CHARLES RIVER WEALTH MANAGEMENT, LLC

Charles River Wealth Management, LLC Form ADV Part 2A – Disclosure Brochure Effective: February 3, 2026 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Charles River Wealth Management, LLC (“Charles River” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (781) 270-5400. Charles River is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Charles River to assist you in determining whether to retain the Advisor. Additional information about Charles River and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s name or CRD# 288017. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/  Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of Charles River. For convenience, the Advisor has combined these documents into a single disclosure document. Charles River believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. Charles River encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor. Material Changes There have been no material changes to this Disclosure Brochure since the last annual amendment filing on February 6th.2025 Future Changes From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s name or CRD# 288017. You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (781) 270-5400. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 2  Item 3 – Table of Contents Item 1 – Cover Page 1 Item 2 – Material Changes ____________________________________________________________ 2 Item 3 – Table of Contents ____________________________________________________________ 3 Item 4 – Advisory Services ____________________________________________________________ 4 Item 5 – Fees and Compensation _______________________________________________________ 6 Item 6 – Performance-Based Fees and Side-By-Side Management ____________________________ 8 Item 7 – Types of Clients ______________________________________________________________ 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss _________________________ 8 Item 9 – Disciplinary Information ______________________________________________________ 10 Item 10 – Other Financial Industry Activities and Affiliations _______________________________ 10 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ____ 10 Item 12 – Brokerage Practices ________________________________________________________ 11 Item 13 – Review of Accounts ________________________________________________________ 12 Item 14 – Client Referrals and Other Compensation _______________________________________ 13 Item 15 – Custody __________________________________________________________________ 13 Item 16 – Investment Discretion ______________________________________________________ 13 Item 17 – Voting Client Securities _____________________________________________________ 14 Item 18 – Financial Information _______________________________________________________ 14 Form ADV Part 2B – Brochure Supplement ______________________________________________ 15 Privacy Policy _____________________________________________________________________ 18 Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 3  Item 4 – Advisory Services A. Firm Information Charles River Wealth Management, LLC (“Charles River” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor. The Advisor is organized as a limited liability company (“LLC”) under the laws of the Commonwealth of Massachusetts. Charles River was founded in March 2017 and is owned and operated by Kenan Nacar (Managing Partner and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Charles River. B. Advisory Services Offered Charles River offers investment advisory services to individuals, high net worth individuals, trust, estates, and charitable organizations (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Charles River’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Investment Management Services Charles River provides customized investment management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary or non-discretionary investment management and consultation. Charles River works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Charles River will then construct a portfolio, consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize bonds, individual stocks, or other investment products as necessary for portfolio construction. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client. ETFs are recommended to Clients only after the Advisor has determined that the ETF is commensurate with the Client’s risk tolerance and investment objectives, as communicated to Charles River. At no time will Charles River utilize double or triple leveraged ETFs in its portfolio construction. The Advisor will review holdings of the ETFs for each Client on an at least annual basis. ETF holdings are also available to the Client through statements from the Custodian. Charles River’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Charles River evaluates and selects ETFs and mutual funds for inclusion in portfolio strategies only after evaluating the management fee(s), overall expense ratios, fund performance, manager tenure, and several other factors of each investment prior to making a recommendation. Charles River may recommend, on occasion, redistributing investment allocations to diversify the portfolio strategy in an effort to reduce risk and increase performance. Charles River may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Charles River may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 4  overweighting of the position(s) in the portfolio, change in risk tolerance of the strategy, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Charles River accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their account[s] at the Custodian, pursuant to the terms of the Client investment advisory agreement. For additional information, please see Item 12 – Brokerage Practices. Retirement Accounts – When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA sponsored plan or to roll over the assets to an Individual Retirement Accounts (“IRAs”), or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). In such instances, the Advisor will serve as an investment fiduciary as that term is defined under The Employee Retirement Income Security Act of 1974 (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws governing retirement accounts. Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services Charles River will typically provide financial planning and consulting services to Clients, pursuant to a written financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, insurance needs, and education savings. A financial plan developed for or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Charles River may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation but is not compensated for making such recommendation. Plans or consultations are completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement the transaction made by the Advisor. C. Client Account Management Prior to engaging Charles River to provide investment advisory services, each Client is required to enter into one of more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – Charles River, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 5  ● Asset Allocation – Charles River will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – Charles River will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – Charles River will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Charles River does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Charles River. E. Assets Under Management As of December 31, 2025, Charles River manages approximately $110,312,780in Client assets, with $109,415,000 managed on a discretionary basis and $897,780on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are be paid quarterly in arrears, pursuant to the terms of the Client’s investment advisory agreement. Investment advisory fees are based on the market value of assets under management at the end of the quarter. The investment advisory fee in the first quarter of service is prorated to the inception date of the account[s] to the first quarter end. Fees are based on a tiered schedule as outlined below. Annual Rate (%) Assets Under Management ($) First $500,000 Next $500,001 to $1,000,000 Next $1,000,001 to $2,000,000 Next $2,000,001 to $3,000,000 Next $3,000,001 to $5,000,000 Over $5,000,001 1.10% 0.95% 0.85% 0.75% 0.65% 0.50% Fees may be negotiable at the sole discretion of the Advisor and are determined based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The Advisor’s fees will also take into consideration the Client’s aggregate assets under management with the Advisor, unless specifically excluded. All securities held in accounts managed by Charles River will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 6  Financial Planning Services Charles River offers financial planning services at an hourly rate ranging from $200 to $350. Fees may be negotiable based on the on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate of total hours and overall costs will be provided to the Client prior to engaging the Advisor for these services. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor and deducted from the Client’s account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the end of each quarter. The amount due is calculated by applying the annual rate divided by 4 to the total assets under management with Charles River. Clients will be provided with a quarterly statement from the Custodian reflecting deduction of the investment advisory fees. Clients are urged to review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by Charles River directly from their accounts held by the Custodian as part of the investment advisory agreement and separate forms provided by the Custodian. Financial Planning Services Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s]. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than Charles River, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and custody fees charged by the Custodian, if applicable. The Advisor's recommended custodian does not charge securities transaction fees for ETF and equity trades in Client accounts, but typically charges for mutual funds and other types of investments. The fees charged by Charles River are separate and distinct from these custody and execution fees. In addition, all fees paid to Charles River for investment management services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of Charles River, but would not receive the services provided by Charles River which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Charles River to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Charles River is compensated for its services at the end of the quarter after investment management services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice, at any time, to the other party. The Client may also terminate the investment advisory agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The Client’s investment advisory agreement with the Advisor is non- transferable without the Client’s prior written consent. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 7  Financial Planning Services Charles River is compensated for its services upon completion of the engagement deliverable[s]. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior written consent. E. Compensation for Sales of Securities Charles River does not buy or sell securities and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management Charles River does not charge performance-based fees for its investment management services. The fees charged by Charles River are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any Client. Charles River does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Charles River offers investment advisory services to individuals, high net worth individuals, trust, estates, and charitable organizations. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These amounts may change over time and are updated at least annually by the Advisor. Charles River generally does not impose a minimum size for establishing a relationship. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Charles River primarily employs fundamental analysis methods in developing investment strategies for its Clients. Research and analysis from Charles River are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria are generally ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. As noted above, Charles River generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Charles River will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 8  times, Charles River may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Charles River will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general risks of investing. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment approach: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. There is also a risk that Authorized Participants are unable to fulfill their responsibilities. Authorized Participants are one of the major parties involved with ETF creation/redemption mechanism in the markets. The Authorized Participants play a critical role in the liquidity of ETFs and essentially have the exclusive right to change the supply of ETF shares in the market. If the Authorized Participants does not fulfill this expected role, there could be an adverse impact on liquidity and the valuation of an ETF. Bond Risks Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 9  the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory or disciplinary events involving Charles River or Mr. Nacar. Charles River values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s name or CRD# 288017. Item 10 – Other Financial Industry Activities and Affiliations Insurance Agency Affiliations As noted in Item 5 above, Mr. Nacar is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Nacar’s role with Charles River. As an insurance professional, Mr. Nacar will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Nacar is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Mr. Nacar or the Advisor. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Charles River has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with Charles River (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. Charles River and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Charles River’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. The Code is available to our Clients upon request. To request a copy of the Code, please contact the Advisor at (781) 270-5400. B. Personal Trading with Material Interest Charles River allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Charles River does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Charles River does not have a material interest in any securities traded in Client accounts. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 10  C. Personal Trading in Same Securities as Clients Charles River allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by conducting a coordinated review of personal accounts and the accounts of the Clients. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Charles River allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterward. At no time will Charles River, or any Supervised Person of Charles River, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Charles River does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize Charles River to direct trades to this Custodian as agreed upon in the investment advisory agreement. Further, Charles River does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where Charles River does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to Clients for custody and execution services Clients are not obligated to use the recommended Custodian and will not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by Charles River, However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. Charles River may recommend the Custodian based on criteria such as, but not limited to, the reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Charles River will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc. (“Raymond James”). Raymond James is a FINRA-registered broker-dealer and New York Stock Exchange/SIPC member. Raymond James will serve as the Client’s “qualified custodian”. Charles River maintains institutional relationships with Raymond James, whereby the Advisor receives economic benefits from the Custodian. Please see Item 14 below. Following are additional details regarding the brokerage practices of the Advisor: Charles River has established an institutional relationship with Raymond James to assist the Advisor in managing Client account[s]. Access to the Raymond James platform is provided at no charge to the Advisor. The Raymond James platform includes brokerage, custody, administrative support, record keeping, technology and related services designed to support registered investment advisors like Charles River in serving Clients. These services are intended to serve the best interests of the Advisor’s Clients. Raymond James may charge securities transaction fees for effecting certain securities transactions. Raymond James enables the Advisor to obtain certain no-load mutual funds without securities transaction fees and other no- load funds at nominal transaction charges. Raymond James’s transaction fee rates are generally considered discounted from customary retail brokerage rates. However, the transaction fees charged by Raymond James may Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 11  be higher or lower than those charged by other custodians and broker-dealers. Please see Item 14 below for additional information. Following are additional details regarding the brokerage practices of the Advisor: 1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. Charles River does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. However, the Advisor does receive certain economic benefits from the Custodian. Please see Item 14 below. 2. Brokerage Referrals – Charles River does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis”, where Charles River will place trades within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account[s] at the Custodian. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Charles River will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The Advisor may aggregate trades for Client accounts. The aggregation of trades allows the Advisor to place orders for the purchase and sale of securities for Client accounts in order to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Charles River will execute its transactions through the Custodian as directed by the Client. Charles River may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. The fees associated with trading are the same regardless of whether trades are aggregated. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Mr. Nacar, Chief Compliance Officer of Charles River. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Charles River if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 12  also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Charles River Charles River is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. Charles River does not receive commissions or other compensation from product sponsors, broker- dealers or any unrelated third party. The Advisor may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, Charles River may receive non-compensated referrals of new Clients from various third-parties. Participation in Institutional Advisor Platform As noted in item 12, Charles River has established an institutional relationship with Raymond James to assist the Advisor in managing Client account[s]. As part of the arrangement, Raymond James also makes available to the Advisor, at no additional charge to the Advisor, certain research and brokerage services, including research services obtained by Raymond James directly from independent research companies. The Advisor may also receive additional services and support from Raymond James. As a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or expand the use of Raymond James's services. The Advisor examined this potential conflict of interest when it chose to enter into the relationship with Raymond James and has determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12 above. The Advisor receives access to software and related support without cost because the Advisor renders wealth management services to Clients that maintain assets at Raymond James The software and related systems support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's recommendation of this Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor has the following benefits from Raymond James: financing services, receipt of duplicate Client confirmations and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to Client accounts; and access to an electronic communication network for Client order entry and account information. B. Client Referrals from Solicitors Charles River does not engage paid solicitors for Client referrals. Item 15 – Custody The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review statements provided by the Custodian, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. Item 16 – Investment Discretion Charles River generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Charles River. The Client grants discretionary authority to the Advisor through the execution of an investment advisory agreement with the Advisor. All discretionary trades made by Charles River will be in Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 13  accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Charles River does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Charles River, nor Mr. Nacar have any adverse financial situations that would reasonably impair the ability of Charles River to meet its obligations to its Clients. Neither Charles River, nor Mr. Nacar have been subject to a bankruptcy or financial compromise. Charles River is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 14  Form ADV Part 2B – Brochure Supplement for Kenan Nacar Managing Partner and Chief Compliance Officer Effective: February 3, 2026 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Kenan Nacar (CRD# 4209369) in addition to the information contained in the Charles River Wealth Management, LLC (“Charles River” or the “Advisor”, CRD# 288017) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Charles River Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (781) 270-5400. Additional information about Mr. Nacar is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4209369. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 15  Item 2 – Educational Background and Business Experience Kenan Nacar, born in 1964, is dedicated to advising Clients of Charles River as the Managing Partner and Chief Compliance Officer. Mr. Nacar also earned a Bachelor of Arts from Cornell University in 1986. Additional information regarding Mr. Nacar’s employment history is included below. Employment History: Managing Partner and Chief Compliance Officer, Charles River Wealth Management, LLC Managing Partner, Chief Compliance Officer, Sagamore Wealth Management, LLC Independent Senior Financial Advisor, Ameriprise Financial Services, Inc. 04/2017 to Present 06/2011 to 03/2017 11/2004 to 06/2011 Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Nacar. Mr. Nacar has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Nacar. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Nacar. However, we do encourage you to independently view the background of Mr. Nacar on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 4209369. Item 4 – Other Business Activities Insurance Agency Affiliations Mr. Nacar is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Mr. Nacar’s role with Charles River. As an insurance professional, Mr. Nacar will receive customary commissions and other related revenues from the various insurance companies whose products are sold. Mr. Nacar is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest since the Advisor recommends certain products of the insurance companies to its Clients. This conflict of interest is mitigated because Clients are under no obligation to implement any recommendations made by Mr. Nacar or the Advisor. Rotary Club of Winchester Mr. Nacar serves on the Board of Directors at the Rotary Club of Winchester, a non-profit organization consisting of business and professional persons united to provide humanitarian services. Mr. Nacar is not compensated for these services. He spends less than 10% of his time at this activity. Item 5 – Additional Compensation Mr. Nacar has additional business activities where compensation is received that are detailed in Item 4 above. Item 6 – Supervision Mr. Nacar serves as the Managing Partner and Chief Compliance Officer of Charles River. Mr. Nacar can be reached at (781) 270-5400. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 16  Charles River has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of Charles River. Further, Charles River is subject to regulatory oversight by various agencies. These agencies require registration by Charles River and its Supervised Persons. As a registered entity, Charles River is subject to examinations by regulators, which may be announced or unannounced. Charles River is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 17  Privacy Policy Effective: February 3, 2026 Our Commitment to You Charles River Wealth Management, LLC (“Charles River” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Charles River (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Charles River does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Driver’s license number Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number[s] Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 18  receive from us. How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No Servicing our Clients We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared Marketing Purposes Charles River does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Charles River or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent[s] or representative[s]. No Not Shared Information About Former Clients Charles River does not disclose and does not intend to disclose, non- public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations Massachusetts In response to Massachusetts law, the Client must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. Client opt-in is obtained through the Client’s execution of authorization forms provided by the third parties, by executing an Information Sharing Authorization Form, or by other written consent by the Client, as appropriate and consistent with applicable laws and regulations. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy, and will provide you with a revised policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (781) 270-5400. Charles River Wealth Management, LLC 50 Mall Road, Suite 209, Burlington, MA 01803 Phone: (781) 270-5400 * Fax: (781) 270-5410 https://kenannacar.myhomehq.biz/ Page 19