more than $1,200 be collected from the client more than 6 months in advance.
Other Fees
There are no additional types of fees or expenses that our clients pay in connection with the
delivery of advisory services.
Agreement Terms
Either party may terminate an agreement at any time by notifying the other in writing. If the
client made an advance payment, we would refund any unearned portion of the advance
payment.
If the client made a payment in arrears, we would collect any earned yet unpaid fees.
Cash Balances
Some of your assets may be held as cash and remain uninvested. Holding a portion of your
assets in cash and cash alternatives, i.e., money market fund shares, may be based on your
desire to have an allocation to cash as an asset class, to support a phased market entrance
strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to
pay fees or to provide for asset protection during periods of volatile market conditions. Your
cash and cash equivalents will be subject to our investment advisory fees unless otherwise
agreed upon. You may experience negative performance on the cash portion of your portfolio if
the investment advisory fees charged are higher than the returns you receive from your cash.
Retirement Plan Rollover Recommendations
As part of our investment advisory services to our clients, we may recommend that clients roll
assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account
(collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP
IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the
client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from
Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts.
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If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge
the client an asset-based fee as set forth in the advisory agreement the client executed with our
firm. This creates a conflict of interest because it creates a financial incentive for our firm to
recommend the rollover to the client (i.e., receipt of additional fee-based compensation).
Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover,
if clients do complete the rollover, clients are under no obligation to have the assets in an IRA
advised on by our firm. Due to the foregoing conflict of interest, when we make rollover
recommendations, we operate under a special rule that requires us to act in our clients’ best
interests and not put our interests ahead of our clients.’
Under this special rule’s provisions, we must:
• meet a professional standard of care when making investment recommendations (give
prudent advice);
• never put our financial interests ahead of our clients’ when making recommendations
(give loyal advice);
• avoid misleading statements about conflicts of interest, fees, and investments;
•
follow policies and procedures designed to ensure that we give advice that is in our
clients’ best interests;
• charge no more than a reasonable fee for our services; and
• give clients basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company
plan. Also, current employees can sometimes move assets out of their company plan before
they retire or change jobs. In determining whether to complete the rollover to an IRA, and to
the extent the following options are available, clients should consider the costs and benefits of
a rollover. Note that an employee will typically have four options in this situation:
1. leaving the funds in the employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance
of understanding the differences between these types of accounts, we will provide clients with
a written explanation of the advantages and disadvantages of both account types and
document the basis for our belief that the rollover transaction we recommend is in your best
interests.
General Information on Compensation and Other Fees
In certain circumstances, fees, account minimums, and payment terms are negotiable
depending on client’s unique situation – such as the size of the aggregate related party
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portfolio size, family holdings, low-cost basis securities, or certain passively advised investments
and pre-existing relationships with clients. Certain clients may pay more or less than others
depending on the amount of assets, type of portfolio, or the time involved, the degree of
responsibility assumed, complexity of the engagement, special skills needed to solve problems,
the application of experience and knowledge of the client’s situation.
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses which shall be incurred by the client. Clients may incur certain charges imposed by
custodians, brokers, third party investment and other third parties such as fees charged by
managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire
transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to our fees, and we shall
not receive any portion of these commissions, fees, and costs.
All fees paid to us for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds to their shareholders. These fees and expenses are
described in each fund’s prospectus. These fees will generally include a management fee, other
expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may
pay an initial or deferred sales charge.
A client could invest in a mutual fund directly, without our services. In that case, the client
would not receive our services, which are designed, among other things, to assist the client in
determining which mutual funds are most appropriate to each client’s financial condition and
objectives. Accordingly, the client should review both the fees charged by the funds and the
fees charged by us to fully understand the total amount of fees to be paid by the client and to
thereby evaluate the advisory services being provided.
Clients should note that similar advisory services may (or may not) be available from other
registered investment advisers for similar or lower fees.
Mutual Fund Share Class Selection
Similar investment management services may (or may not) be available from other investment
advisers for a lower fee. Investment management fees, which include investment management
and transaction costs, may be more or less costly than paying for the services separately,
depending upon the investment advisory fees charged, the number of transactions for the
account, the mutual fund share class you purchase and the underlying 12(b)-1 fee, and the level
of brokerage and other fees that would be payable if you obtained the services available
individually.
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Item 6: Performance-Based Fees and Side-by-Side Management
We do not charge performance-based fees.
“Performance-based fees” are fees based on the capital gains or capital appreciation in an
account. “Side-by-side management” refers to the practice of managing both accounts that are
charged a performance-based fee and accounts that are charged other types of fees, such as
asset-based fees and hourly fees. Because we do not charge performance-based fees, we do
not engage in side-by-side management.
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Item 7: Types of Clients
Types of Clients
We provide services to individuals, high net worth individuals, and small businesses.
Account Minimums
We have a minimum account size of $250,000. We may group certain related client accounts
for the purposes of achieving the minimum account size and determining the annualized fee.
Accounts below these minimums may be accepted on an individual basis at our discretion. Such
circumstances may include, but not be limited to, 1) additional assets will soon be deposited or
2) the client has other accounts with the Firm.
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
We conduct economic analysis and attempt to analyze and determine economic trends.
Additionally, we conduct fundamental analysis. Fundamental analysis generally involves
assessing a company’s or security’s value based on factors such as sales, assets, markets,
management, products and services, earnings, and financial structure. Other security analysis
methods may include charting, technical and cyclical analysis.
When evaluating the underlying a specific security, we utilize the fi360 Fiduciary Score™
quantitative evaluation of how well a fund meets a minimum set of due diligence criteria
defined by fi360 to reflect prudent fiduciary management. The criteria include total returns,
risk-adjusted returns, expenses, and other portfolio statistics. The fi360 Fiduciary Score™
Quarter is calculated on a quarterly basis for every mutual fund, ETF and IGSA with at least 3
years of history. Each investment's specific share class is evaluated against the thresholds and
point system identified in the fi360 Fiduciary Score™ Methodology available at fi360.com or in
the Glossary (Note: Insurance Group Separate Accounts (IGSAs) are ranked relative to their
corresponding mutual fund/ETF peer group). The points are totaled and used to calculate a
percentile rank which becomes the fi360 Fiduciary Score™ Quarter. The fi360 Fiduciary
Score™ Average, also calculated on a quarterly basis, is a three-year rolling average of an
investment’s quarterly Scores. If the investment does not have three years’ worth of Scores,
all available historical quarterly Scores are used to calculate the Average Score.
Furthermore, we base our investment advice on traditionally accepted principles of asset
allocation using risk profiles, time frame and objective. Each investment must meet Fi360
Fiduciary Score Criteria (11 specified criteria):
1. Inception Date: The investment must have at least a 3-year track history.
2. Manager Tenure: The investment manager must have at least a 2-year track history.
(Most senior manager’s tenure)
3. Assets: The investment must have at least 75 million under management. (Total across
all share classes for funds/ETFs)
4. Composition: The investment's allocation to its primary asset class should be greater
than or equal to 80%. (Not applied to all peer groups)
5. Style: The investment's current style box should match the peer group. (Not applied to
all peer groups)
6. Prospectus Net Exp Ratio: The investment must place in the top 75% of its peer group.
7. Alpha: The investment must place in the top 50% of its peer group.
8. Sharpe: The investment must place in the top 50% of its peer group.
9. 1 Year Return: The investment must place in the top 50% of its peer group.
10. 3 Year Return: The investment must place in the top 50% of its peer group.
11. 5 Year Return: The investment must place in the top 50% of its peer group.
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Each individual client IPS defines when a client portfolio is rebalanced. Usually, an investment
that moves beyond 5% of its strategic allocation will trigger rebalancing. An investment that
falls below the top 25% of its peer group and no longer meets a minimum of due diligence
criteria is put on a watch list.
Investments falling below 75% of their peer group are recommended for sale unless the tax
consequences suggest a holding period.
Investment Strategies
Our investment strategies and advice may vary depending upon each client's specific financial
situation. As such, we determine investments and allocations based upon your predefined
objectives, risk tolerance, time horizon, financial information, liquidity needs, and other various
suitability factors. Your restrictions and guidelines may affect the composition of your portfolio.
It is important that you notify us immediately with respect to any material changes to your
financial circumstances, including for example, a change in your current or expected income
level, tax circumstances, or employment status.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends, and other distributions), and the loss of
future earnings. Although we manage assets in a manner consistent with your investment
objectives and risk tolerance, there can be no guarantee that our efforts will be successful.
You should be prepared to bear the following risks of loss:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
•
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic, and social conditions may trigger market events.
Inflation Risk: When any type of inflation is present, a dollar next year will not buy as
much as a dollar today, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also referred
to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily
relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
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and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company, which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties (i.e.,
Non-traded REITs and other alternative investments) are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or a declining market value.
• Cybersecurity Risk: A breach in cyber security refers to both intentional and
unintentional events that may cause an account to lose proprietary information, suffer
data corruption, or lose operational capacity. This in turn could cause an account to
incur regulatory penalties, reputational damage, and additional compliance costs
associated with corrective measures, and/or financial loss.
• Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase
morbidity and mortality over a wide geographic area, crossing international boundaries,
and causing significant economic, social, and political disruption.
• Custodial Risk: This risk is the probability that a party to a transaction will be unable or
unwilling to fulfill its contractual obligations either due to technological errors, control
failures, malfeasance, or potential regulatory liabilities.
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Item 9: Disciplinary Information
We are required to disclose all pertinent facts regarding any legal, regulatory, or disciplinary
events that would be material to your evaluation of the Firm or the integrity of our
management.
There have never been any legal, regulatory, or disciplinary actions against the Firm or our
management persons.
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Item 10: Other Financial Industry Activities and Affiliations
We are required to disclose to our clients any relationship or arrangement with certain related
persons that is material to our advisory business.
Financial Industry Activities
We are not registered as a broker-dealer. We are not registered and do not have an application
pending as a securities broker-dealer, futures commission merchant, commodity pool operator
or commodity trading advisor.
Several of our management persons are registered representatives of an unaffiliated broker-
dealer, Commonwealth Financial Network® (“Commonwealth”), member FINRA/SIPC. As such,
these individuals will be able to effect securities transactions and may receive separate, yet
customary, compensation for effecting securities transactions. In addition, these individuals are
registered as investment advisor representatives of Commonwealth.
We do not have arrangements that are material to our business and clients and investors with a
related person who is a broker-dealer, investment company, other investment adviser, financial
planning firm, commodity pool operator, commodity trading adviser, futures commission
merchant, bank or thrift institution, accounting firm, law firm, insurance company or agency,
pension consultant, real estate broker or dealer, or an entity that creates or packages limited
liability companies.
Insurance Company or Agency
Certain of our Investment Adviser Representatives may be licensed insurance agents or brokers
and may be appointed with several insurance companies. They may earn separate
compensation for transactions implemented through various insurance companies. Clients are
not obligated to use any company for insurance product purchases and may work with any
insurance agent they choose. Insurance compensation will be separate and distinct from our
investment advisory fees.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics
Our employees must comply with a Code of Ethics and Statement for Insider Trading (the
“Code”). The Code describes our high standard of business conduct, and fiduciary duty to our
clients. The Code’s key provisions include:
• Statement of General Principles
• Policy on and reporting of Personal Securities Transactions
• A prohibition on Insider Trading
• Restrictions on the acceptance of significant gifts
• Procedures to detect and deter misconduct and violations
• Requirement to maintain confidentiality of client information
Our employees must acknowledge the terms of the Code at least annually, and any employee
not in compliance with the Code may be subject to termination. We will provide a copy of our
Code upon request.
Participation or Interest in Client Transactions – Personal Securities Transactions
Both the Firm and our employees may buy or sell securities identical to those recommended to
clients for their personal accounts. The Code, described above, is designed to assure that the
personal securities transactions, activities, and interests of the employees of the Firm will not
interfere with (i) making decisions in the best interest of clients and (ii) implementing such
decisions while, at the same time, allowing employees to invest for their own accounts. Under
the Code certain classes of securities, primarily mutual funds, have been designated as exempt
transactions, based upon a determination that these would materially not interfere with the
best interest of our clients. In addition, the Code requires pre-clearance of many transactions.
Nonetheless, because the Code in some circumstances would permit employees to invest in the
same securities as clients, there is a possibility that employees might benefit from market
activity by a client in a security held by an employee. The Firm may maintain a list of restricted
securities that employees may not purchase or sell based upon having (or possibly having)
access to inside information. Employee trading is continually monitored under the Code and
designed to reasonably prevent conflicts of interest between the Firm and our clients.
Participation or Interest in Client Transactions and Principal/Agency Cross Trades
We do not recommend any securities to our clients in which we have a material financial
interest. We do not affect any principal or agency cross securities transactions for client
accounts. We also do not cross trades between client accounts.
Participation or Interest in Client Transactions – Aggregation
We and our employees may trade in the same securities with client accounts on an aggregated
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basis when consistent with our obligation of best execution. In such circumstances, the
affiliated and client accounts will share commission costs equally and receive securities at a
total average price. We will retain records of the trade order (specifying each participating
account) and its allocation, which will be completed prior to the entry of the aggregated order.
Completed orders will be allocated as specified in the initial trade order. Partially filled orders
will be allocated on a pro rata basis. Any exceptions will be explained on the order.
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Item 12: Brokerage Practices
Research and Other Soft Dollar Benefits
We have no written or verbal arrangements whereby we receive soft dollars.
Brokerage for Client Referrals
We do not receive client referrals from broker/dealers.
Client Directed Brokerage
We do not allow directed brokerage accounts.
Directed Brokerage (Commonwealth)
Registered Representatives of Commonwealth are subject to FINRA Conduct Rule 3280 that
restricts them from conducting securities transactions away from Commonwealth. Therefore,
clients are advised that IARs are limited to conducting securities transactions through
Commonwealth. Commonwealth may charge a higher or lower fee than another broker charges
for a particular type of service, such as transaction fees. Clients may utilize the broker-dealer of
their choice and have no obligation to purchase or sell securities through Commonwealth.
However, if the client does not use Commonwealth, the IAR will reserve the right not to accept
the account. As a registered FINRA broker-dealer, Commonwealth routes order flow through
National Financial Services LLC (NFS), an unaffiliated broker dealer. NFS is obligated to seek best
execution pursuant to FINRA Rule 5310 for all trades executed, however better executions may
be available via another broker-dealer based on a number of factors including volume, order
flow and market making activity. While it is possible that clients may pay higher commission or
transaction fees through Commonwealth, we have determined that Commonwealth currently
provides a combination of customer service, brokerage capabilities, research resources, and
technology that aligns with the needs of our Firm and our clients. Based on these factors, we
select Commonwealth when compared to many non-service-oriented, deep-discount, and
internet-based brokers that are available to the public.
For our client accounts maintained there, Commonwealth are compensated through
commissions or other transaction-related fees for securities trades that are executed through
the Broker Dealer or that settle into Commonwealth accounts. The brokerage commissions
and/or transaction fees charged by Commonwealth are exclusive of and in addition to our fees.
Directed Brokerage – Other Economic Benefits
We may receive from Commonwealth, at no cost to us, professional services, computer
software, and related systems support, enabling us to better monitor client accounts
maintained at Commonwealth. We may receive this support without cost because of the
portfolio management services rendered to clients that maintain assets at Commonwealth. The
support provided may benefit us, but not our clients directly. In fulfilling our duties to our
clients, we endeavor at all times to put the interests of our clients first. Clients should be aware,
however, that our receipt of economic benefits from a broker-dealer may create a conflict of
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interest since these benefits may influence our choice of broker-dealer over another broker-
dealer that does not furnish similar services, software, and systems support.
The commissions paid by our clients shall comply with our duty to obtain “best execution.”
However, a client may pay a commission that is higher than another qualified broker-dealer
might charge to effect the same transaction where we determine, in good faith, that the
commission is reasonable in relation to the value of the brokerage and research services
received. In seeking best execution, the determinative factor is not the lowest possible cost, but
whether the transaction represents the best qualitative execution, taking into consideration the
full range of a broker-dealer’s services, including among others, the value of research provided,
execution capability, commission rates, and responsiveness. Consistent with the foregoing,
while we will seek competitive rates, we may not necessarily obtain the lowest possible
commission rates for client transactions.
Commonwealth also makes available to us other products and services that benefit us but may
not directly benefit our clients’ accounts. Many of these products and services may be used to
service all or some substantial number of our accounts, including accounts not maintained at
Commonwealth.
Commonwealth products and services that assist us in managing and administering clients’
accounts include software and other technology that (i) provide access to client account data
(such as trade confirmations and account statements); (ii) facilitate trade execution and
allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and
other market data; (iv) facilitate payment of our fees from our clients’ accounts; and (v) assist
with back-office functions, recordkeeping and client reporting.
Trade Aggregation
We may aggregate (or “block”) trades for multiple client accounts when buying or selling the
same security. This allows us to trade in larger volumes, which can simplify execution and
potentially reduce transaction costs.
When trades are aggregated, all participating accounts receive the same average price. If the
order is only partially filled, we allocate shares fairly and in good faith, considering factors like
available cash, asset allocation, risk profile, and security type. Small orders may be filled in full
before applying a pro rata allocation. Each client pays a proportionate share of any
commissions or fees. Our goal is to ensure fair and equitable treatment for all clients, with no
favoritism.
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Item 13: Review of Accounts
Reviews
We monitor client portfolios as part of an ongoing process, and regular account reviews are
generally conducted on a quarterly basis. Reviews could also occur at the time of new deposits,
material changes in the client’s financial information, changes in economic cycles, at our
discretion or as often as the client directs. Reviews entail analyzing securities, sensitivity to
overall markets, economic changes, investment results, asset allocation, etc., to ensure the
investment strategy and expectations are structured to continue to meet the client’s objectives.
These reviews are conducted by one of our Investment Advisor Representatives.
Clients are encouraged to discuss their needs, goals, and objectives with us and to inform us of
any changes.
Reporting
At least quarterly, the custodian provides clients with an account statement for each client
account, which may include individual holdings, cost basis information, deposits and
withdrawals, accrued income, dividends, and performance. We may also provide clients with
periodic reports regarding their holdings, allocations, and performance.
Financial Planning – Reviews and Reporting
The initial financial plan is included as a component of the financial planning service. Clients
may receive updated financial plans for a separate fee.
22
Item 14: Client Referrals and Other Compensation
Other Compensation – Brokerage Arrangements
See disclosure in Item 12 regarding compensation, including economic benefits received in
connection with giving advice to clients.
Compensation – Client Referrals
We have been fortunate to receive many client referrals over the years. The referrals came
from current clients, estate planning attorneys, accountants, employees, personal friends of
employees and other similar sources. We do not compensate referring parties for these
referrals.
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Item 15: Custody
Custody – Fee Debiting
Clients may authorize us (in the client agreement) to debit fees directly from their account at
the broker dealer, bank, or other qualified custodian (“custodian”). The custodian is advised in
writing of the limitation of our access to the account. The custodian sends a statement to the
client, at least quarterly, indicating all amounts disbursed from the account including the
amount of advisory fees paid directly to the Firm.
Custody – Account Statements
Clients receive at least quarterly statements from the custodian that holds and maintains
client’s investment assets. Clients are urged to carefully review such statements and compare
such official custodial records to the reports that we provide. Our reports may vary from
custodial statements based on accounting procedures, reporting dates, or valuation
methodologies of certain securities.
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Item 16: Investment Discretion
We may accept limited power of attorney to act on a discretionary basis on behalf of clients. A
limited power of attorney allows us to execute trades on behalf of clients. When such limited
powers exist between the Firm and the client, we have the authority to determine, without
obtaining specific client consent, both the amount and type of securities to be bought to satisfy
client account objectives.
If we have not been given discretionary authority, we consult with the client prior to each
trade.
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Item 17: Voting Client Securities
Proxy Voting
We do not have any authority to and do not vote proxies on behalf of clients, nor do we make
any express or implied recommendation with respect to voting proxies. Clients retain the sole
responsibility for receiving and voting proxies that they receive directly from either their
custodian or transfer agents. Clients may contact us for information about proxy voting.
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Item 18: Financial Information
We have no financial commitments that impair our ability to meet contractual and fiduciary
commitments to clients and we have not been the subject of a bankruptcy proceeding.
We do not require prepayment of fees of both more than $1,200 per client, and more than six
months in advance; and therefore, we are not required to provide a balance sheet to clients.
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Form ADV Part 2B – Investment Advisor Brochure Supplement
Ashwood Advisors, LLC
Form ADV Part 2B
Investment Advisor Brochure Supplement
5 North Meadows Road
Medfield MA, 02052
Phone: (508) 359-9442
Fax: (508) 359-2494
www.geremiainvestments.com
Stephen A. Geremia, AIF®
April 2026
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact Stephen A. Geremia, Managing Member and Chief Compliance Officer, at (508) 359-
9442 or sgeremia@geremiainvestments.com if you did not receive our Brochure or if you have
any questions about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
28
Item 2: Educational Background and Business Experience
We require that employees that provide investment advice have a bachelor's degree and
further coursework demonstrating knowledge of financial planning and tax planning. Examples
of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA.
Additionally, advisors must have work experience that demonstrates their aptitude for financial
planning and investment management.
1962
Stephen A. Geremia
CRD #: 1459834
1999 to Present
Business Background:
Ashwood Advisors, LLC
Managing Member, Chief Compliance Officer
and Investment Advisor Representative
Commonwealth Financial Network
Investment Advisor Representative
Registered Representative
2007 to Present
1997 to Present
Formal Educational after High School:
New England College
Bachelor of Arts in English and Philosophy
Professional Designations:
Accredited Investment Fiduciary (AIF®)
Professional Certifications
Stephen A. Geremia maintains a professional designation, which requires the following
minimum requirements:
Accredited Investment Fiduciary® (AIF®)
Center for Fiduciary Studies (fi360 / Fiduciary 360)
Issued By
Prerequisites
• Candidate must meet a point-based threshold based on a
combination of education, relevant industry experience,
and/or professional development
Candidate must complete one of the following:
Education
Requirements
• Web-based program
• Capstone Program
Final Certification exam, proctored closed book
6 hours per year
Exam Type
Continuing Education
Requirements
29
Item 3: Disciplinary Information
Stephen A. Geremia has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Stephen A. Geremia is a Registered Representative and Investment Advisor Representative with
Commonwealth Financial Network. In such capacities, he may offer securities and receive
normal and customary commissions as a result of securities transactions. This presents a
conflict of interest to the extent that he recommends that a client invest in a security which
results in a commission being paid to him. As an independent contractor of Commonwealth,
Stephen spends less than 10% of his time offering securities products on a commission or fee
basis.
Stephen A. Geremia is a licensed insurance agent through numerous insurance companies. In
such a capacity, he may offer insurance products and receive normal and customary
commissions as a result of such a purchase. This presents a conflict of interest to the extent
that he recommends the purchase of an insurance product which results in a commission being
paid to him as an insurance agent. The insurance business comprises less than 5% of his time.
Item 5: Additional Compensation
As disclosed above, Stephen A. Geremia is Registered Representative and Investment Advisor
Representative with Commonwealth Financial Network and therefore receives the associated
compensation for services provided under that entity. Stephen A. Geremia is also an
independent contractor associated with Commonwealth, and as such has a revenue sharing
agreement in place with Commonwealth. This revenue sharing agreement compensates
Commonwealth for the services they provide to him such as mutual fund due diligence, and
client account custodianship through Commonwealth’s relationship with National Financial
Services.
Item 6: Supervision
Stephen A. Geremia, Managing Member and Chief Compliance Officer, supervises the persons
named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Stephen A. Geremia
supervises these persons by holding regular staff, investment, and other ad hoc meetings. In
addition, Stephen A. Geremia regularly reviews client reports, emails, and trading, as well as
employees’ personal securities transaction and holdings reports. Stephen A. Geremia,
Managing Member and Chief Compliance Officer, may be reached at (508) 359-9442 or
sgeremia@geremiainvestments.com.
30
Form ADV Part 2B – Investment Advisor Brochure Supplement
Ashwood Advisors, LLC
Form ADV Part 2B
Investment Advisor Brochure Supplement
5 North Meadows Road
Medfield MA, 02052
Phone: (508) 359-9442
Fax: (508) 359-2494
www.geremiainvestments.com
Matthew A. Geremia, CFP®
April 2026
This Brochure Supplement provides information about the Firm’s (“we,” “us,” “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact Stephen Geremia, Managing Member and Chief Compliance Officer, at (508) 359-9442
or sgeremia@geremiainvestments.com if you did not receive our Brochure or if you have any
questions about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
31
Item 2: Educational Background and Business Experience
We require that employees that provide investment advice have a bachelor's degree and
further coursework demonstrating knowledge of financial planning and tax planning. Examples
of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA.
Additionally, advisors must have work experience that demonstrates their aptitude for financial
planning and investment management.
1991
Matthew A. Geremia
CRD #: 6355547
Business Background:
Ashwood Advisors, LLC
Financial Advisor and Investment Advisor Representative
Wealth Management Associate
2023 to Present
2017 to 2023
2018 to Present
Commonwealth Financial Network
Registered Representative and Investment Advisor Representative
Formal Educational after High School:
St. Lawrence University
Bachelor of Arts in Government
Professional Designations:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Professional Certifications
Matthew Geremia maintains a professional designation, which requires the following minimum
requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college
Prerequisites
or university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program,
or hold one of the following:
Education
Requirements
• CPA
• ChFC®
• Chartered Life Underwriter® (CLU®)
• CFA®
• Ph.D. in business or economics
32
• Doctor of Business Administration
• Attorney's License
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Matthew A. Geremia has not been involved in any activities resulting in a disciplinary
disclosure.
Item 4: Other Business Activities
Matthew A. Geremia is a Registered Representative and Investment Advisor Representative
with Commonwealth Financial Network. In such capacities, he may offer securities and receive
normal and customary commissions as a result of securities transactions. This presents a
conflict of interest to the extent that he recommends that a client invest in a security which
results in a commission being paid to him. As an independent contractor of Commonwealth,
Matthew spends less than 10% of his time offering securities products on a commission or fee
basis.
Matthew A. Geremia is a licensed insurance agent through numerous insurance companies. In
such a capacity, he may offer insurance products and receive normal and customary
commissions as a result of such a purchase. This presents a conflict of interest to the extent
that he recommends the purchase of an insurance product which results in a commission being
paid to him as an insurance agent. The insurance business comprises less than 5% of his time.
Item 5: Additional Compensation
As disclosed above, Matthew A. Geremia is Registered Representative and Investment Advisor
Representative with Commonwealth Financial Network and therefore receives the associated
compensation for services provided under that entity. Matthew A. Geremia is also an
independent contractor associated with Commonwealth, and as such has a revenue sharing
agreement in place with Commonwealth. This revenue sharing agreement compensates
Commonwealth for the services they provide to him such as mutual fund due diligence, and
client account custodianship through Commonwealth’s relationship with National Financial
Services.
Item 6: Supervision
Stephen A. Geremia, Managing Member and Chief Compliance Officer, supervises the persons
33
named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Stephen A. Geremia
supervises these persons by holding regular staff, investment, and other ad hoc meetings. In
addition, Stephen A. Geremia regularly reviews client reports, emails, and trading, as well as
employees’ personal securities transaction and holdings reports. Stephen A. Geremia,
Managing Member and Chief Compliance Officer may be reached at (508) 359-9442 or
sgeremia@geremiainvestments.com.
34