Overview

Assets Under Management: $297 million
Headquarters: NEEDHAM, MA
High-Net-Worth Clients: 211
Average Client Assets: $1 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection, Educational Seminars

Fee Structure

Primary Fee Schedule (GOODMAN ADVISORY GROUP DISCLOSURE BROCHURE, BROCHURE SUPPLEMENT AND PRIVACY POLICY)

MinMaxMarginal Fee Rate
$0 and above 1.80%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $18,000 1.80%
$5 million $90,000 1.80%
$10 million $180,000 1.80%
$50 million $900,000 1.80%
$100 million $1,800,000 1.80%

Clients

Number of High-Net-Worth Clients: 211
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 76.90
Average High-Net-Worth Client Assets: $1 million
Total Client Accounts: 776
Discretionary Accounts: 776

Regulatory Filings

CRD Number: 285637
Last Filing Date: 2024-11-08 00:00:00
Website: https://goodmanadv.com

Form ADV Documents

Additional Brochure: GOODMAN ADVISORY GROUP DISCLOSURE BROCHURE, BROCHURE SUPPLEMENT AND PRIVACY POLICY (2025-05-05)

View Document Text
Registered as: Goodman Advisory Group, LLC Form ADV Part 2A – Disclosure Brochure Effective: May 5, 2025 This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Goodman Advisory Group, LLC (“Goodman Advisory Group” or the “Advisor”). If you have any questions about the contents of this Disclosure Brochure, please contact us at (781) 559-0320. Goodman Advisory Group is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about Goodman Advisory Group to assist you in determining whether to retain the Advisor. Additional information about Goodman Advisory Group and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 285637. Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 http://www.goodmanadvisorygroup.com 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 advisory personnel of Goodman Advisory Group. For convenience, we have combined these documents into a single disclose document. Material Changes We have updated our address to 160 Gould St. Suite 102, Needham, MA 02494 Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client 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 our firm name or our CRD# 285637. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (781) 559-0320. Page 2 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................ 1 Item 2 – Material Changes ...................................................................................................................................... 2 Item 3 – Table of Contents ..................................................................................................................................... 3 Item 4 – Advisory Services .................................................................................................................................... 4 A. Firm Information ............................................................................................................................................................ 4 B. Advisory Services Offered ............................................................................................................................................. 4 C. Client Account Management ......................................................................................................................................... 5 D. Wrap Fee Programs ..................................................................................................................................................... 6 E. Assets Under Management .......................................................................................................................................... 6 Item 5 – Fees and Compensation .......................................................................................................................... 6 A. Fees for Advisory Services ........................................................................................................................................... 6 B. Fee Billing ..................................................................................................................................................................... 6 C. Other Fees and Expenses ............................................................................................................................................ 7 D. Advance Payment of Fees and Termination ................................................................................................................. 7 E. Compensation for Sales of Securities ........................................................................................................................... 8 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 A. Methods of Analysis ...................................................................................................................................................... 8 B. Risk of Loss .................................................................................................................................................................. 9 Item 9 – Disciplinary Information ......................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 11 A. Code of Ethics ............................................................................................................................................................. 11 B. Personal Trading with Material Interest ....................................................................................................................... 11 C. Personal Trading in Same Securities as Clients ......................................................................................................... 11 D. Personal Trading at Same Time as Client .................................................................................................................. 12 Item 12 – Brokerage Practices ............................................................................................................................. 12 A. Recommendation of Custodian[s] ............................................................................................................................... 12 B. Aggregating and Allocating Trades ............................................................................................................................. 12 Item 13 – Review of Accounts.............................................................................................................................. 13 A. Frequency of Reviews................................................................................................................................................. 13 B. Causes for Reviews .................................................................................................................................................... 13 C. Review Reports ........................................................................................................................................................... 13 Item 14 – Client Referrals and Other Compensation ......................................................................................... 13 A. Compensation Received by Goodman Advisory Group .............................................................................................. 13 B. Client Referrals from Solicitors .................................................................................................................................... 13 Item 15 – Custody ................................................................................................................................................. 13 Item 16 – Investment Discretion .......................................................................................................................... 14 Item 17 – Voting Client Securities ....................................................................................................................... 14 Item 18 – Financial Information ........................................................................................................................... 14 Appendix 1 - Wrap Fee Program Brochure ........................................................................................................ 15 Form ADV Part 2B – Brochure Supplements ..................................................................................................... 22 Privacy Policy ........................................................................................................................................................ 32 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Page 3 Item 4 – Advisory Services A. Firm Information Goodman Advisory Group, LLC (“Goodman Advisory Group” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”), which is organized as a Limited Liability Company (“LLC”) under the laws of the Commonwealth of Massachusetts. Goodman Advisory Group was founded in September 2009 and began operating as an independent registered investment advisor in January 2017. Goodman Advisory Group is owned and operated by Deborah N. Goodman (Principal and Chief Compliance Officer) and Joseph Rofino. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Goodman Advisory Group. The Advisor serves as a fiduciary to Clients, as defined under 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. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. B. Advisory Services Offered Goodman Advisory Group offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable organizations, retirement plans and businesses in the Commonwealth of Massachusetts and other states (each referred to as a “Client”). Investment Management Services Goodman Advisory Group provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and a broad range of comprehensive financial planning and consulting services. Goodman Advisory Group 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. Goodman Advisory Group will implement the investment strategy with its internal management and/or the use of unaffiliated money managers (as described below). Internal Management Services - Goodman Advisory Group evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Goodman Advisory Group will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. The Advisor may retain certain types of investments based on a Client’s legacy portfolio construction. Goodman Advisory Group’s investment strategy[ies] is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. Goodman Advisory Group may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Goodman Advisory Group 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. Goodman Advisory Group may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Goodman Advisory Group accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. For additional information, please see Item 12 – Brokerage Practices and Item 15 - Custody. Page 4 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Financial Planning Services Goodman Advisory Group will typically provide a variety of 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, objectives and financial situation. 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, risk management assessment, as well as tax planning, retirement needs analysis, college funding, business succession, insurance needs, elder care issues and estate planning insight and other areas of a Client’s financial situation. 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. Goodman Advisory Group may also refer Clients to an accountant, attorney or another specialist, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may or may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. C. Client Account Management Prior to engaging Goodman Advisory Group to provide investment advisory services, each Client is required to enter into one or 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 – Goodman Advisory Group, in connection with the Client, will develop a strategy that seeks to achieve the Client’s investment goals and objectives. • Asset Allocation – Goodman Advisory Group will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance of risk for each Client. • Portfolio Construction – Goodman Advisory Group will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – Goodman Advisory Group will provide investment management and ongoing oversight of the Client’s investment portfolio. Page 5 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com D. Wrap Fee Programs Goodman Advisory Group includes securities transaction fees together with its investment advisory fees. Including these fees into a single asset-based fee is considered a “Wrap Fee Program”. The Advisor customizes its investment management services for its Clients. The Advisor sponsors the Goodman Advisory Group Wrap Fee Program solely as a supplemental disclosure regarding the combination of fees. Depending on the level of trading required for the Client’s account[s] in a particular year, the Client may pay more or less in total fees than if the Client paid its own transaction fees. Please see Appendix 1 – Wrap Fee Program Brochure, which is included as a supplement to this Disclosure Brochure. E. Assets Under Management As of December 31, 2024 the Goodman Advisory Group manages approximately: Assets Under Management Discretionary $370,433,857 Non-discretionary $0 Total: $370,433,857 Clients may request more current information at any time by contacting the Advisor. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written agreement with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range up to 1.80% annually 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 investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by Goodman Advisory Group will be independently valued by the Custodian. Goodman Advisory Group will not have the authority or responsibility to value portfolio securities. Financial Planning Services Goodman Advisory Group offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly engagements range from $200 to $500 per hour. Fixed fee engagement fees range from $2,500 to $10,000. 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 for total hours and/or total costs will be provided to the Client prior to engaging for these services. B. Fee Billing Page 6 Investment Management Services Investment advisory fees are calculated by the Custodian and deducted from the Client’s account[s]. The Client shall instruct the Custodian to deduct the investment advisory fee from the Client’s account[s] for each billing period and pay the investment advisory fee[s] to the Advisor. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with Goodman Advisory Group at the end of each quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com investment advisory fee. It is the responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written authorization permitting Goodman Advisory Group to be paid directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Financial Planning Services Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the financial planning agreement. The balance shall be invoiced 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 Goodman Advisory Group, in connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees charged by the Custodian. The fees charged by Goodman Advisory Group are separate and distinct from these custody and execution fees. In addition, all fees paid to Goodman Advisory Group for investment advisory 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 could invest in these products directly, without the services of Goodman Advisory Group, but would not receive the services provided by Goodman Advisory Group which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by Goodman Advisory Group to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services Goodman Advisory Group is compensated for its services in advance of the quarter in which investment advisory services are rendered. Either party may also terminate the investment advisory agreement, at any time, by providing advance written notice 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. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Financial Planning Services Goodman Advisory Group requires an advance deposit as described above. 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 or in the case of a fixed fee engage, the percentage of the engagement scope completed by the Advisor. The Advisor will refund any unearned, prepaid planning fees from the effective date of termination. The Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent. Page 7 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com E. Compensation for Sales of Securities Certain Advisory Persons of Goodman Advisory Group may also be registered representatives of LPL Financial LLC ("LPL Financial"), a securities broker-dealer, and a member of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). In one’s separate capacity as a registered representative of LPL Financial, an Advisory Person may implement securities transactions under LPL Financial and not through Goodman Advisory Group. In such instances, an Advisory Person will receive commission-based compensation in connection with the purchase and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by an Advisory Person in one’s capacity as a registered representative is separate and in addition to Goodman Advisory Group’s advisory fees. This practice presents a conflict of interest because Advisory Persons who are registered representatives may have an incentive to effect securities transactions for the purpose of generating commissions rather than solely based on the Client’s needs. We mitigate this conflict in two ways. First, Clients are under no obligation, contractually or otherwise, to purchase securities products through one of our Advisory Persons. Second, Goodman Advisory Group will not charge an ongoing investment advisory fee on any assets implemented in the separate capacity of one of our Advisory Persons. Please see Item 10. Certain Advisory Persons are also licensed as independent insurance professionals and will earn commission- based compensation for selling insurance products. Insurance commissions earned by the Advisory Person are separate and in addition to advisory fees paid to Goodman Advisory Group. This practice presents a conflict of interest, as there may be an incentive to recommend insurance products for the purpose of generating commissions rather than solely based on a Client’s needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through the Advisory Person. Please see Item 10 for additional information. Item 6 – Performance-Based Fees and Side-By-Side Management Goodman Advisory Group does not charge performance-based fees for its investment advisory services. The fees charged by Goodman Advisory Group are as described in Item 5 – Fees and Compensation above and are not based upon the capital appreciation of the funds or securities held by any Client. Goodman Advisory Group does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients. Item 7 – Types of Clients Goodman Advisory Group offers investment advisory services to high net worth individuals, individuals, trusts, estates, charitable organizations, retirement plans and businesses in the Commonwealth of Massachusetts and other states. 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. Goodman Advisory Group generally requires a minimum size for establishing a relationship of $1,000,000, which may be waived in the Advisor’s sole discretion. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis Goodman Advisory Group employs fundamental, technical and behavioral analysis methods in developing investment strategies for its Clients. Research and analysis from Goodman Advisory Group is 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. Page 8 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com 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”. Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that Goodman Advisory Group will be able to accurately predict such a reoccurrence. Behavioral finance analysis involves an examination of conventional economics as well as behavioral and cognitive psychological factors. Behavioral finance methodology seeks to combine a qualitative and quantitative approach to provide explanations for why individuals may, at times, make irrational financial decisions. Where conventional financial theories have failed to explain certain patterns, the behavioral finance methodology investigates the underlying reasons and biases that cause some people to behave against their best interests. The risks relating to behavior finance analysis are that it relies on spotting trends in human behavior that may not predict future trends. As noted above, Goodman Advisory Group generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. Goodman Advisory Group will typically hold all or a portion of a security for more than a year, but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Goodman Advisory Group may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. Goodman Advisory Group will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in “Item 13 – Review of Accounts”. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The Advisor does not utilize margin borrowing as part of its trading strategies, but may utilize margin in order to meet liquidity needs or to maintain flexibility with certain positions. 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 strategy: Page 9 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com 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 has 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. the mutual funds will fluctuate with the value of the underlying securities that make up the Mutual Fund Risks – The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of 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. Options Contracts – Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Real Estate Investment Trusts (“REITs”) – Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. Equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). financially troubled companies, most of which are privately held and lack investments may carry higher risks and are also subject to interest rate, liquidity risks. Client should only have a portion of their assets in these Business Development Companies – The use of business development companies involves investing in smaller and developing companies, as well as publicly available information. These leverage, valuation, price volatility and investments. Pandemic Risk – Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. 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 Goodman Advisory Group or any of its Supervised Persons. Goodman Advisory Group and its Supervised Persons value the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 285637. Page 10 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation As noted in Item 5, certain Advisory Persons are also a registered representative of LPL Financial. In an Advisory Person’s separate capacity as a registered representative, the Advisory Person will typically receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by an Advisory Person of Goodman Advisory Group. Neither Goodman Advisory Group nor an Advisory Person will earn ongoing investment advisory fees in connection with any services implemented in the Advisory Person’s separate capacity as a registered representative. Under supervision by LPL Financial, LPL Financial may have access to certain confidential information of the Client, including, but not limited to financial information, investment objectives, transactions and holdings information. Please see our Privacy Policy, which is included with this Disclosure Brochure. Insurance Agency Affiliations As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of insurance recommendations are separate and apart from their role with Goodman Advisory Group. As insurance professionals, Advisory Persons may receive customary commissions and other related revenues from the various insurance companies whose products are sold. Advisory Persons are not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by the Advisory Persons or the Advisor. Use of Independent Managers The Advisor may recommend that all or a portion of a Client’s portfolio be implemented using one or more Independent Managers. Please see item 4 above as well as Item 14. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Goodman Advisory Group has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client. This Code applies to all persons associated with Goodman Advisory Group (our “Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. Goodman Advisory Group and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of Goodman Advisory Group’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code, please contact us at (781) 559-0320. B. Personal Trading with Material Interest Goodman Advisory Group allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Goodman Advisory Group does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company. Goodman Advisory Group does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients Goodman Advisory Group allows our 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 we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have 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 may have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can potentially 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 Goodman Advisory Group requiring reporting of personal securities trades Page 11 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. We have also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While Goodman Advisory Group allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will Goodman Advisory Group, or any Supervised Person of Goodman Advisory Group, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] Goodman Advisory Group does not have discretionary authority to select the broker-dealer/custodian (herein the “Custodian”) for custody and execution services. As certain Advisory Persons are also registered representatives of LPL Financial, Goodman Advisory Group is limited in the Custodian[s] in which can be recommended to Clients. Typically, Goodman Advisory Group will recommend that Clients engage LPL Financial as the Custodian, where Goodman Advisory Group has access to LPL Financial’s systems, back office support, research and other benefits. While Goodman Advisory Group receives these economic benefits from LPL Financial, we believe LPL Financial provides quality execution and related services for our Clients at competitive prices. Price is not the sole factor Goodman Advisory Group considers in evaluating best execution and the recommendation of a custodian. Goodman Advisory Group also considers the quality of the brokerage services provided by LPL Financial, including the firm's reputation, execution capabilities, commission rates, and responsiveness to our Clients and our firm. Clients are free to use whatever broker-dealer/custodian they choose to implement financial planning recommendations. For investment advisory services, Goodman Advisory Group would be required to obtain permission to use a broker-dealer/custodian other than LPL Financial due to the oversight role LPL Financial assumes over the Advisory Persons. Please see Item 14. 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 the broker-dealer/custodian in exchange for research and other services. Goodman Advisory Group 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. 2. Brokerage Referrals - Goodman Advisory Group does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Goodman Advisory Group will place trades within the established account[s] at the Custodian as directed by the Client. Further, all Client accounts are traded within their respective brokerage account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Goodman Advisory Group will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the designated Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Goodman Advisory Group will execute its transactions through the Custodian as authorized by the Client. Goodman Advisory Group may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities Page 12 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Client accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by an advisory person. Formal reviews are generally conducted at least annually or more or less 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 or less 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 Goodman Advisory Group if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Item 14 – Client Referrals and Other Compensation A. Compensation Received by Goodman Advisory Group Participation in Institutional Advisor Platform Goodman Advisory Group has established institutional relationship with LPL Financial to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support as part of its relationship with LPL Financial. 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 potential conflict of interest since these benefits may influence the Advisor's recommendation of the Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from LPL Financial: 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 Goodman Advisory Group does not engage paid solicitors for Client referrals. Item 15 – Custody Goodman Advisory Group does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct Goodman Advisory Group to utilize the Custodian for the Client’s security transactions. Clients should review statements provided by the Page 13 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com account custodian and compare to any reports provided by Goodman Advisory Group to ensure accuracy, 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 Goodman Advisory Group generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Goodman Advisory Group. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by Goodman Advisory Group will be in accordance with each Client's investment objectives and goals. Item 17 – Voting Client Securities Goodman Advisory Group does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither Goodman Advisory Group, nor its management, have any adverse financial situations that would reasonably impair the ability of Goodman Advisory Group to meet all obligations to its Clients. Neither Goodman Advisory Group, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. Goodman Advisory Group is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more in advance. Page 14 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 1 – Cover Page Registered as: Goodman Advisory Group, LLC Form ADV Part 2A Appendix 1 (“Wrap Fee Program Brochure”) Effective: May 5, 2025 This Form ADV 2A - Appendix 1 (“Wrap Fee Program Brochure”) provides information about the qualifications and business practices for Goodman Advisory Group, LLC (“Goodman Advisory Group” or the “Advisor”) services when offering services pursuant to a wrap program. This Wrap Fee Program Brochure shall always be accompanied by the Goodman Advisory Group Disclosure Brochure, which provides complete details on the business practices of the Advisor. If you did not receive the complete Goodman Advisory Group Disclosure Brochure or you have any questions about the contents of this Wrap Fee Program Brochure or the Goodman Advisory Group Disclosure Brochure, please contact us at (781) 559-0320. Ascent is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Wrap Fee Program 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 Wrap Fee Program Brochure provides information about Ascent to assist you in determining whether to retain the Advisor. Additional information about Goodman Advisory Group and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 285637. Page 15 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 2 – Material Changes Form ADV 2 - Appendix 1 provides information about a variety of topics relating to an Advisor’s business practices and conflicts of interest. In particular, this Wrap Fee Program Brochure discusses wrap fee programs offering by the Advisor. Material Changes We have updated our address to 160 Gould St. Suite 102, Needham, MA 02494 Future Changes From time to time, we may amend this Wrap Fee Program Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Wrap Fee Program Brochure (along with the complete Goodman Advisory Group Disclosure Brochure) or a Summary of Material Changes shall be provided to each Client annually and if a material change occurs in the business practices of Goodman Advisory Group. At any time, you may view this Wrap Fee Program Brochure and the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 285637. You may also request a copy of this Disclosure Brochure at any time, by contacting us at (781) 559-0320. Page 16 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 3 – Table of Contents Item 1 – Cover Page .............................................................................................................................................. 15 Item 2 – Material Changes .................................................................................................................................... 16 Item 3 – Table of Contents ................................................................................................................................... 17 Item 4 – Services Fees and Compensation ........................................................................................................ 18 Item 5 – Account Requirements and Types of Clients ...................................................................................... 19 Item 6 – Portfolio Manager Selection and Evaluation ....................................................................................... 19 Item 7 – Client Information Provided to Portfolio Managers ............................................................................ 20 Item 8 – Client Contact with Portfolio Managers ............................................................................................... 20 Item 9 – Additional Information ........................................................................................................................... 20 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 Page 17 www.goodmanadvisorygroup.com Item 4 – Services Fees and Compensation A. Services Goodman Advisory Group provides customized investment advisory services for its Clients. This Wrap Fee Program Brochure is provided as a supplement to the Goodman Advisory Group Disclosure Brochure (Form ADV 2A). This Wrap Fee Program Brochure is provided along with the complete Disclosure Brochure to provide full details of the business practices and fees when selecting Goodman Advisory Group as your investment advisor. As part of the investment advisory fees noted in Item 5 – Fees and Compensation of the Disclosure Brochure, Goodman Advisory Group includes normal securities transaction fees as part of the overall investment advisory fee. Securities regulations often refer to this combined fee structure as a “Wrap Fee Program”. The sole purpose of this Wrap Fee Program Brochure is to provide additional disclosure relating the combination of securities transaction fees into the single “bundled” investment advisory fee. This Wrap Fee Program Brochure references back to the Goodman Advisory Group Disclosure Brochure in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Disclosure Brochure for details on Goodman Advisory Group’s investment philosophy and related services. B. Program Costs Advisory services provided by Goodman Advisory Group are offered in a wrap fee structure whereby normal securities transaction costs are included in the overall investment advisory fee paid to Goodman Advisory Group. As the level of trading in a Client’s account[s] may vary from year to year, the annual cost to the Client may be more or less than engaging for advisory services where the transactions costs are borne separately by the Client. The cost of the Wrap Fee Program varies depending on services to be provided be to each Client, however, the Client is not charged more if there is higher trading activity in the Client’s account[s]. A Wrap Fee structure has a potential conflict of interest as the Advisor may have an incentive to limit the number of trades placed in the Client’s account[s]. Please see Item 5 – Fees and Compensation of the Disclosure Brochure for complete details on fees. C. Fees Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the agreement. Investment advisory fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment advisory fees range up to 1.80% annually 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 investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with Advisor. All securities held in accounts managed by Goodman Advisory Group will be independently valued by the Custodian. Goodman Advisory Group will not have the authority or responsibility to value portfolio securities. As noted above, the Wrap Fee Program includes normal securities trading costs incurred in connection with the discretionary investment management services provided by Goodman Advisory Group. Securities transaction fees for Client-directed trades may be charged back to the Client. Clients may incur certain fees or charges imposed by third parties in connection with investments made on behalf of the Client’s account[s]. Under this Wrap Fee Program, Goodman Advisory Group includes securities transactions costs as part of its overall investment advisory fee. In addition, all fees paid to Goodman Advisory Group for investment advisory services or part of the Wrap Fee Program are separate and distinct from the expenses charged by mutual funds and exchange-traded funds to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and Page 18 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com 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. The Client may also incur other costs assessed by the Custodian or other parties for account related activity fees, such as wire transfer fees, trade away fees and other fees. The Advisor does not control nor share in these fees. The Client should r e v i e w both the fees charged by the fund[s] and the fees charged by Goodman Advisory Group to fully understand the total fees to be paid. Please see Item 5.C. – Other Fees and Expenses in the Disclosure Brochure (included with this Wrap Fee Program Brochure). D. Compensation Goodman Advisory Group is the sponsor and portfolio manager of this Wrap Fee Program. Goodman Advisory Group receives investment advisory fees paid by Clients for participating in the Wrap Fee Program and pays the Custodian for the costs associated with the normal trading activity in the Client’s account[s]. Item 5 – Account Requirements and Types of Clients Goodman Advisory Group offers investment advisory services to high-net-worth individuals, individuals, trusts, estates, charitable organizations and businesses. Goodman Advisory Group generally requires a minimum account size for establishing a relationship of $1,000,000 to effectively implement its investment process, which may be waived in the Advisor’s sole discretion. Please see Item 7 – Types of Clients in the Disclosure Brochure for additional information. Item 6 – Portfolio Manager Selection and Evaluation Portfolio Manager Selection Goodman Advisory Group serves as sponsor and as portfolio manager for the services under this Wrap Fee Program. Related Persons Goodman Advisory Group personnel serve as portfolio managers for this Wrap Fee Program. Goodman Advisory Group does not serve as a portfolio manager for any third-party wrap fee programs. Performance-Based Fees Goodman Advisory Group does not charge performance-based fees. Supervised Persons Goodman Advisory Group Advisory Persons serve as portfolio managers for all accounts, including the services described in this Wrap Fee Program Brochure. Details of the advisory services provided are included in Item 4.A. of the Disclosure Brochure. Methods of Analysis Please see Item 8 of the Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on the research and analysis methods employed by the Advisor. 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. Goodman Advisory Group will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. 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[s]. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided Page 19 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com 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. 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. Please see Item 8.B. – Risk of Loss in the Disclosure Brochure for details on investment risks. Proxy Voting Goodman Advisory Group does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 7 – Client Information Provided to Portfolio Managers Goodman Advisory Group is the sponsor and sole portfolio manager for the Program. The Advisor does not share Client information with other portfolio managers because it is the sole portfolio manager for this Wrap Fee Program. Please also see the Goodman Advisory Group Privacy Policy (included after this Wrap Fee Program Brochure). Item 8 – Client Contact with Portfolio Managers Goodman Advisory Group is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at Goodman Advisory Group. Item 9 – Additional Information A. Disciplinary Information and Other Financial Industry Activities and Affiliations Goodman Advisory Group values the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any advisor or service provider with whom you partner. Our backgrounds are on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our firm name or our CRD# 285637. Please see Item 9 of the Goodman Advisory Group Disclosure Brochure as well as Item 3 of each Advisory Person’s Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the background of the Advisor and its Advisory Persons. Other Financial Activities and Affiliations Please see Items 10 and 14 of the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure). B. Code of Ethics, Review of Accounts, Client Referrals, and Financial Information Goodman Advisory Group has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all persons subject to Goodman Advisory Group’s compliance program (our “Supervised Persons”). Complete details on the Goodman Advisory Group Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Review of Accounts Investments in Client accounts are monitored on a regular and continuous basis by Advisory Persons of Goodman Advisory Group under the supervision of the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure. Page 2 0 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Other Compensation Participation in Institutional Advisor Platform Goodman Advisory Group has established institutional relationship with LPL Financial to assist the Advisor in managing Client account[s]. The Advisor receives access to software and related support as part of its relationship with LPL Financial. 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 potential conflict of interest since these benefits may influence the Advisor's recommendation of the Custodian over one that does not furnish similar software, systems support, or services. Additionally, the Advisor may receive the following benefits from LPL Financial; 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. Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Program Brochure) for details on additional compensation that may be received by Goodman Advisory Group or its Advisory Persons. Each Advisory Person’s Brochure Supplement (also included with this Wrap Fee Program Brochure) provides details on any outside business activities and the associated compensation. Client Referrals from Solicitors Goodman Advisory Group does not engage paid solicitors for Client referrals. Financial Information Neither Goodman Advisory Group, nor its management has any adverse financial situations that would reasonably impair the ability of Goodman Advisory Group to meet all obligations to its Clients. Neither Goodman Advisory Group, nor any of its Advisory Persons, has been subject to a bankruptcy or financial compromise. Goodman Advisory Group is not required to deliver a balance sheet along with this Disclosure Brochure, as the firm does not collect advance fees of $1,200 or more for services to be performed six months or more in advance. Please see Item 18 of the Form ADV Part 2A – Disclosure Brochure. Page 21 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 1 – Cover Page Form ADV Part 2B – Brochure Supplement for Deborah N. Goodman, CFP®, CPA, President and Chief Compliance Officer Effective: May 5, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Deborah N. Goodman, CPA, CFP® (CRD# 5331474) in addition to the information contained in the Goodman Advisory Group, LLC (“Goodman Advisory Group” or the “Advisor”, CRD# 285637) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Goodman Advisory Group Disclosure Brochure or this Brochure Supplement, please contact us at (781) 559- 0320. Additional information about Ms. Goodman is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 5331474. Page 22 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 2 – Educational Background and Business Experience Deborah N. Goodman, CFP®, CPA, , born in 1976, is dedicated to advising Clients of Goodman Advisory Group as the President and Chief Compliance Officer. She brings over 27 years of financial planning knowledge and client servicing experience to Goodman Advisory Group, LLC. Deborah provides total wealth management strategies for high net worth individuals including access to investment advisory services, risk management assessment, as well as tax planning, retirement needs analysis, college funding, business succession, elder care issues and estate planning insight. Deborah obtained a Bachelor of Science in Economics from the Wharton School of the University of Pennsylvania and a Master of Business Administration from Babson College. Additional information regarding Deborah’s employment history is included below. Employment History: President and Chief Compliance Officer, Goodman Advisory Group, LLC Registered Representative, LPL Financial LLC Vice President, LPL Financial LLC d/b/a Goodman Advisory Group Senior Financial Analyst, Boston Scientific Corporation Senior Associate, Arthur Andersen, LLP 11/2016 to Present 08/2007 to Present 05/2007 to 10/2016 09/2001 to 09/2005 09/1998 to 09/2001 About the CFP® Designation The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP® Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. Currently, more than 71,000 individuals have obtained CFP® certification in the United States. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP® Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP® Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination, administered in 10 hours over a two-day period, includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as 2,000 hours per year); and • Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services Page 23 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP® Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. Certified Public Accountant (“CPA”) CPAs are licensed and regulated by their state boards of accountancy. While state laws and regulations vary, the education, experience and testing requirements for licensure as a CPA generally include minimum college education (typically 150 credit hours with at least a baccalaureate degree and a concentration in accounting), minimum experience levels (most states require at least one year of experience providing services that involve the use of accounting, attest, compilation, management advisory, financial advisory, tax or consulting skills, all of which must be achieved under the supervision of or verification by a CPA), and successful passage of the Uniform CPA Examination. In order to maintain a CPA license, states generally require the completion of 40 hours of continuing professional education (CPE) each year (or 80 hours over a two-year period or 120 hours over a three-year period). Additionally, all American Institute of Certified Public Accountants (AICPA) members are required to follow a rigorous Code of Professional Conduct which requires that they act with integrity, objectivity, due care, competence, fully disclose any conflicts of interest (and obtain client consent if a conflict exists), maintain client confidentiality, disclose to the client any commission or referral fees, and serve the public interest when providing financial services. The vast majority of state boards of accountancy have adopted the AICPA’s Code of Professional Conduct within their state accountancy laws or have created their own. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Ms. Goodman. Ms. Goodman has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Ms. Goodman. 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 Ms. Goodman. However, we do encourage you to independently view the background of Ms. Goodman on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 5331474. Item 4 – Other Business Activities Broker-Dealer Affiliation Ms. Goodman is also a registered representative of LPL Financial LLC (“LPL Financial”). In Ms. Goodman’s separate capacity as a registered representative, Ms. Goodman will typically receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by Ms. Goodman. Neither the Advisor nor Ms. Goodman will earn ongoing investment advisory fees in connection with any products or services implemented in Ms. Goodman’s separate capacity as a registered representative. Insurance Agency Affiliations Deborah Goodman is also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from Ms. Goodman’s role with Goodman Advisory Group. As an insurance professional, she may receive customary commissions and other related revenues from the various insurance companies whose products are sold. Ms. Goodman is not required to offer the products of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory fees. This may cause a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by Ms. Goodman or the Advisor. Page 24 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com In addition to Deborah’s broker-dealer and insurance affiliations, she also volunteers her time to teach retirement planning seminars and to give talks providing general financial planning education. Deborah is not compensated for these seminars. Item 5 – Additional Compensation Deborah Goodman has additional business activities that are detailed in Item 4 above. Item 6 – Supervision Deborah Goodman serves as the President and Chief Compliance Officer of Goodman Advisory Group. She can be reached at (781) 559-0320. Goodman Advisory Group has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting their fiduciary obligations to Clients of Goodman Advisory Group. Further, Goodman Advisory Group is subject to regulatory oversight by various agencies. These agencies require registration by Goodman Advisory Group and its Supervised Persons. As a registered entity, Goodman Advisory Group is subject to examinations by regulators, which may be announced or unannounced. Goodman Advisory Group is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Page 25 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 1 – Cover Page Form ADV Part 2B – Brochure Supplement for Joseph P. Rofino, CFA Director of Research Effective: May 5, 2025 This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Joseph P. Rofino, CFA (CRD# 6057255) in addition to the information contained in the Goodman Advisory Group, LLC (“Goodman Advisory Group” or the “Advisor”, CRD# 285637) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the Goodman Advisory Group Disclosure Brochure or this Brochure Supplement, please contact us at (781) 559-0320. Additional information about Mr. Rofino 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# 6057255. Page 26 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 2 – Educational Background and Business Experience Joseph P. Rofino, CFA, born in 1981, is dedicated to advising Clients of Goodman Advisory Group as Director of Research. Joe earned a Masters in Business Administration from the University of Massachusetts in 2010 and a Bachelor of Science in Marketing Communication from Emerson College in 2003. Additional information regarding Mr. Rofino’s employment history is included below. Employment History: Director of Research, Goodman Advisory Group, LLC Registered Representative, LPL Financial LLC Director of Research, LPL Financial LLC d/b/a Goodman Advisory Group Institutional Consulting Analyst, Morgan Stanley Smith Barney LLC Senior Managed Accounts Specialist, Trading, Eaton Vance Corp 10/2016 to Present 05/2016 to Present 03/2016 to 10/2016 04/2012 to 03/2016 03/2004 to 04/2012 Chartered Financial Analyst (“CFA”) The Chartered Financial Analyst (“CFA”) charter is a professional designation established in 1962 and awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour examinations over two to four years. The three levels of the CFA Program test a wide range of investment topics, including ethical and professional standards, fixed-income analysis, alternative and derivative investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at least four years of acceptable professional experience in the investment decision-making process and must commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. CFA(R) (is a trademark owned by CFA Institute. Item 3 – Disciplinary Information There are no legal, civil or disciplinary events to disclose regarding Mr. Rofino. Mr. Rofino 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. Rofino. 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 a r b i t r a t i o n 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. Rofino. However, we do encourage you to independently view the background of Mr. Rofino on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6057255. Item 4 – Other Business Activities Broker-Dealer Affiliation Mr. Rofino is also a registered representative of LPL Financial LLC (“LPL Financial”). In Mr. Rofino’s separate capacity as a registered representative, Mr. Rofino will typically receive commissions for the implementation of recommendations for commissionable transactions. Clients are not obligated to implement any recommendation provided by Mr. Rofino. Neither the Advisor nor Mr. Rofino will earn ongoing investment advisory fees in connection with any products or services implemented in Mr. Rofino’s separate capacity as a registered representative. Item 5 – Additional Compensation Mr. Rofino has additional business activities that are detailed in Item 4 above. Page 27 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Item 6 – Supervision Mr. Rofino serves as Director of Research of Goodman Advisory Group and is supervised by Deborah Goodman, the Chief Compliance Officer. Ms. Goodman can be reached at (781) 559-0320. Goodman Advisory Group has implemented a Code of Ethics and internal compliance that guide each Supervised Person in meeting their fiduciary obligations to Clients of Goodman Advisory Group. Further, Goodman Advisory Group is subject to regulatory oversight by various agencies. These agencies require registration by Goodman Advisory Group and its Supervised Persons. As a registered entity, Goodman Advisory Group is subject to examinations by regulators, which may be announced or unannounced. Goodman Advisory Group is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor. Page 28 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com Privacy Policy Effective Date: May 5, 2025 Our Commitment to You Goodman Advisory Group, LLC (“Goodman Advisory Group” or the “Advisor”) is committed to safeguarding the use of personal information of our Client’s (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. Goodman Advisory Group (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Goodman Advisory Group does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? 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 Account applications and forms Other advisory agreements and legal documents Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Page 29 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com 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 share information with technology vendors and third-party service providers to manage and support operations and regulatory compliance (such as administrators, brokers, custodians, regulators, credit agencies, consultants and 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 Goodman Advisory Group does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Goodman Advisory Group or the client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. 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 Goodman Advisory Group does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. State-specific Regulations Massachusetts In response to a Massachusetts law, clients must “opt-in” to share non-public personal information with non-affiliated third parties before any personal information is disclosed. We may disclose non-public personal information to other financial institutions with whom we have joint business arrangements for proper business purposes in connection with the management or servicing of your account. 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) 559-0320. Page 30 Goodman Advisory Group, LLC 160 Gould St., Suite 102, Needham, MA 02494 Phone: (781) 559-0320 www.goodmanadvisorygroup.com