View Document Text
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 1
Item 1 - Cover Page (Brochure)
Delphinus Financial Advisors, LLC
56 Pratt Street
Mansfield, MA 02048
Contact Information
Anthony A Salotto, CFP®, EA, LLC Member & Manager
Phone: 781-780-2439
Email: asalotto@delphinusfa.com
Website: http://www.delphinusfa.com
Date: January 26, 2026
This Brochure provides information about the qualifications and business practices of
Delphinus Financial Advisors, LLC. If you have any questions about the contents of this
Brochure, please contact us at the phone or email listed above. 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.
Delphinus Financial Advisors, LLC is a SEC registered investment advisor located in the
Commonwealth of Massachusetts. Registration of an investment advisor does not imply any
level of skill or training. The oral and written communications of an advisor provide you
with information about which you determine to hire or retain an advisor.
Additional information about Delphinus Financial Advisors, LLC is available on the SEC’s
website at www.adviserinfo.sec.gov.
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 2
Item 2 - Material Changes
This Item will provide a summary of any material changes made to this Brochure after the
date of our last annual update, the date of which is referenced below.
We will ensure that you receive a summary of any materials changes to this and subsequent
Brochures within 120 days of the close of our business’ fiscal year. We may further provide
other ongoing disclosure information about material changes as necessary. We will further
provide you with a new Brochure as necessary based on changes or new information, at any
time, without charge.
Currently, our Brochure may be requested by contacting us at the phone or email listed on
the previous page. Brochures are provided free of charge.
Additional information about Delphinus Financial Advisors, LLC is available via the SEC’s
web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any
persons affiliated with Delphinus Financial Advisors, LLC who are registered as Investment
Adviser Representatives.
There have been no material changes since the Firm’s last ADV annual amendment update
of February 18, 2025.
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 3
Item 3 - Table of Contents
Item 1 - Cover Page (Brochure) ..................................................................................... 1
Item 2 - Material Changes ............................................................................................. 2
Item 3 - Table of Contents ............................................................................................. 3
Item 4 – Advisory Business ............................................................................................ 4
Firm Description .............................................................................................................................. 4
Advisory Services ............................................................................................................................. 4
Item 5 – Fees and Compensation .................................................................................. 6
Item 6 – Performance-Based Fees and Side-By-Side Management ............................. 7
Item 7 – Types of Clients ............................................................................................... 7
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................... 7
Methods of Analysis ........................................................................................................................ 7
Investment Strategies....................................................................................................................... 8
Risk of Loss ...................................................................................................................................... 8
Item 9 – Disciplinary Information ................................................................................. 8
Item 10 – Other Financial Industry Activities and Affiliations ..................................... 8
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ........................................................................................................... 9
Code of Ethics .................................................................................................................................. 9
Participation or Interest in Client Transactions and Personal Trading .................................... 9
Item 12 – Brokerage Practices ..................................................................................... 10
Item 13 - Review of Accounts ....................................................................................... 11
Item 14 - Client Referrals and Other Compensation .................................................... 11
Item 15 - Custody ......................................................................................................... 12
Item 16 - Investment Discretion .................................................................................. 12
Item 17 – Voting Client Securities ............................................................................... 12
Item 18 – Financial Information .................................................................................. 12
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 4
Item 4 – Advisory Business
Firm Description
Delphinus Financial Advisors, LLC (“Advisor”) is a fee-only holistic financial planning firm
that specializes in providing holistic financial planning and investment advisory services to
individuals and families. Advisor is owned and operated by Anthony A. Salotto, who
established Delphinus Financial Advisors, LLC in January 2010. In July 2024, Andrew
Blacker obtained a minority ownership interest in the firm. Advisor distinguishes itself from
traditional investment advisory firms by serving as a trusted guide for providing clients a
means to identify their personal financial objectives, find solutions to their financial problem
areas, design and simplify their cash flow, perform tax planning as well as individual tax
preparation, advising on financial risk and investment allocations, retirement planning,
education planning, insurance, estate planning, and managing assets. All is tailored to the
client’s unique objectives.
Advisor does not sell insurance or investment products, nor does it accept commission as a
result of any product recommendations. Advisor does not pay referral or finder’s fees, nor
does it accept such fees from other firms.
Advisor has legacy clients who receive services and pay fees that differ from those below and
are no longer on offer by the firm.
Advisor and client will enter into an agreement that details the scope of the relationship and
responsibilities of both Advisor and client. Advice and services provided under the
agreement are tailored to the stated objectives of the client.
Advisor hereby acknowledges that it is a "fiduciary" when the firm’s services are subject to
the provisions of Employment Retirement Income Security Act (ERISA) of 1974, as
amended. When Advisor provides investment advice regarding a retirement plan account or
individual retirement account, Advisor is a fiduciary within the meaning of Title 1 of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal revenue Code, as
applicable, which are laws governing retirement accounts. Advisor operates under a special
rule that requires Advisor to act in the best interests of the client and not put Advisor’s
interests ahead of client’s interests.
Advisory Services
Advisor provides ongoing financial planning services, ongoing investment management
services, and tax planning and preparation. Incoming clients all engage Advisor to provide
ongoing financial planning services with the option to add ongoing investment management
services. Those clients that engage Advisor to provide ongoing financial planning and
investment management services also have the option to add tax planning and preparation
services. Advisor provides services for a fixed, annual fee based on its understanding of the
complexity of a client’s financial situation and the scope, amount, type, and extent of
services needed by the client. Advisor does not offer investment management or tax
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 5
planning and preparation separately as a standalone service. A description of the specifics of
the abovementioned services follows:
Financial Planning
When clients engage Advisor for ongoing financial planning services, depending on their
needs, Advisor will provide the following:
- An initial review of clients’ financial matters as well as financial counsel and advice
on the matters of their spending, savings and debt levels.
- Assistance in identifying clients’ financial goals and investment objectives and
recommendations as to the investment of their assets in accordance with their
investment objectives, risk tolerance, investment time horizon, and any restrictions.
- Advice as to the conservation of clients’ assets and the production of their income to
help minimize their tax liability.
- A review of clients’ current insurance coverage and available options and
recommendations for changes when needed.
- Assistance to clients or their attorney as relates to their estate planning, including
advice as to the financial implications in the distribution of their estate; and,
- From time to time, at their request, advice on various financial matters impacting
clients or their immediate family.
Investment Management
When clients choose to include investment management services with ongoing financial
planning, Advisor will be responsible for the investment of the cash and securities that
clients designate for management (“Account”) in accordance with clients’ investment
objectives, risk tolerance, investment timeline, and any restrictions that clients impose.
Clients grant Advisor discretionary authority to manage their Account(s) in the agreements
that they sign with Advisor. Discretionary authority allows Advisor the authority to select,
purchase, and sell securities for clients’ Accounts, including the amounts, and to place orders
with custodians to execute transactions in those Accounts without prior consultation with
clients.
In the event that clients have assets held in a retirement plan account sponsored by their
employer or other accounts in which Advisor has no authority (“Held Away Account”),
clients acknowledge that Advisor’s services to a Held Away Account is limited to advising
them as to the investment options and selections for those assets. Advisor does not accept
authority to effect trades in Held Away Accounts, or to make disbursements, withdrawals, or
change beneficiaries in them. The responsibility for executing trades in Held Away
Accounts is the clients, and clients are responsible for notifying Advisor of any changes to
investment options or restrictions in Held Away Accounts.
Tax Planning & Preparation
When clients choose to include tax planning and preparation services with ongoing financial
planning and investment management, Advisor will provide clients advice on their personal
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 6
income tax liability. Depending on the client, advice on personal income tax liability
includes calculations of withholding rates and/or estimated tax payments, tax advice on
unique investment holding strategies (for example, employer stock), specific tax efficiency
strategies, and long-term tax planning strategies. Also, Advisor will compute the amount of
tax or refund due based on the information furnished by the client for all individual federal
and state taxes (this covers the federal 1040 return and associated state return but excludes
any other return types). Finally, Advisor will prepare the forms and schedules necessary to
properly report the client’s income, adjustments, expenditures, deductions, exemptions, and
other information required for individual returns (this covers the federal 1040 return and
associated state return but excludes any other return types).
As of December 31, 2025, the firm managed $157,091,655 in assets on a discretionary basis,
and $0 assets on a non-discretionary basis.
Item 5 – Fees and Compensation
Advisor has legacy clients who pay fees that differ from those noted below and are no longer
on offer by the firm.
Advisory Services
Advisor charges a fixed, annual fee for its services and determines that fee based upon its
understanding of the complexity of a client’s financial situation and the scope, amount, type,
and extent of services needed by the client. Advisor’s fee is billed monthly, in advance.
Clients authorize Advisor to deduct its fee directly from their Account held at an
independent custodian. Clients authorize Advisor to instruct the Account's custodian to
deduct its fee from the Account as it becomes due and payable. If a client has more than one
Account, Advisor determines from which Account to deduct its fee based on the client’s
best interest or at their instruction. Clients consent to Advisor’s billing their Accounts
disproportionately for fees if it becomes necessary due to insufficient funds in a given
Account or if doing so is in the client’s best interest. If Advisor cannot directly deduct its fee
from a client’s Account(s), Advisor will invoice the client for their fee as it becomes due and
payable. When clients make payment directly, Advisor accepts payment by credit card
through a third-party vendor.
Annual fees are initially calculated and are then recalculated at Advisor’s discretion on thirty
(30) days written notice to the client). In no event will the Advisor require prepayment of
more than $1,200.00 in fees for services provided six months or more in advance from any
client.
Add-ons, credits, and miscellaneous adjustments: Additional charges may be assessed at the sole
discretion of Advisor for amended tax returns and for additional tax returns prepared for
dependents of the client, if applicable. Credits and miscellaneous adjustments may also be
applied, as deemed appropriate, at the sole discretion of Advisor.
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 7
General Fees and Compensation Notes
Delphinus Financial Advisors, LLC is a fee-only financial advisory firm and does not sell
investment or insurance products.
Fees are generally not negotiable and are paid directly by the client as described above. The
client may terminate an engagement by providing written notice within five days of signing
the agreement. Additionally, either party may terminate an agreement, without penalty, upon
written notice. Any prepaid but unearned fees will be promptly refunded by Advisor. Any
fees that have been earned but not yet paid by the client will be due and payable. Whether
fees have been earned or unearned will be determined by Advisor in Advisor’s sole
discretion.
In addition to Advisor’s fee, clients may incur certain other fees, charges, and/or taxes due
to implementation of Advisor’s recommendations. Additional charges and fees will be
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. Mutual funds and
exchange traded funds also charge internal management fees, which are disclosed in a fund’s
prospectus. Such charges, fees, and taxes are exclusive of, and in addition to, the Advisor’s
fee.
Item 6 – Performance-Based Fees and Side-By-Side Management
Advisor does not charge any performance-based fees (fees based on a share of capital gains
or capital appreciation of the assets of a client).
Item 7 – Types of Clients
Advisor provides holistic financial planning and investment advisory services primarily to
individuals and families. For those who may not be a fit for Advisor, Advisor may provide
names of other firms for consideration.
Item 8 – Methods of Analysis, Investment Strategies and Risk of
Loss
Methods of Analysis
The main sources of information Advisor may rely upon when researching and analyzing
securities will include traditional research materials such as financial newspapers and
magazines, annual reports, prospectuses, filings with the SEC, as well as research materials
prepared by others, company press releases and corporate rating services. Advisor also
subscribes to various professional publications deemed to be consistent and supportive of
Advisor’s investment philosophy.
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 8
Moreover, Advisor approaches investment portfolio analysis and implementation based on
internal factors such as your tax situation, overall risk tolerance, current financial situation,
and your personal goals and aspirations. After identifying these items, your portfolio will be
structured around your individual needs, while attempting to minimize negative effects of
external factors, such as interest rates, market performance, and the economy as a whole.
Investment Strategies
In general, Advisor recommends no-load mutual funds (i.e., mutual funds that have no sales
fees), U.S. government securities (including individual bonds), money market accounts, and
certificates of deposit. In certain cases, other products may be deemed appropriate for you
and may be recommended, based upon your goals, needs and objectives. And in the course
of providing investment advice, Advisor may address issues related to other types of assets
that you may already own.
Risk of Loss
Any investment in securities involves a risk of loss that clients should be prepared to bear.
While Advisor will use its best judgment and good faith efforts in rendering services to
clients, not every investment decision or recommendation made by Advisor will be
profitable. Advisor cannot warrant or guarantee any level of account performance, or that an
Account will be profitable over time. Client assumes all market risk involved and
understands that investment decisions are subject to various market, currency, economic,
political, and business risks.
Item 9 – Disciplinary Information
Registered Investment Advisers are required to disclose all material facts regarding any legal
or disciplinary events that would be material to your evaluation of Delphinus Financial
Advisors, LLC or the integrity of Delphinus Financial Advisors, LLC’s management.
Delphinus Financial Advisors, LLC has no information to disclose which is applicable to this
Item.
Item 10 – Other Financial Industry Activities and Affiliations
Advisor is a member of the Alliance of Comprehensive Planners (ACP). This non-profit,
member-owned organization provides training and support through an alliance of fee-only
comprehensive financial advisors. As a member of ACP, Advisor has the right to use
proprietary products and systems designed by ACP. ACP offers education in the form of in-
person, web, and telephone conferences (which may provide continuing education credits)
and services produced by collaborative efforts of the fee-only financial advisors.
Advisor is a member of the National Association of Personal Financial Advisors (NAPFA),
which requires that its members are fee-only and obtain a minimum of 60 continuing
education credits every two years.
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 9
Advisor is a member of the National Association of Tax Professionals (NATP), a non-profit
professional association which provides support, continuing education, and research services
to its members.
Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Delphinus Financial Advisors, LLC seeks to avoid material conflicts of interest. Accordingly,
neither Advisor nor its Investment Adviser Representatives nor its team members receive
any third party direct monetary compensation (i.e., commissions, 12b-1 fees, or other fees)
from brokerage firms (custodians) or mutual fund companies.
Although Advisor believes that its business methodologies, ethics rules, and adopted policies
are appropriate to eliminate, or at least minimize, potential material conflicts of interest, and
to appropriately manage any material conflicts of interest that may remain, clients should be
aware that no set of rules can possibly anticipate or relieve all potential material conflicts of
interest. In any event, Advisor will disclose to advisory clients any material conflict of
interest relating to Advisor, its representatives, or any of its employees which could
reasonably be expected to impair the rendering of unbiased and objective advice.
Code of Ethics
Advisor has adopted a Code of Ethics for all supervised persons of the firm describing its
high standard of business conduct and fiduciary duty to its clients. The Code of Ethics
includes provisions relating to the confidentiality of client information, a prohibition on
insider trading, restrictions on the acceptance of significant gifts and the reporting of certain
gifts and business entertainment items, and personal securities trading procedures, among
other things. All supervised persons of Advisor must acknowledge the terms of the Code of
Ethics annually, or as amended.
Additionally, Advisor follows the standards set by the Certified Financial Planning Board,
the Fiduciary Oath promulgated by the National Association of Personal Financial Advisors,
and the Cambridge Pledge to Clients by the Alliance of Comprehensive Planners.
Participation or Interest in Client Transactions and Personal Trading
Advisor does not currently participate in securities in which it has a material financial
interest. Advisor and its related persons, as a matter of policy, do not recommend to clients,
or buy or sell for client accounts, securities in which the firm or its related persons has a
material financial interest.
Advisor or individuals associated with Advisor may buy and sell some of the same securities
for its own account that Advisor buys and sells for its clients. When appropriate the Advisor
will purchase or sell securities for clients before purchasing or selling the same securities for
Advisor’s own account. In some cases, Advisor may buy or sell securities for its own account
for reasons not related to the strategies adopted by the Advisor’s clients. The Code of Ethics
is designed to assure that the personal securities transactions will not interfere with making
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 10
decisions in the best interest of advisory clients while at the same time, allowing employees
to invest for their own accounts.
Certain classes of securities, such as open-ended mutual funds, are designated as exempt
transactions, meaning employees may trade these without prior permission because such
trades would not materially interfere with the best interest of Advisor’s clients. Nonetheless,
because the Code of Ethics permits employees to invest in the same securities as clients,
there is a possibility that employees might somehow benefit from the market activity of a
client. Accordingly, when applicable, Employee trading is monitored under the Code of
Ethics, and to reasonably prevent conflicts of interest between Advisor and its clients.
Advisor will disclose to advisory clients any material conflict of interest relating to Advisor,
its representatives, or any of its employees which could reasonably be expected to impair the
rendering of unbiased and objective advice. Advisor will notify clients in advance of its
policies in respect to officers trading for their own account including the potential conflict of
interest that arises when recommending securities to clients in which Advisor or its principal
holds a material position.
Item 12 – Brokerage Practices
Advisor may use its discretion when recommending a broker-dealer. Client is not obligated
to effect transactions through any broker-dealer recommended by Advisor. When
recommending a broker-dealer the Advisor will comply with its fiduciary duty to obtain best
execution and with the Securities Exchange Act of 1934, and will take into account such
relevant factors as:
Price
The broker-dealer’s facilities, reliability and financial responsibility
The ability of the broker-dealer to effect transactions, particularly with regard to such
aspects as timing, order size and execution of order
The research and related brokerage services provided by such broker or dealer to the
Advisor, notwithstanding that the account may not be the direct or exclusive
beneficiary of such services
Any other factors the Advisor considers to be relevant
Advisor currently recommends clients use Charles Schwab & Co. Inc. as the independent
qualified custodian for their assets. Charles Schwab & Co. Inc. (“Schwab”) is a registered
broker-dealer and SIPC member. Advisor is independently owned and operated and not
affiliated with Schwab. Schwab offers independent investment Advisors services which
include custody of securities, trade execution, clearance, and settlement of transactions.
Advisor may receive some benefits from Schwab through its participation in their program.
(Please see the disclosure under Item 14 below.)
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 11
Item 13 - Review of Accounts
Delphinus Financial Advisors, LLC is responsible for reviewing accounts and providing
recommendations as follows:
Clients typically receive account reviews annually in conjunction with the relevant client
meeting, or as needed upon client request. Reviews are performed by Anthony Salotto or by
other Investment Adviser Representatives registered with Delphinus Financial Advisors,
LLC.
Clients typically receive financial planning recommendations at or soon after the conclusion
of a client meeting. Recommendations are provided by Anthony Salotto or by other
Investment Adviser Representatives registered with Delphinus Financial Advisors, LLC.
If you maintain any brokerage account(s), your custodian will provide a statement at least
quarterly which includes a list of all assets held in the account, asset values, and all
transactions affecting the account assets, including any additions or withdrawals.
Item 14 - Client Referrals and Other Compensation
Delphinus Financial Advisors, LLC is a fee-only financial planning firm and does not sell
insurance or investment products, nor does it accept commissions because of any product
recommendations.
As disclosed under Item 12 above, Advisor participates in Schwab Advisor Services™ which
provides Advisor and its clients with access to their institutional brokerage services (trading,
custody, reporting, and related services), many of which are not typically available to Schwab
retail customers. Schwab also makes available to Advisor various support services some of
which help Advisor manage or administer clients’ accounts, while others help Advisor
manage and grow its business. Schwab’s support services are generally available on an
unsolicited basis (Advisor doesn’t have to request them) and at no cost to Advisor. These
benefits may include the following products and services (provided without cost or at a
discount): receipt of duplicate Client statements and confirmations; research related products
and tools; consulting services; access to a trading desk serving Advisor participants; access to
block trading (which provides the ability to aggregate securities transactions for execution
and then allocate the appropriate shares to Client accounts); the ability to have advisory fees
deducted directly from Client accounts; access to an electronic communications network for
Client order entry and account information; access to mutual funds with no transaction fees
and to certain institutional money managers; and compliance, marketing, research,
technology, and practice management products or services provided to Advisor by third
party vendors without cost or at a discount. The benefits received by Advisor through
participation in the program do not depend on the amount of brokerage transactions
directed to Schwab. As part of its fiduciary duties to clients, Advisor endeavors at all times to
put the interests of its clients first. Clients should be aware, however, that the receipt of
economic benefits by Advisor or its related persons in and of itself creates a potential
conflict of interest and may indirectly influence the Advisor's choice of Schwab for custody
and brokerage services.
Part 2A of Form ADV for Delphinus Financial Advisors, LLC – Page 12
Item 15 - Custody
Clients will receive at least quarterly statements from the broker-dealer, bank or other
qualified custodian that holds and maintains the client’s investment assets. Advisor urges all
clients to carefully review such statements and compare such official custodial records to any
statements that we may provide to you. Advisor may also provide clients with periodic
reports on client’s account. These reports may vary from custodial statements based on
accounting procedures, reporting dates, or valuation methodologies of certain securities.
Because we deduct Advisor’s fees for some clients, we are deemed to have constructive
custody. Because the Firm follows certain SEC Rule custody safeguards, the Firm is not
subject to the additional requirements of an adviser with physical custody of client funds and
securities.
The Firm may, at times, have constructive custody of assets to the extent it uses Standing
Letters of Authorizations (“SLOAs”) for third-party money movement. The Firm satisfies
the requirements set forth in the SEC No-Action Letter of February 21, 2017, to avoid the
surprise annual audit requirements otherwise required of an adviser with custody.
Item 16 - Investment Discretion
Advisor’s role is to make investment and planning recommendations. Clients will execute a
Limited Power of Attorney (LPOA) granting Advisor trading authority over certain client
accounts. Advisor will manage these accounts on a discretionary basis meaning the Advisor
will execute trades in these accounts without the client’s prior approval in accordance with
client’s objectives and suitability. For certain clients’ Held Away Accounts, Advisor will
provide recommendations and advice, which client is under no obligation to follow. The
implementation of any recommendations made by Advisor for Held Away Accounts is the
sole and exclusive responsibility of the client.
Item 17 – Voting Client Securities
As a matter of firm policy and practice, Advisor does not have any authority to and does not
vote proxies on behalf of advisory clients. Clients retain the responsibility for receiving and
voting proxies for all securities maintained in client portfolios. At the request of a client,
Advisor may provide advice to clients regarding the client’s voting of proxies.
Item 18 – Financial Information
Registered Investment Advisers are required to provide you with certain financial
information or disclosures about their financial condition. Advisor will not require
prepayment of more than $1200 in fees for services to be provided six months or more in
advance from any client. Advisor has no financial commitment that impairs its ability to
meet contractual and fiduciary commitments to clients and has not been the subject of a
bankruptcy proceeding.