Overview

Assets Under Management: $127 million
Headquarters: MEDFIELD, MA
High-Net-Worth Clients: 20
Average Client Assets: $4.8 million

Frequently Asked Questions

ASHWOOD ADVISORS is a fee-based investment advisor. Detailed fee schedules are available in their SEC Form ADV filing.

Yes. As an SEC-registered investment advisor (CRD #128811), ASHWOOD ADVISORS is subject to fiduciary duty under federal law.

ASHWOOD ADVISORS is headquartered in MEDFIELD, MA.

ASHWOOD ADVISORS serves 20 high-net-worth clients according to their SEC filing dated April 28, 2026. View client details ↓

According to their SEC Form ADV, ASHWOOD ADVISORS offers financial planning and portfolio management for individuals. View all service details ↓

ASHWOOD ADVISORS manages $127 million in client assets according to their SEC filing dated April 28, 2026.

According to their SEC Form ADV, ASHWOOD ADVISORS serves high-net-worth individuals. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Clients

Number of High-Net-Worth Clients: 20
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 75.08%
Average Client Assets: $4.8 million
Total Client Accounts: 195
Discretionary Accounts: 180
Non-Discretionary Accounts: 15

Regulatory Filings

CRD Number: 128811
Filing ID: 2099765
Last Filing Date: 2026-04-28 11:20:26

Form ADV Documents

Primary Brochure: 04 28 2026 ASH FORM ADV 2A AND 2B FINAL (2026-04-28)

View Document Text
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). 1 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. 2 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 3 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 4 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: 5 • 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. 6 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 7 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. 8 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 9 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. 10 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. 11 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. 12 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. 13 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 14 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. 15 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. 16 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. 17 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 18 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. 19 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 20 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. 21 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. 23 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. 24 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. 25 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. 26 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. 27 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