Overview

Headquarters
St Petersburg, FL
Total Firm Assets
$139 million
Average High-Net-Worth Client Portfolio Size
$3.1 million

Fee Structure

Primary Fee Schedule (HOWLAND 06_18_2026_ADV_PART_2_BROCHURE)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.20%
$1,000,001 $2,000,000 1.08%
$2,000,001 $3,000,000 0.96%
$3,000,001 $4,000,000 0.84%
$4,000,001 $5,000,000 0.72%
$5,000,001 and above 0.60%

Minimum Annual Fee: $3,000

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,000 1.20%
$5 million $48,000 0.96%
$10 million $78,000 0.78%
$50 million $318,000 0.64%
$100 million $618,000 0.62%

Clients

High-Net-Worth Share of Firm Assets
95.01%
Number of High-Net-Worth Clients
42
Total Client Accounts
67
Discretionary Accounts
67

Services Offered

Services: Portfolio Management for Individuals

Regulatory Filings

SEC CRD Number
106963

Primary Brochure: HOWLAND 06_18_2026_ADV_PART_2_BROCHURE (2026-06-18)

View Document Text
ITEM 1 – COVER PAGE Firm Disclosure (Part 2A of Form ADV) 10261 4 th Street North Saint Petersburg, Florida 337 16 (813) 333 -2900 | (727) 491-7777 www.InvestHowland.com If you have any questions about the contents of - Form ADV Part 2A brochure provides information about the qualifications and business practices of Howland and Associates, LLC. the brochure, please contact Robert Howland of Howland and Associates, LLC at (813) 333 2900 or Rob@InvestHowland.com . The information in th e Firm Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. registered investment adviser. Registration as an Howland and Associates, LLC is a investment adviser with the SEC or the State of Florida does not imply any level of skill or training. O ral and written communications from an investment adviser may be used to evaluate , hire, or retain an investment adviser. LLC is available on the SEC’s website Additional information about Howland and Associates, at www.adviserinfo.sec.gov . The SEC’s website also provides information about any persons affiliated with Howland and Associates , LLC who are registered, or are required to be , LLC . registered, as investment adviser representatives of Howland and Associates regarding securities The Firm Brochure will be updated and amended to reflect changes regulations , routine annual updates , and business practices. An annual disclosure or summary of changes to th e Firm Brochure will be provided to each advisory client . ITEM 2 – MATERIAL CHANGES The brochure updates the version dated March 24, 2026 . • Howland and Associ ates has reached AUM greater than $110 million and is in the process of moving the registration from the state of Florida to the Sec urities and Exchange Com mission. 2 ITEM 3 – TABLE OF CONTENTS Item 1 – Cover Page ......................................................................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................................................................. 2 Item 3 -Table of Contents .............................................................................................................................................................................. 3 Item 4 – Advisory Business ............................................................................................................................................................................ 4 Item 5 – Fees and Compensation ................................................................................................................................................................ 5 Item 6 – Performance-Based Fees and Side-By-Side Management .............................................................................................. 8 Item 7 – Types of Clients ................................................................................................................................................................................ 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................................................ 8 Item 9 – Disciplinary Information ............................................................................................................................................................... 10 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................................................... 10 Item 11 – Code of Ethics .............................................................................................................................................................................. 10 Item 12 – Brokerage Practices ................................................................................................................................................................... 11 Item 13 – Review of Accounts .................................................................................................................................................................... 12 Item 14 – Client Referrals and Other Compensation ......................................................................................................................... 12 Item 15 – Custody ........................................................................................................................................................................................... 12 Item 16 – Investment Discretion ................................................................................................................................................................ 13 Item 17 – Voting Client Securities ............................................................................................................................................................. 13 Item 18 – Financial Information .................................................................................................................................................................. 13 Item 19 – Additional Items for State-Registered Entities ................................................................................................................. 14 Item 1- Cover Page......................................................................................................................................................................................... 15 Item 2 - Educational Background and Business Experience ........................................................................................................... 15 Item 3 - Disciplinary Information ............................................................................................................................................................... 17 Item 4 - Other Business Activities ............................................................................................................................................................. 17 Item 5 - Additional Compensation ............................................................................................................................................................ 18 Item 6 - Supervision ....................................................................................................................................................................................... 18 Item 7 – Requirements for State-Registered Advisors ..................................................................................................................... 18 3 ITEM 4 – ADVISORY BUSINESS Howland and Associates , LLC is a registered investment advisor specializing in the management of separate , tailored investment portfolios comprised of publicly traded companies. Howland and Associates , LLC has been providing investment advisory services since its founding in 1992 and is 100% owned by D. S. Howland, CFA . As of March 31, 2026, Howland and Associates , LLC managed $ 138,704 ,932.00 in client assets on a discretionary basis. Howland and Associates , LLC neither manages nondiscretionary accounts nor engages in nondiscretionary client relationships. Investment p ortfolios are made and managed by Howland and Associates , LLC to serve families with individual investment situations , employment considerations , or risk reduction concerns . Howland and Associates , LLC encourages clients to seek the benefits of qualified advice from a CERTIFIED FINANCIAL PLANNER ™ professional or Chartered Financial Analyst . Howland and Associates , LLC provides investment management advice for assets under management . Each client’s particular situation determine s the need and investment style. To help guide clients in understanding risk and time horizons, Howland and Associates , LLC has designed seven investment objectives : (1) Opportunistic Growth , (2) Core , (3) Defensive , (4) Triton , (5) Heritage , (6) Howland and Associates Repository Program , (7) 529 . Howland and Associates also helps manage 529 educational plans. Portfolios may deviate from investment style model s for periods of time to serve specific purpose s, such as personal client concerns, tax efficiency, or volatile market conditions. Howland and Associates , LLC advises clients on the management of 529 plan s and helps families consider the larger implications of family wealth management with educational savings. firm Howland and Associates, LLC has an on-going relationship with clients to manage portfolios and investment assets . In most situations, a separate account is set up at a brokerage where Howland and Associates, LLC has the limited power to trade investments and process fees. 4 -income securities, ommend 529 plans may also hold age- Client investment accounts may hold publicly traded equity and fixed exchange -traded funds, mutual funds, money market instruments, and other securities consistent with client objectives and Firm policies. The Firm does not routinely rec or manage derivatives, futures, or cryptocurrency strategies. based portfolios or specific investments designed or offered by the custodian for 529 plans. non- to Upon mutual agreement, the manager and client may agree on occasion to retain a managed asset in a client’s account that is outside the investment strategy . Non-managed and may alter portfolio performance. A assets will be detailed on account statements request to include non-managed assets in a client account must be provided in writing Howland and Associates, LLC. Supervision is not provided for non-managed assets. Howland and Associates, LLC does not offer annuities or life insurance products . Clients should note that investment strategies involve risk of loss and that past performance is not indicative of future results. The Firm may assist clients in identifying and submitting claims related to securities class action settlements. In connection with this service, the Firm may provide relevant account and transaction information to third -party claims administrators or lega l service providers for the purpose of filing and processing such claims. The Firm does not receive compensation for this service unless otherwise disclosed. ITEM 5 – FEES AND COMPENSATION f each month . Monthly Howland and Associates, LLC receives compensation for portfolio management services . A monthly management fee is charged, based on a percentage of the market value of assets under management at the close of trading on the last business day o fees are rounded up or down to the nearest dollar . Howland and Associates, LLC has the client account s. limited power to deduct the monthly management fee in advance from 529 plan monthly fees may be bundled, invoiced directly or paid with an ACH transfer. Howland and Associates, LLC has the authority to deduct advisory fees directly from client accounts, which is considered custody under SEC rules. The Firm complies with applicable custody requirements, including the use of qualified custodians and delivery of account statements. 5 On occasion, Howland and Associates, LLC may agree with the client to process and receive fees from a non -managed source of funds . new client will then be The initial fee for all accounts is waived for the first partial month. A billed for the following month based on the value of the assets on the last day of the first month. 529 custodia n The monthly minimum fee for client relationships is outlined in the Client Agreement. Management fees are exclusive of brokerage commissions, transaction fees, or product fees and other related costs and expenses which shall be incurred by the client. With discretion, and in limited situations, Howland and Associates, LLC may negotiate specific circumstances and management fees. Family account values may also be bundled to reduce advisory fees. Accounts may be terminated by the client or Howland and Associates, LLC with written notice. The p repaid monthly fee at Howland and Associates, LLC will be returned for terminated or closed accounts upon written request from the client . Fees returned will be calculated on the date of account closure notice. Howland and Associates, LLC may negotiate limited fees for the time required to process reports and provide information to former clients who wish to obtain records or reports on closed accounts. -lot Clients may incur additional fees and charges imposed by custodians, brokers, or other third parties, which may include custodial fees, transaction fees, sales charge fees, odd differentials fees, transfer -taxes fees, wire transfer fees, and electronic fund fees. Custodian s charge separate fees for 529 Plans . Howland and Associates, LL C does not receive a portion of the custodial fee s for the discretionary management of the 529 Plan held at a custodian . Exchange traded funds (ETFs) and mutual funds , age-based portfolios and other investment products offered by custodians may impose additional service fees, expenses, or transaction costs. Howland and Associates, LLC shall not receive any portion of ET F or mutual fund commissions, fees, or costs. Howland and Associates, LLC charges investment management fees on a declining tiered fee schedule as a percentage of the client’s total assets under management. The maximum annual investment management fee is 1.2%. The annual investment management fee for the 6 Howland and Associates, LLC Repository Program (HARP) is 0.12%. Management fees are billed monthly. Monthly Fee INVESTMENT MANAGEMENT FEE SCHEDULE $250 Monthly Minimum Fee Tiered monthly fee on assets valued less than $1,000,000 0.10% Tiered monthly fee on the 2nd Million $1,000,000 - $1,999,999.99 0.09% Tiered monthly fee on the 3 rd Million $2,000,000 - $2,999,999.99 0.08% Tiered monthly fee on the 4 th Million $3,000,000 - $3,999,999.99 0.07% Tiered monthly fee on the 5th Million $4,000,000 - $4,999,999.99 0.06% Tiered monthly fee on assets valued greater than $5,000,000 + 0.05% Monthly Fee Howland and Associates, LLC Repository Program (HARP) Accounts ($25 monthly minimum fee) 0.01% 529 PLAN INVESTMENT MANAGEMENT FEE SCHEDULE Monthly Fee Tiered monthly fee on assets valued less than $1,000,000 0.05% 7 Tiered monthly fee on the 2 nd Million $1,000,000 - $1,999,999.99 0.045% Tiered monthly fee on the 3 rd Million $2,000,000 - $2,999,999.99 0.04% Tiered monthly fee on the 4 th Million $3,000,000 - $3,999,999.99 0.035% Tiered monthly fee on the 5 th Million $4,000,000 - $4,999,999.99 0.03% Tiered monthly fee on assets valued greater than $5,000,000+ 0.025% - A report detailing all account fees charged by Howland and Associates, LLC is available for current clients at any time, without charge, by contacting Robert Howland at (813) 333 2900 or at Rob@InvestHowland.com . ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Howland and Associates, LLC does not charge performance -based fees , fees based on capital gain s, or fees based on capital appreciation of a client’s assets. ITEM 7 – TYPES OF CLIENTS Howland and Associates, LLC generally seeks to manage client portfolios with investable assets of approximately $500,000 or more; however, the Firm does not impose a strict minimum account size and may accept smaller accounts at its discretion. Portfolio management services are designed for families, high-net-worth individuals, trusts, estates, Individual Retiremen t Arrangements (IRAs), corporate pension and profit -sharing plans, 529 plans, and foundations. require alternate methods of All accounts are retained or accepted at the sole discretion of Howland and Associates, LLC. Howland and Associates, LLC has no conditions or minimum account size for establishing or maintaining an investment advisory account. Small portfolios may management and allocation. 8 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Howland and Associates, LLC creates investment portfolios to meet the needs of clients . Each portfolio reflects a unique set of circumstance s, time horizon, risk acceptance, and other holdings. Howland and Associates , LLC employs a range of fundamental investment strategies to meet portfolio requirements. Stocks purchased for a sset appreciation are tracked with analysis of relative price, earnings, and expectations of growth. Positions held for a sset protection are analyzed for risks, earnings, reliability, and market conditions. Howland and Associates , LLC modifies portfolio objectives to help families and managers frame how money may be invested and evaluate portfolio perfo rmance. Portfolio models are positioned around the needs of families, values of individuals, and the stages of life. Assets in the Howland and Associates, LLC Opportunistic Growth strategy objective are oriented towards companies with strong growth expectations for long -term investment. The Opportunistic Growth strategy was established in 1992. The Defensive strategy objective serves near-term needs and is tilted towards companies with robust earnings. The Core strategy objective is composed for families who have complex circumstances. Howland and Associates , LLC will use discretion and understanding to blend the best investment elements for the family’s unique situation. The Core Family strategy relies on close communication and mutual understanding. The Triton strategy objective analyzes and invests in specific companies seeking the greatest opportunity to improve the environment and provide a return to clients . a The Heritage strategy objective at Howland and Associates, LLC is designed for families who have greater ambition to preserve . Investments in the Heritage strategy are lon g term. Howland and Associates applies broad investment themes to find companies for families who want or need to invest for the next generation. , The Howland and Associates Repository Program (HARP) is designed to invest cash on a provisional short-term basis upon client request . Howland and Associates , LLC will use cash, cash alternatives, Treasury bonds, corporate bonds, mutual funds, money market funds, commercial paper, and exchange traded funds for potentially greater return s than other cash alternatives . The management fee for the HARP program is lower than the standard investment management fee at Howland and Associates , LLC . Howland and As sociates , LLC applies higher fee s on other investment management account s. 9 Howland and Associates, LLC manages 529 plans in reference to family situations, beneficiary needs, appropriateness, tax considerations, other educational assets, contributions, and account owners . a guide for portfolio allocation and , LLC will create a Howland and Associates, LLC uses various indexes as perfo rmance. Howland and Associates , LLC currently uses the S&P 500® Equal Weight Index as a basic index. In the past, Howland and Associates , LLC has used other indexes for portfolio allocation and evaluation. Upon request or in special situations, Howland and Associates custom index for a family or a portfolio. Howland and Associates, LLC will work with each client to understand and manage risk of loss, risk aversion, risk capacity (ab ility to take risk), risk composure (appetite), risk need (need to take risk to reach goals), risk perception (subjective), risk preference (emotion), and risk tolerance associated with their indiv idual investments. Risk profiles and risks vary across time and asset class. Howland and Associates, LLC manages investment risk through portfolio diversification, disciplined investment processes, and adherence to internal trading, best execution, and risk management lio policies. Additional information regarding trading practices, execution quality, and portfo oversight is available upon request and is addressed in the Firm’s Compliance Policies and Procedures Manual. ITEM 9 – DISCIPLINARY INFORMATION Registered investment advisers are required to disclose all material facts regarding any legal or material disciplinary events that would be relevant to an evaluation of the advisory business or the integrity of its management. Howland and Associates, LLC has no information applicable to this Item. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Howland and Associates, LLC is an independent firm. Howland and Associates, LLC has no affiliat ions. ITEM 11 – CODE OF ETHICS and uphold a fiduciary duty. Howland and Associates, LLC Howland and Associates, LLC employs a Code of Ethics to ensure a high standard of business conduct , reduce conflicts of interest, frequently reviews, amends, and acknowledges the Code of Ethics to maintain that the policies are reasonably designed to always protect the client’s privacy and interests , as well as demonstrate the commitment to the fiduciary duties of honesty and integrity. All Supervised Persons are required to 1 0 acknowledge and certify compliance with the Firm’s Code of Ethics upon hire and annually thereafter. onfidentiality requirements , restrictions on significant The provisions of the Code of Ethics include c gifts or business entertainment items, and employee securities trading controls . Employee trading is monitored for compliance with applicable restrictions and securities law. Employee trading activities will not interfere with making decisions in the best interest Employees shall not front -run client accounts or improperly benefit from trades in s of clients. client accounts. Employee s at Howland and Associates, LLC , along with clients, participate in equity and ETF block trades. Employees and clients both receive an identical per -share price on equity block orders . Howland and Associates, LLC does not participate in principal , client, or agency cross securities transactions. Howland and Associates, LLC is neither affiliated with nor registered as a broker -dealer. is available upon request by contacting Robert Howland by phone at (813) 333 - The Code of Ethics 2900 or at Rob@InvestHowland.com . ITEM 12 – BROKERAGE PRACTICES Howland and Associates, LLC uses third-party brokerage firms for the custody , security, and clearing of assets. Howland and Associates, LLC holds a limited power of attorney on individual client accounts at brokerage firms to make trades in the client’s account and may allocate shares of a block trade to a client account. or Howland and Associates, LLC has limited business relationships with brokerage firms and custodians of assets . Howland and Associates, LLC does not receive compensation from brokerage firms custodians . The client or manager may choose any custodian or brokerage firm with an agreement between all parties . Client accounts are balanced and reconciled with the third -party custodian daily. Howland and Associates, LLC does not participate in soft dollar transactions. Soft dollar transactions are amounts that money managers pay out of their clients' accounts to a brokerage firm to cover the cost of research or other services the firm provides. Howland and Associates, LLC seeks best execution on a qualitative basis, considering factors such as price, execution capability, reliability, and service quality, consistent with its Trading Best Practices and Best Execution Policy. 1 1 ITEM 13 – REVIEW OF ACCOUNTS Howland and Associates reviews and manages Client accounts on an on-going basis to meet investment needs and objectives . Howland and Associates, LLC meets regularly with clients to discuss portfolio perfo rmance, allocation, and investment objectives. Investment managers use an individualized understanding of each client to determine individual investment mandates and nuanced portfolio models . The frequency of client review meetings may vary based on client preferences and market conditions. Howland and Associates, LLC provide s a monthly statement for each portfolio that helps the client review and understand their individualized investments . Statements from Howland and Associates may show portfolio allocation, benchmark performance, performance over specific time periods, and perfo rmance of individual holdings . Customized client reports are also available upon request. ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION Howland and Associates, LLC provides referral credits to existing clients who help to establish new relationships with friends and family members. Referring clients receive a credit in the amount equal to 100% of the first month management fee of the new r elationship. Howland and Associates, LLC uses testimonials from current clients in print and online marketing materials in accordance with the SEC Marketing Rule. No cash or non -cash compensation is provided for testimonials, and all required disclosures are included. Howland and Associates, LLC uses third-party ratings or rankings in marketing communications. Ratings are provided by independent organizations based on specific, published criteria. C ompensation is paid for third -party ratings. ITEM 15 – CUSTODY Howland and Associates, LLC uses third -party brokerage house services to retain all client assets Howland and Associates, LLC does not have physical custody of client assets and does not serve as trustee, except as disclosed. Howland and Associates, LLC has authorization to collect fees from client accounts. The ability to collect fees from client accounts is considered constructive custody. 1 2 and tax documents are provided by brokerage custodians . Howland Official account statements and Associates, LLC will work with clients and brokerage custodians to explain, manage, and reconcile any account discrepancies. 529 plans may be hel d at various custodians. Custodian security values are used for the purposes of performance measurement and fee calculations at Howland and Associates, LLC . ITEM 16 – INVESTMENT DISCRETION Howland and Associates, LLC manages client portfolios with complete discretionary authority. Portfolios are managed in accordance with the portfolio objective as defined in the Client Agreement . Clients may change investment objectives at any time. In limited circumstances, Howland and Associates, LLC and the c lient may agree to specific limitations and security selection . For example, a client may specify in writing that tobacco company investments should not be purchased in a specific portfolio. Clients shall notify Howland and Associates, LLC of any changes to tax status or other material factors that potentially impact investment time horizon or risk considerations. ITEM 17 – VOTING CLIENT SECURITIES are available The proxy voting record, policies, and procedures of Howland and Associates, LLC upon request. Client s may retain proxy voting authority. ITEM 18 – FINANCIAL INFORMATION Howland and Associates, LLC has not been subject to any bankruptcy proceedings, nor does it have any financial commitment s that impair its ability to meet the contractual and fiduciary commitments made to its clients. Registered investment advisers are required in this item to provide certain financial information or disclosures about the financial condition of Howland and Associates, LLC. Howland and Associates , LLC was a recipient of the CARES act small business loan in April of 2020 during the global outbreak of COVID -19. At the time of application, t he CARES act loan was an opportunity for Howland and Associates, LLC to safeguard against economic uncertainty and adverse business conditions. 1 3 ITEM 19 – ADDITIONAL ITEMS FOR STATE-REGISTERED ENTITIES A. Executive officers and management persons, their formal education and business background : D. S. Howland, CFA, earned the Chartered Financial Analyst ®, designation in 1985. She has been engaged in investment management since graduating from the University of South Florida in 1977. Her degree is a B.A. in Business with a Finance major. She a member of the Chartered is Past President of Chartered Financial Analysts of Tampa Bay; Financial Analyst Institute (CFAI) since 1977. She was formerly Senior Vice President at Eickhoff, Pieper & Willoughby, Inc. (now Sabal Trust), Tampa, Florida, was formerly employed by SunTrust Bank’s Trust Division, Tampa, Flor ida, and was a Securities Analyst at Roulston & Co., Cleveland, Ohio. B. Principal, Robert C. Howland, CFP , became a CERTIFIED FINANCIAL PLANNE R®, in 2019. Robert has completed a Certificate in Financial Planning program of study from the University of Miami. Robert has worked in the finance industry since 2007. He holds a B.A. degree in History and B.A. degree in Media from Southern Methodist University . C. Ross Thomas, MS, holds a Master of Science in Science Information Technology from the University of Liverpool and a B.S. in Computer Science from Florida State University . D. Alex Tavares , MFA, holds a Master of Fine Arts from Antioch University Los Angeles and a B.A. from Florida State University. E. There is no business in which Howland and Associates, LLC is actively engaged other than investment advice. F. Howland and Associates, LLC does not offer performance -based fees. G. Howland and Associates, LLC and its management individuals have not been involved in any of the events . H. Howland and its management individuals are not involved in any other relationship or arrangement with any issuer of securities that is not listed in Item 10.C. of Part 2A. 1 4 Form ADV Part 2B ITEM 1 – COVER PAGE D. S. Howland, CFA President/ Investment Adviser Representative Howland and Associates, LLC 10261 4th Street Nor th Saint Petersburg, Florida 33716 (813) 333-2900 | (727) 491-7777 www.InvestHowland.com Form ADV Part 2B Brochure Supplement the Howland and e supplement. The Brochure Supplement provides information about D. S. Howland, CFA for the Howland and Associates, LLC client brochure. Client s should have received a copy of the brochure. Please contact Robert Howland , CFP® at Rob@investHowland.com if you did not receive Associates , LLC client brochure or if you have any questions about the contents of th Additional information about D. S. Howland, CFA is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2 – EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Doris Sheppard Howland, CFA ® #8324 Year of Birth: 1950 Education: University of South Florida, BA – Finance, 1977 Chartered Financial Analyst, #8324, 1985 Business background: Security Analyst and Trader , Roulston & Co., Inc. Cleveland, OH, 1976 Trust Investment Department, Flagship Bank of Tampa , Tampa, FL, 1977 – 1979 1 5 Vice President -Portfolio Manager, Eickhoff, Pieper & Willoughby, Inc., Tampa, FL 1983 – 1992) Portfolio Manager, Howland and Associates, LLC Saint Petersburg , FL 1992 – present Robert C. Howland, CFP® #161094 Year of Birth: 1980 Education: Southern Methodist University , BA – History, 2004 Southern Methodist University, BA – Film & Media , 2004 University of Miami, Certificate in Financial Planning , 2018 Certified Financial Planner ®, # 161094 Business Background: Journalist, Texas Cable News (Belo Corp) , Dallas, Texas, 2004 Personal Assistant – General Electric / Universal Studios, Hollywood, CA , 2004 – 2007 Chief Compliance Officer /Principal – Howland and Associates, LLC Saint Petersburg, FL, 2007 – present Ross M. Thomas Year of Birth: 1981 Education: Florida State University, BA – Management of Information Systems , 2004 University of Liverpool, MS – Science Information Technology , 2011 Business Background: Senior Technical Specialist, Janus Digital Displays 1 6 Saint Petersburg, Florida, 2006 – 2008 Digital Network Administrator, AccentHealth LLC Tampa, Florida, 2010 – 2017 IT/DevOps Administrator, Rapid Web Services/The SSL Store Saint Petersburg, Florida, 2018 – 2020 Investment Advisor Representative – Howland and Associates, LLC Saint Petersburg, FL, 2020 – present Alex L. Tavares Year of Birth: 1981 Education: Florida State University, BA – English, 2003 Antioch University Los Angeles , MFA – English, 2006 Business Background: Professor of English, Hillsborough Community College Tampa , Florida, 2007 – Present Investment Advisor Representative – Howland and Associates , LLC Saint Petersburg, Florida, 20 23 – Present ITEM 3 – DISCIPLINARY INFORMATION Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of each supervised person providing investment advice. No information is applicable to this Item. ITEM 4 – OTHER BUSINESS ACTIVITIES supervised person’s other financial Registered investment advisers are required to disclose all facts regarding material conflicts that may impact a relationship between the advisory business and the industry activities. No information is applicable to this Item. 1 7 ITEM 5 – ADDITIONAL COMPENSATION Registered investment advisers are required to disclose all facts regarding someone who is not a client and provides an economic benefit to the supervised person for providing advisory services. No information is applicable to this Item. ITEM 6 – SUPERVISION D. S. Howland, CFA is the owner of the firm, as well as Chief Investment Officer and Portfolio Manager. She makes all decisions regarding portfolio management in a manner consistent with applicable laws, SEC guidelines, and regulations . ITEM 7 – REQUIREMENTS FOR STATE-REGISTERED ADVISORS A. Howland and its management person have not been involved in any of the events. B. No supervised person associated with Howland and Associates, LLC has been the subject of a bankruptcy petition. 1 8 Addendum Professional Designations – Minimum Qualifications Required for Each Designation CFA ® - Chartered Financial Analyst ® Issued by: CFA Institute Prerequisites/Experience Required: Candidate must meet the following requirements: Undergraduate degree or higher and 4 years of professional experience involving investment decision -making Educational Requirements: Self -study program (250 hours of study for each of the 3 levels) Examination Type: 3 course exams , offered annually or semi -annually Continuing Education/Experience Requirements: None required but highly recommended CFP ® – C ERTIFIED FINANCIAL PLANNER ™ Issued by: Certified Financial Planner Board of Standards, Inc. Prerequisites/Experience Required: Candidate must meet the following requirements: A bachelor’s degree (or higher) from an accredited college or university, and 3 years of full - time personal financial planning experience Educational Requirements: Candidate must complete a CFP -board registered program , or hold one of the following: • CPA • ChFC • Chartered Life Underwriter (CLU) • CFA ® • Ph.D. in business or economics • Doctor of Business Administration • Attorney's License Examination Type: CFP Certification Examination Continuing Education/Experience Requirements: 30 hours every 2 years 1 9

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