View Document Text
M3 Advisory Group, LLC
Form ADV Part 2 – Disclosure Brochure
Effective: October 27, 2025
This Form ADV 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of M3 Advisory Group, LLC (“M3” or the “Advisor”). If you have any questions about the content of this Disclosure
Brochure, please contact the Advisor at (781) 371-2670.
M3 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 M3 to assist you in determining whether to retain the Advisor.
Additional information about M3 and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 156208.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203
Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.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 the Advisory
Persons of M3. For convenience, the Advisor has combined these documents into a single disclosure document.
M3 believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. M3 encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the
Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing
on January 30th, 2025:
• The Advisor no longer votes proxy on behalf of Clients. Please see item 17 for additional information.
• The Advisor has added Independent Managers as part of its service offering, and has updated Items 4,
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or this summary of Material Changes shall be provided to you annually or if a material
change is made.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 156208. You
may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (781) 371-2670.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 2 -
Item 3 – Table of Contents
ITEM 1 - COVER ................................................................................................................................................................. 1
ITEM 2 - MATERIAL CHANGES ...................................................................................................................................... 2
ITEM 4 – ADVISORY SERVICES ..................................................................................................................................... 4
ITEM 5 – FEES AND COMPENSATION ......................................................................................................................... 8
ITEM 6 – PERFORMANCE-BASED FEES ...................................................................................................................... 9
ITEM 7 – TYPES OF CLIENTS ....................................................................................................................................... 10
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................. 10
ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................................. 11
ITEM 10 – OTHER FINANCIAL ACTIVITIES AND AFFILIATIONS ...................................................................... 11
ITEM 11 – CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING
.............................................................................................................................................................................................. 12
ITEM 12 – BROKERAGE PRACTICES ......................................................................................................................... 12
ITEM 13 – REVIEW OF ACCOUNTS ............................................................................................................................ 13
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ........................................................................ 14
ITEM 15 – CUSTODY ...................................................................................................................................................... 14
ITEM 16 – INVESTMENT DISCRETION ..................................................................................................................... 14
ITEM 17 – VOTING CLIENT SECURITIES .................................................................................................................. 14
ITEM 18 – FINANCIAL INFORMATION ..................................................................................................................... 15
BROCHURE SUPPLEMENTS (ADV2B) ....................................................................................................................... 17
PRIVACY POLICY ............................................................................................................................................................. 23
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 3 -
Item 4 – Advisory Services
A. Firm Information
M3 Advisory Group, LLC (“M3” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”) under the laws of
Massachusetts. M3 was founded in January 2011 and is owned by John D. Jeffries (Managing Director). This
Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by M3.
For additional information on M3 or this Disclosure Brochure, please contact Nicholas Jeffries, Chief Compliance
Officer.
B. Advisory Services Offered
M3 offers investment advisory services to individuals, high net worth individuals, trust, estates, retirement plans,
charitable organizations and corporations (each referred to as a “Client”).
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. M3’s fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Investment Management Services
M3 provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and consulting
services. M3 works with its Clients to identify their investment goals and objectives as well as their risk tolerance
and financial situation in order to create a portfolio strategy. M3 will then construct a portfolio, consisting of
domestic and international equity securities, fixed income securities, exchange-traded funds (“ETFs”) and/or
mutual funds to achieve the Client’s investment goals. The Advisor may also utilize other investments as
necessary to meet the needs of its Clients. The Advisor may retain other types of investments from the Client’s
legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as identified
between the Advisor and the Client.
M3’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. M3
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 the acceptance by the Advisor.
M3 evaluates and selects investments for inclusion in Client portfolios only after applying their internal due
diligence process, which may include an evaluation of the style consistency, management fees, overall expense
ratios, fund performance, manager tenure, and several other factors of each investment. M3 may recommend, on
occasion, redistributing investment allocations to diversify the portfolio in an effort to reduce risk and increase
performance. M3 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. M3 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, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will M3 accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within their designated account[s] at the
Custodian, pursuant to the advisory agreement, please see Item 12 – Brokerage Practices.
M3 Asset Allocation Portfolios – M3 will typically invest Client accounts in the M3 Asset Allocation Portfolios. The
methodology employed by M3 utilizes risk-controlling features which manage portfolios through the application of
Riskalyze guidelines that govern the investment management of the portfolio. M3’s investment models are
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 4 -
based on the concept of “Using Disciplined Riskalyze Diversification to Build and Preserve Our Client’s Wealth.”
In our experience the application of such rules to the management of a portfolio allows for “active” management
of a portfolio while also attempting to control risk. M3’s management process is designed to limit the affect by
subjective and emotional human decision-making, which can lead to costly investment mistakes.
The M3 Asset Allocation Portfolios consists of The Riskalyze / Morningstar asset allocation models: Model
portfolios are constructed to reflect the clients identified risk tolerance.
• Conservative
• Moderate Conservative
• Moderate
• Moderate Aggressive
• Aggressive
The offering of customized models allow for the selection of the proper risk tolerance for each client or account.
M3 derives its performance through the act of attempting to control risk, unlike most managers who attempt to gain
an advantage by assuming risk. Each portfolio is designed to control risk, regardless of the risk tolerance of the
investor, utilizing the following metrics to accomplish this goal:
Individual stock diversification
• Precision asset allocation
• Elimination of emotion
•
• Rebalancing
• Value screening
• Active/passive diversification
Each of the asset allocation models utilizes Core Equity Holdings of ETF and Stocks as its active management
component. Core Equity relies on six independent strategies in the form of defined asset portfolios to select
approximately 160 underlying stocks that comprise the active portion of each of the portfolios. ETFs are then
utilized to round out the asset classes to adhere to our asset allocation models. Rebalancing occurs every six
months, serving the dual purpose of refreshing the active management portion of the portfolio and realigning the
portfolio with our asset allocation strategy. Both purposes also attempt to control risk.
M3 works with investment product sponsors and the M3 portfolios incorporate the following independent partners
into their investment process:
Index IQ
• Fidelity Institutional Wealth / Bond Trading Desk
• Blackrock/iShares
• State Street Global Advisors
• PowerShares
• Vanguard
• RevenueShares
•
• Deutsche Bank
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 5 -
Use of Independent Managers - M3 Advisory will recommend that Clients utilize one or more unaffiliated investment
managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment
portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and
due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment
objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent
Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Financial Planning and Consulting Services
M3 will typically provide a variety of financial planning services to Clients, either as a component of investment
management services or pursuant to a written financial planning or consulting agreement. Services are offered in
several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services will involve preparing a financial plan or rendering a financial
consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass
one or more areas of need, including, but not limited to investment planning, retirement planning, estate
planning, personal savings, education savings, insurance needs 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 begin or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs. M3 may also refer Clients to
an accountant, attorney or other 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 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.
Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing
relationship with the Advisor.
Retirement Plan Advisory Services
M3 provides advisory services to retirement plans (each a “Plan”) and the company sponsor (the “Plan
Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its
fiduciary obligations to the Plan. Each engagement is customized to the needs of the Plan and Plan Sponsor.
Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
Investment Oversight Services (ERISA 3(21))
• Ongoing Investment Recommendation and Assistance
Certain of these services are provided by M3 serving in the capacity as a fiduciary under the Employee
Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2),
the Plan Sponsor is provided with a written description of M3’s fiduciary status, the specific services to be
rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging M3 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 – M3, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 6 -
• Asset Allocation – M3 will use the Riskalyze Platform to develop a strategic asset allocation targeted to
meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
These strategic asset allocation weightings will also be monitored by the Advisor as part of its investment
management process.
• Portfolio Construction – M3 will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
•
Investment Management and Supervision – M3 will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
M3 does not place Client assets into a wrap fee program. Investment management services are provided directly
by M3.
E. Assets Under Management
As of December 31, 2024, M3 manages approximately $310,000,000 in Client assets, $280,000,000 of which are
managed on a discretionary basis and $30,000,000 of which are managed on a non-discretionary basis. Clients
may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client shall sign one or more advisory agreements that detail the responsibilities of M3 and the
Client.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid monthly (the “billing period”) at the end of each billing period, pursuant to the
terms of the investment advisory agreement. Investment advisory fees are based on the market value of assets
under management at the end of each billing period. Fixed Investment advisory fees range from 0.50% to 2.00%,
depending on the size and complexity of the Client relationship. Relationships with multiple goals and objectives
and other complexities may be charged a higher fee. The Advisor may also charge its annual investment advisory
fee according to the tiered fee schedule below:
Assets Under Management ($)
$0 to $4,999,999
$5,000,000 to $9,999,999
$10,000,000 and above
Annual Rate (%)
0.65%
0.35%
0.25%
Investment advisory fees in the first billing period of service are prorated to the inception date of the account[s] to
the end of the first billing period. Fees may be negotiable at the sole discretion of the Advisor. Certain legacy Clients
may have fees that are charged in advance or based on a different fee methodology. The Client’s fees will take into
consideration the aggregate assets under management with Advisor. All securities held in accounts managed by
M3 will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the
Advisor shall not receive any portion of these commissions, fees, and costs.
Use of Independent Managers - As noted in Item 4, the Advisor may implement all or a portion of a Client’s
investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor
does not earn any compensation from an Independent Manager. The Advisor will only earn its investment
advisory fee as described above. The total blended fee, including the Advisor’s fee and the Independent
Manager’s fee, will not exceed 2.00% annually.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 7 -
Financial Planning and Consulting Services
M3 occasionally offers financial planning or consulting services on an hourly basis at a rate ranging from $150 to
$350 per hour, based on a fixed fee per engagement. Fees may be negotiable based on the nature and complexity
of the services to be provided, the overall relationship with the Advisor, and the experience and billing rate of the
individual providing services. An estimate for total hours and costs will be determined prior to engaging for these
services. M3 also offers ongoing financial planning services for a fixed fee which can be charged monthly or
quarterly in arrears or as an annual fee ranging from $5,000 to $72,000 per year.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00%. Fees may be
negotiable depending on the size and complexity of the Plan.
B. Fee Billing
Investment Management Services
Investment advisory fees will be calculated by the Advisor and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted
from the Client’s account[s] at each billing period. The amount due is calculated by applying the monthly or
quarterly rate to the total assets under management with M3 at the end of the billing period. Clients will be provided
with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fees. 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 advisory fees to
be deducted by M3 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 and Consulting Services
Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s].
Ongoing financial planning fees are invoiced monthly or quarterly in arrears.
Retirement Plan Advisory Services
Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms
of the retirement plan advisory agreement.
Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Advisor and the Independent Manager
will each assume the responsibility for calculating and deducting their respective fees from the Client’s account[s]
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than M3, in connection with investment
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 Advisor's recommended Custodian does not charge securities transaction fees for
ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the
Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of
investments. The investment advisory fee charged by M3 is separate and distinct from these custody and execution
fees.
In addition, all fees paid to M3 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 may be able to invest in these products directly, without the services of M3, but would not
receive the services provided by M3 which are designed, among other things, to assist the Client in determining
which products or services are most appropriate to 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 M3 to fully understand the total
fees to be paid. Please see Item 12 – Brokerage Practices.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 8 -
D. Advance Payment of Fees and Termination
Investment Management Services
M3 is generally compensated for its investment management services after the billing period in which services are
rendered. Either party may 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 fees, if applicable. The
Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent.
Financial Planning and Consulting Services
M3 is compensated for its financial planning and consulting services upon completion of the engagement
deliverables. Either party may terminate the financial planning or consulting 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 responsible for actual hours logged on the
planning project times the agreed upon hourly rate. In the case of a fixed fee engagement the percentage of the fee
is based on the percentage completion of the engagement. The Client’s financial planning agreement with the
Advisor is non-transferable without the Client’s prior consent.
Use of Independent Managers
In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best
interest, the Advisor will have the discretion to terminate the relationship with the Independent Manager. The
terms for termination are set forth in the respective agreements between the Advisor and the Independent
Managers.
Retirement Plan Advisory Services
M3 is compensated for its services at the end of the billing period in which retirement plan advisory services are
rendered. Either party may terminate the retirement plan advisory agreement, at any time, by providing advance
written notice to the other party. The Client may also terminate the retirement plan advisory agreement within five
(5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client
will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due
and payable by the Client. The Client’s retirement plan services agreement with the Advisor is non-transferable
without the Client’s prior consent.
E. Compensation for Sales of Securities
M3 does not buy or sell securities for the receipt of commissions. The Advisor does not receive any compensation
for securities transactions in any Client account, other than the investment advisory fees noted above.
Advisory Persons are licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person will earn commission-based compensation for selling insurance products,
including insurance products they sell to Clients. Insurance commissions earned by an Advisory Person are
separate and in addition to M3's advisory fees. This practice presents a conflict of interest because a person
providing investment advice on behalf of the Advisor who is also an insurance agent has an incentive to
recommend insurance products to Clients for the purpose of generating commissions rather than solely based on
Client needs. However, Clients are under no obligation, contractually or otherwise, to purchase insurance
products through an Advisory Person.
Item 6 – Performance-Based Fees
M3 does not charge performance-based fees for its investment advisory services. The fees charged by M3 are
as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 9 -
M3 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 for its Clients.
Item 7 – Types of Clients
M3 offers investment advisory services to individuals, high net worth individuals, trusts, estates, retirement plans,
charitable organizations, and corporations. M3 generally does not impose a minimum size for establishing a
relationship.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
M3 is focused on managing risk and generating returns through disciplined and whenever possible the removal
of human bias from the decision-making process. M3 may also employ fundamental and technical analysis
methods in developing investment strategies for its Clients. Research and analysis from M3 are derived from
numerous sources, including Morningstar, Fidelity, Vanguard, financial media companies, third-party research
materials, and review of company activities, including annual reports, prospectuses, press releases and research
prepared by others.
M3 also obtains information from regulatory reports and other sources as appropriate. The Advisor also utilizes
information obtained from regulatory releases, the Internet, information provided at conferences and other
information obtained from regulatory sources.
As noted above, M3 generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. M3 will typically hold all or a portion of a security for more than a year, but for adjustments made
for purposes of rebalancing the portfolio. At times, M3 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. M3 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. 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 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. M3 generally employs investment strategies that do not involve any significant or unusual risk other
than domestic equity and international market risks. The risks associated with a particular strategy are provided
to each Client in advance of investing Client accounts. Following are some of the risks associated with the
Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 10 -
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later. There is also a risk that Authorized Participants are unable to fulfill their responsibilities.
Authorized Participants are one of the major parties involved with ETF creation/redemption mechanism in the
markets. The Authorized Participants play a critical role in the liquidity of ETFs and essentially have the exclusive
right to change the supply of ETF shares in the market. If the Authorized Participants does not fulfill this expected
role, there could be an adverse impact on liquidity and the valuation of an ETF.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Independent Manager Risks
The Advisor may select certain Independent Managers to manage a portion of the Client’s portfolio. The Advisor
will conduct due diligence, monitor the performance and adherence to the investment mandates and objectives
on the selected Independent Managers. However, the Advisor will not have an active role in the day-to-day
management of this portion of the Client’s portfolio. A failure by an Independent Managers to achieve its
investment objectives could result in a negative impact on the Client’s overall investment portfolio.
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. For more information on our investment advisory services, please
contact us at (781) 371-2670.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving M3 or its management persons. M3 values
the trust you place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any
advisor or service provider that the Client engages. The backgrounds of the Advisor and its Advisory Persons are
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov and can be found by
searching with the Advisor’s firm name or CRD# 156208.
Item 10 – Other Financial Activities and Affiliations
Insurance Agency Affiliations
As noted in Item 5, Advisory Persons are also licensed insurance professionals. Implementations of insurance
recommendations are separate and apart from an Advisory Person's role with the Advisor. As an insurance
professional, an Advisory Person will receive customary commissions and other related revenues from the
various insurance companies whose products are sold. An Advisory Person is not required to offer the products
of any particular insurance company. Commissions generated by insurance sales do not offset regular advisory
fees. This practice presents a conflict of interest in recommending certain products of the insurance companies.
Clients are under no obligation to implement any recommendations made by an Advisory Person or the Advisor.
Use of Independent Managers
As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio with one or more
Independent Managers. The Advisor does not receive any compensation nor does this present a material conflict
of interest. The Advisor will only earn its investment advisory fee as described in Item 5.A.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 11 -
Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading
A. Code of Ethics
M3 has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with M3 (“Supervised Persons”). The Code was developed to
provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. M3 and
its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of
M3’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 may address employee ethics and
conflicts of interest. To request a copy of the Code, please contact the Advisor at (781) 371-2670.
B. Personal Trading with Material Interest
M3 allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. M3 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. M3 does not have a material interest in
any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
M3 allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, the Advisor must be disclosed to Clients and mitigated through
policies and procedures. As noted above, the Advisor has adopted a Code of Ethics, which addresses insider
trading (material non-public information controls) and personal securities reporting procedures. When trading for
personal accounts, Supervised Persons of M3 have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by M3 requiring reporting of personal securities trades by its Supervised Persons for review by the
Chief Compliance Officer (“CCO”). The Advisor has also adopted written policies and procedures to detect the
misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While M3 allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded after Client
orders have been placed and filled. At no time, will M3 or any Supervised Person of M3, transact in any
security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
M3 does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize M3 to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, M3 does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-
by-trade basis.
Where M3 does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will
not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by M3.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not
engaged. M3 may recommend the Custodian based on criteria such as, but not limited to, reasonableness of
commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the
Custodian’s offices. M3 will generally recommend that Clients establish their account[s] at Fidelity Clearing &
Custody Solutions and related entities of Fidelity Investments, Inc. (collectively “Fidelity”), FINRA-registered
broker-dealer and member SIPC. Fidelity will serve as the Client’s “qualified custodians”. M3 maintains an
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 12 -
institutional relationship with Fidelity, whereby the Advisor receives economic benefits from Schwab and Fidelity.
Please see Item 14 below.
The following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an
advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for
research and other services. M3 does not participate in soft dollar programs sponsored or offered
by any broker-dealer/custodian. However, M3 does receive certain economic benefits from Fidelity
as detailed in Item 14.
2. Brokerage Referrals - M3 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 M3 will place
trades within the established account[s] at the Custodian designated by the Client. Further all Client
accounts are traded within their respective account[s] at the Custodian. The Advisor will not engage in any
principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions
with other Client accounts (i.e., purchase of a security into one Client account from another Client’s
account[s]). M3 will not be obligated to select competitive bids on securities transactions and does not
have an obligation to seek the lowest available transaction costs. These costs are determined by the
Custodian.
B. Aggregating and Allocating Trades
The 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 the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. M3 will execute its transactions through the
Custodian as directed by the Client. M3 generally trades the Client’s account[s] individually. M3 may aggregate
orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple
(discretionary) accounts. If a block trade cannot be executed in full at the same price or time, the securities
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 particular Client accounts. Prior to entry of a block trade, a written pre-allocation will
be generated which identifies the group of Client accounts participating in the order.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Mr. Jeffries, Managing Director
of the Advisor. Formal Client reviews are conducted at least annually or more frequently at the Client’s request.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify M3 if changes occur in
his/her personal financial situation that might adversely affect his/her 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].
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 13 -
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by M3
M3 may refer Clients to various third parties to provide certain financial services necessary to meet the goals of its
Clients. Likewise, M3 may receive referrals of new Clients from a third-party.
Participation in Institutional Advisor Platform
The Advisor has established an institutional relationship with Fidelity to assist the Advisor in managing Client
account[s]. Access to the Fidelity Institutional platform is provided at no charge to the Advisor. The Advisor
receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity. The software and related systems support may
benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all
times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic
benefits from a custodian creates a conflict of interest since these benefits may influence the Advisor’s
recommendation of this custodian over one that does not furnish similar software, systems support, or services.
Additionally, the Advisor may receive the following benefits from Fidelity: 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 Promoters
The Advisor does not compensate, either directly or indirectly, any affiliated or unaffiliated parties (“Promoters”)
for Client referrals.
Item 15 – Custody
M3 does not accept or maintain custody of Client accounts, except for the limited circumstances outlined below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom M3 exercises discretionary authority must hold their assets with a "qualified
custodian." Clients are responsible for engaging a “qualified custodian” to safeguard their funds and securities
and must instruct M3 to utilize that Custodian for securities transactions on their behalf. Clients are encouraged
to review statements provided by the Custodian and compare to any reports provided by M3 to ensure accuracy,
as the Custodian does not perform this review.
Money Movement Authorization - For instances where Clients authorize M3 to move funds between their
accounts, M3 and the Custodian have implemented safeguards to ensure that all money movement activities are
conducted strictly in accordance with the Client’s documented instructions.
Item 16 – Investment Discretion
M3 generally has discretion over the selection and number 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 M3.
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 M3 will be in accordance with each Client's investment objectives
and goals.
Item 17 – Voting Client Securities
M3 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.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 14 -
Item 18 – Financial Information
Neither M3, nor its management have any adverse financial situations that would reasonably impair the ability of
M3 to meet all obligations to its Clients. Neither M3, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. M3 is not required to deliver a balance sheet along with this Disclosure
Brochure as the firm does not collect fees of $1,200 or more for services to be performed six months or more in
advance.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 15 -
Form ADV Part 2B – Brochure Supplement
for
John D. Jeffries, CLU®
Founder, Managing Director
Effective: October 27, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of John
D. Jeffries, CLU® (CRD# 1332202) in addition to the information contained in the M3 Advisory Group, LLC (“M3”
or the “Advisor” CRD #156208) Disclosure Brochure. If you have not received a copy of this Brochure Supplement
or if you have any questions about the content of this Brochure Supplement or M3’s Disclosure Brochure, please
contact the Advisor at (781) 371-2670.
Additional information about John D. Jeffries 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# 1332202.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 16 -
Item 2 – Educational Background and Business Experience
Mr. Jeffries, born in 1961, serves as a Founder and Managing Director of M3. John has been serving Clients with
investment and insurance needs for over 26 years. Prior to establishing the registered investment advisory
practice, John served as a Financial Advisor with LPL Financial. John earned an MBA from Boston College -
Wallace E. Carroll Graduate School of Management. John is a graduate of University of Massachusetts Amherst
with a BA in Economics and Political Science. John has also earned the Chartered Life Underwriter (“CLU”)
designation from the American College in Bryn Mawr, PA. Mr. Jeffries holds the Series 6,7,63,65 and is a
General Securities Principal.
Mr. Jeffries is an elected official in the town of Dover Massachusetts, he currently serves as Chairman of the
Board of Selectman. Mr. Jeffries servers on the Board of Directors of Armstrong Ambulance in Arlington MA, a
76-year-old private company. Mr. Jeffries was co-founder, and Director of the following companies and
organizations: U.S. Seafood Corp, Plymouth Street Partners, Selective Technology Sales, and the Wellesley
Community Center. He served two terms as a Member of the Finance and Budget Committee in the Town of
Wellesley, Massachusetts.
02/2011 to Present
05/2015 to 12/2016
09/2012 to 06/2014
07/2011 to 08/2012
03/2011 to 07/2011
12/2006 to 03/2011
Past Securities Registration and Employment History:
Founder, Managing Director, M3 Advisory Group, LLC
Registered Representative, Fusion Analytics Securities LLC
Registered Representative, Hebert J. Sims & Co., Inc.
Registered Representative, Mutual Securities Corp.
Registered Representative, Purshe Kaplan Sterling Investments
Registered Representative and Investment Advisor Representative, Linsco Private
Ledger
M3 Equity Advisors, LLC
02/2003 to 12/2006
The Chartered Life Underwriter (“CLU®”)
The Chartered Life Underwriter® (CLU®) is a designation of insurance expertise, helping gain a significant
advantage in a competitive market. This course of study helps by providing in-depth knowledge on the insurance
needs of individuals, business owners and professional clients.
Program Learning Objectives:
• Provide guidance to clients on types and amounts of life insurance needed
• Make recommendations on aspects of risk management, including personal and business uses of a
variety of insurance solutions
• Provide guidance to clients on legal aspects of life insurance contracts and beneficiaries
• Assist clients in making decisions about estate planning, including proper holding of assets and title to
assets, as well as the implications of various wills and trust arrangements on financial, retirement and
succession planning issues
Provide a holistic and comprehensive approach to addressing the insurance planning needs of their clients
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Jeffries. Mr. Jeffries 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. Jeffries.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Jeffries.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 17 -
However, the Advisor does encourage you to independently view the background of Mr. Jeffries on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 1332202.
Item 4 – Other Business Activities
Insurance Affiliations
Mr. Jeffries is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from his role with M3. As an insurance professional, Mr. Jeffries will receive customary
commissions and other related revenues from the various insurance companies whose products are sold. Mr.
Jeffries is not obligated to offer the products of any particular insurance company. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in recommending
certain products of the insurance companies. Clients are under no obligation to implement any recommendations
made by Mr. Jeffries or the Advisor.
Town of Dover
Mr. Jeffries also serves as a Selectman for the Town of Dover, MA. Mr. Jeffries spends less than 10% of his time
in this capacity. He is not compensated.
Item 5 – Additional Compensation
Mr. Jeffries has additional business activities where compensation is received. These business activities are
detailed in Item 4 above.
Item 6 – Supervision
Mr. Jeffries serves as Founder and Managing Director of M3 Advisory and is supervised by Nicholas Jeffries, the
Chief Compliance Officer. Mr. Jeffries can be reached at (781) 371-2670.
M3 Advisory has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of M3 Advisory. Further, M3 Advisory is subject to
regulatory oversight by various agencies. These agencies require registration by M3 Advisory and its Supervised
Persons. As a registered entity, M3 Advisory is subject to examinations by regulators, which may be announced
or unannounced. M3 Advisory 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.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 18 -
Form ADV Part 2B – Brochure Supplement
for
Mark W. Scionti
Managing Director
Effective: October 27, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Mark W. Scionti (CRD# 1425426) in addition to the information contained in the M3 Advisory Group, LLC (“M3
Advisory” or the “Advisor”, CRD# 156208) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the M3 Advisory Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (781) 371-2670.
Additional information about Mr. Scionti 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# 1425426.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 19 -
Item 2 – Educational Background and Business Experience
Mark W. Scionti, born in 1962, is dedicated to advising Clients of M3 Advisory as a Managing Director. Mr.
Scionti earned a MA in Economics from Boston University in 1987. Mr. Scionti also earned a BS in Economics
from Boston University in 1985. Additional information regarding Mr. Scionti’s employment history is included
below.
Employment History:
M3 Advisory Group, LLC dba M3 Family Office LLC, Investment Advisor Representative 02/2020 to Present
Investment Advisor Representative, Integrated Wealth Concepts LLC
09/2018 - 03/2020
M3 Advisory Group, LLC
Investment Advisor Representative
-
- Managing Director
Managing Director M3 Capital Advisors, LLC
02/2015 - 11/2018
02/2011 - 02/2015
07/2002 - 01/2016
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Scionti. Mr. Scionti 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. Scionti.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Scionti.
However, the Advisor does encourage you to independently view the background of Mr. Scionti on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 1425426.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Scionti is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. Scionti’s role with M3 Advisory. As an insurance professional, Mr. Scionti will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Scionti is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Scionti or the Advisor. Mr. Scionti spends approximately 10% of his time per
month in this capacity.
Item 5 – Additional Compensation
Mr. Scionti has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Scionti serves as a Managing Director of M3 Advisory and is supervised by Nicholas Jeffries, the Chief
Compliance Officer. Mr. Jeffries can be reached at (781) 371-2670.
M3 Advisory has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of M3 Advisory. Further, M3 Advisory is subject to
regulatory oversight by various agencies. These agencies require registration by M3 Advisory and its Supervised
Persons. As a registered entity, M3 Advisory is subject to examinations by regulators, which may be announced
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 20 -
or unannounced. M3 Advisory 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.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 21 -
Privacy Policy
Effective: October 27, 2025
Our Commitment to You
M3 Advisory Group, LLC (“M3” or the “Advisor”) is committed to safeguarding the use of your personal
information that we have as your Investment Advisor.
M3 (also referred to as "we", "our" and "us" throughout this notice) 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. 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.
M3 does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and proper 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 Privacy Policy.
Why you need to know?
Registered investment advisors (“RIAs”) share some of your personal information. Federal and State laws give
you the right to limit some of this sharing. Federal and State laws 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 sources do we collect information from in addition to you?
Custody, brokerage and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Transactional information with us or others
Investment questionnaires and
suitability documents
Other information needed to service
account
How do we protect your information?
To safeguard your personal information from unauthorized access and use, we maintain physical, procedural and
electronic safeguards. These include computer safeguards such as passwords, as well as secured files and
buildings. Our employees are advised about M3's need to respect the confidentiality of each client’s non-public
personal information. We train our employees on their responsibilities. We require third parties that assist in
providing our services to you to protect the personal information they receive. This includes contractual language
in our third-party agreements.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 22 -
How we share your information?
RIAs do need to share personal information regarding its clients to effectively implement the RIA’s services. In
the section below, we list some reasons we may share your personal information.
Sharing
Limitations
M3 may share
this information.
Clients cannot
limit the Advisor’s
ability to share.
M3 may share
this information.
Clients cannot
limit the Advisor’s
ability to share.
M3 does not
share personal
information.
Clients cannot
limit the Advisor’s
ability to share.
M3 does share
personal
information.
Clients can limit
the Advisor’s
ability to share.
Basis For Sharing
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as brokers, custodians, regulators, credit agencies, other
financial institutions) as necessary for us to provide agreed upon services
to you, consistent with applicable law, including but not limited to:
processing transactions; general account maintenance; responding to
regulators or legal investigations; and credit reporting.
Administrators
We may disclose your non-public personal information to companies we
hire to help administer our business. Companies that we hire to provide
services of this nature are not allowed to use your personal information
for their own purposes and are contractually obligated to maintain strict
confidentiality. We limit their use of your personal information to the
performance of the specific service we have requested.
Marketing Purposes
M3 does not disclose, and does not intend to disclose, personal
information with non-afffiliated 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 M3 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.
Authorized Users
In addition, your non-public personal information may also be disclosed
to you and persons that we believe to be your authorized agent or
representative.
Clients can limit
the Advisor’s
ability to share.
Information About Former Clients
M3 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.
M3 does not
share personal
information
regarding former
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 notice of our Privacy Policy annually for as long as you maintain an ongoing relationship with
us. Periodically we may revise our Privacy 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) 371-2670.
M3 Advisory Group, LLC
60 Kendrick Street, Suite 203, Needham Heights, MA 02494
Phone: (781) 371-2670 * Fax: (781) 371-2690
www.m3ag.com
- 23 -