MASCOMA WEALTH MANAGEMENT

Mascoma Wealth Management LLC Part 2A of Form ADV Brochure 80 South Main Street, Suite 103 Hanover, NH 03755 February 28, 2026 https://mascoma.bank/wealth-management/mascoma-wealth-management-llc/ This brochure provides information about the qualifications and business practices of Mascoma Wealth Management LLC (MWM). If you have any questions about the contents of this brochure, please contact us at (603) 676-8813 or via email at Wealth@mascomabank.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about Mascoma Wealth Management LLC also is available on the SEC's website at www.adviserinfo.sec.gov. Mascoma Wealth Management LLC (MWM) is an SEC Registered Investment Advisor. Registration does not imply a certain level of skill or training. 1  Item 2 Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an advisor's disclosure brochure, the advisor is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated March 27, 2025, we have made the following material changes: • We have modified language in Item 5 to reflect that fees begin accruing on the business day assets are received. Previously, the section stated that fees would begin accruing after the account is funded only on the next subsequent first (1st) or fifteenth (15th) day of the month. • We have added additional details in Item 8 regarding the functioning of MWM's Investment • Committee. In Item 16, we have added clarifying language that any client directed restrictions or prohibitions in accounts we have been granted discretion must be provided in writing. • We have added language in Items 4 and 10 regarding the use of sub-advisors as part of our investment management services. Please refer to these items for further details. 2  Item 3 Table Of Contents Item 1 Cover Page Item 2 Material Changes Item 3 Table Of Contents Item 4 Advisory Business Item 5 Fees and Compensation Item 6 Performance-Based Fees and Side-By-Side Management Item 7 Types of Clients Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Item 9 Disciplinary Information Item 10 Other Financial Industry Activities and Affiliations Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Item 12 Brokerage Practices Item 13 Review of Accounts Item 14 Client Referrals and Other Compensation Item 15 Custody Item 16 Investment Discretion Item 17 Voting Client Securities Item 18 Financial Information Page 1 Page 2 Page 3 Page 4 Page 6 Page 8 Page 8 Page 8 Page 12 Page 12 Page 13 Page 13 Page 14 Page 15 Page 15 Page 16 Page 16 Page 16 3  Item 4 Advisory Business Description of Services and Fees Mascoma Wealth Management LLC ("MWM") is a fee-only registered investment adviser based in Hanover, New Hampshire. MWM is organized as a Registered Investment Advisor under the Securities & Exchange Commission. Our firm was originally established in March of 2013 and is a wholly owned subsidiary of Mascoma Bank of Lebanon, NH. MWM primarily provides comprehensive financial planning and customized discretionary portfolio management services to individuals, families and non-profit institutions. MWM generally invests client assets in domestic and international stocks, exchange traded funds ("ETFs"), bonds, and no load mutual funds. MWM works with each client to establish an appropriate investment profile at the onset of the relationship and through ongoing conversations regarding investment expectations, time horizons, risk tolerances and liquidity needs. MWM assists each client with selecting an investment objective with established asset allocation ranges for each of their accounts. Clients can impose reasonable restrictions on MWM's management of their accounts. As of December 31, 2025, MWM client assets under management were: • Discretionary: $536,015,042 • Non-Discretionary: $31,738,002 • Total Assets: $567,753,044 Portfolio Management Services MWM provides financial advice and planning services as part of an all-inclusive service, including either discretionary or non-discretionary management of investment portfolios in accordance with individual investment objectives. All services are included as part of the overall management fee described below. If you retain our firms services, we will enter into an agreement for those services. If you participate in our discretionary investment management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is granted by the investment management agreement you sign with our firm. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your specific restrictions and guidelines in writing. If you participate in our non-discretionary account services you, the client, retain discretionary authority over the account. We may provide general investment recommendations and advice but will only execute transactions with your explicit authorization and direction. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. You may make additions to and withdrawals from your account at any time, subject to our right to terminate an account. You may withdraw account assets on notice to our firm, and subject to the usual and customary securities transfer and settlement procedures of the account custodian. However, we design our portfolios as long-term investments and asset withdrawals may impair the achievement of 4  your specific investment objectives. We may advise you to move your account to an alternate servicing model outside of MWM's operating platform if your assets fall below an amount which we are able to manage effectively. Additions to your account may be in cash or securities; however, we expressly reserve the right to liquidate any transferred securities or decline to accept particular securities into your account. We may consult with you about the options and ramifications of transferring or liquidating securities. However, you are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge) and/or tax ramifications. You are also advised to promptly notify our firm if there are ever any changes in your financial situation or investment objectives or if you wish to impose any reasonable restrictions upon our management services. The agreement for services will continue in effect until terminated by either party pursuant to the terms of the agreement. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. Refunds are not applicable as our fees are payable quarterly in arrears. Advisory Services to Retirement Plans The advisory services we offer to employee benefit plans ("Plan") are designed to assist plan sponsors in meeting their management and fiduciary obligations to participants under the Employee Retirement Income Securities Act ("ERISA"). Pursuant to adopted regulations of the U.S. Department of Labor, we are required to provide the Plan's responsible Plan fiduciary (the person who has the authority to engage us as an investment adviser to the Plan) with a written statement of the services we provide to the Plan, the compensation we receive for providing those services, and our status. This information is outlined within the advisory management agreement. Sub-Adviser Relationships As part of our investment management services, we may use one or more sub-advisers to assist in certain aspects of managing your account(s). We will maintain discretionary authority over the account(s) and will continue to regularly monitor the performance of your accounts managed by sub- adviser(s). If we recommend your account(s) be enrolled with a sub-adviser, you will be required to sign a form authorizing the account Custodian, Fidelity Investments, to grant the sub-adviser limited trading authority over the account. Any fees associated with the sub-advisers' services are separate and apart from the fees you pay to MWM. Each sub-advisers' fees and compensation arrangements are described within their firm's ADV Disclosure Brochures which will be provided to you prior to enrollment in their services and are also available upon request. Please also refer to the Other Financial Industry Activities and Affiliations section for additional information related to compensation and conflicts of interest relating to our Sub-Adviser partnerships; however please note, you will not pay MWM a higher advisory fee as a result of any sub-advisory relationships. 5  Types of Investments We primarily offer advice and allocate your assets among ETFs, individual equity and debt securities, or mutual funds; however, as appropriate, we will also recommend other types of investments for you since each client has different needs and different tolerance for risk. We will advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. Each type of security has its own unique set of risks associated with it, it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. You may request that we refrain from investing in particular securities or certain types of securities. You must provide these specific restrictions to our firm in writing. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Item 5 Fees and Compensation Our annual fee for management services provided to discretionary and non-discretionary relationships varies (between 0.50% and 1.10% ) depending on discretion or non-discretion and upon the market value of the assets we manage on your behalf, as follows: Discretionary Account Fee Schedule 1.10% on the first $1,000,000 0.90% on the next $1,000,000 0.75% on the next $1,000,000 0.50% above $3,000,000 6  Non-Discretionary Account Fee Schedule 0.50% on the balance MWM requires a minimum relationship size of $300,000 and an annual minimum fee of $3,000 for discretionary and non-discretionary relationships. We may aggregate account assets for you and your minor children, joint accounts, and/or other types of related accounts for purposes of calculating the above fee schedule or to satisfy minimum requirements. The investment management fee is billed and payable quarterly in arrears based on the average daily balance of your account(s) during the previous quarter. Fees begin accruing only after an Account is funded, beginning on the business day assets are received. In our sole discretion, we may negotiate to charge a lesser management fee based upon certain criteria such as anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, pre-existing client, account retention, pro bono activities, etc. Our Agreement and the separate agreement you sign with a financial firm for custodial and brokerage services will authorize our firm through the financial firm to debit your account for the amount of our management fee and to directly remit that management fee to our firm in accordance with applicable custody rules. The financial firm we utilize has agreed to send a statement to you no less than quarterly indicating all amounts disbursed from your account including the amount of any management fees paid directly to our firm. You should review all statements for accuracy. We will also receive a duplicate copy of your account statements. Our annual fee for advisory services to employer retirement plans varies (between 0.30% and 0.45%) depending upon the market value of the Retirement Plan assets, as follows: Employee Benefit Plan Fee Schedule 0.45% on plans up to $2,000,000 0.35% on plans for the next $2,000,000 0.30% on plans over $4,000,000 Our minimum relationship size for employer retirement plan advisory services is $1,000,000. The investment advisory fee is billed and payable quarterly in arrears based on the quarter-end balance of the plan assets. If the agreement for services is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our compensation for services provided to an employee benefit Plan is based on the fee schedule listed above; however, the fee may be negotiated based on the size and complexity of the Plan and services required. The final negotiated fee will be detailed in the advisory agreement. Grandfathering of Fees: Clients are subject to fees schedules in effect at the time the advisory agreement is executed. Therefore, fee schedules will differ among clients. 7  Additional Fees and Expenses As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual funds and exchange traded funds ("ETFs"). The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or ETFs (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You may also incur administrative fees, transaction charges and/or brokerage fees when purchasing or selling securities, mutual funds or ETFs. These charges and fees are typically imposed by the broker- dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, ETFs, our firm, and others. For information on our brokerage practices, please refer to the Brokerage Practices section of this Disclosure Brochure. If your accounts are enrolled in sub-adviser services, any fees associated with those services are separate and apart from the fees you pay to MWM. We do not share in any portion of the charges imposed by the sub-adviser. Each sub-advisers' fees and compensation arrangements are described within their firm's ADV Disclosure Brochures which will be provided to you prior to enrollment in their services and are also available upon request. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. Performance-based fees are fees that are based on a share of the capital gains or capital appreciation of a client's account. Our fees are calculated as described in the Advisory Business section above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your account. Item 7 Types of Clients We offer investment advisory services to individuals, families, pension and profit sharing plans, trusts, estates, charitable organizations, municipalities, corporations, employee retirement plan sponsors, and other business entities. MWM requires a minimum relationship size of $300,000 for all discretionary and non-discretionary relationships, a minimum relationship size of $1,000,000 for employer retirement plan advisory relationships, and an annual minimum fee of $3,000 for all relationships. We may aggregate account assets for you and your minor children, joint accounts, and/or other types of related accounts for purposes of calculating the above fee schedule or to satisfy minimum requirements. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Investment Philosophy: The fiduciary mindset drives our entire investment management process.  Our selection process is rigorous and structured to target an appropriate risk-adjusted investment return consistent with your risk profile. At the same time, we believe that we are nimble enough to adjust portfolios as 8  market and economic conditions warrant. Our core investment suite focuses on the use of Exchange Traded Funds (ETFs) to provide diversified broad market exposure and low expenses.   To the extent it is of interest, Mascoma Wealth Management can incorporate investment options it screens for their Environmental, Social, and Governance (ESG) attributes.  We have a strong commitment to working with clients to ensure that their portfolios reflect their values. MWM's investment approach seeks to accomplish three primary objectives: • Provide actively managed, strategically diversified, long-term portfolios. • Utilize passive investment vehicles as the core of our portfolios. • Generate returns consistent with an account's stated risk tolerance. Investment Strategy: At the inception of an advisor/client personal relationship, we ask new clients to complete a fiduciary questionnaire designed to outline their current financial situtation, risk tolerance, time horizon, and income needs. These questionnaires are instrumental in developing appropriate investment objectives, which dictate how much should be invested in equities and fixed income in each of your accounts. You should understand that the equity portion of your portfolio is determined to be the portion of the portfolio with the greatest risk. Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Investment Committee: MWM's Investment Committee partners with team members from Investment Research, Compliance, and Operations. It holds weekly meetings to design, oversee and implement the firm's investment philosophy, approach, and processes. The Investment Committee leverages partnerships with some of the largest money managers in the world, including JPMorgan, BlackRock, Vanguard, State Street, Fidelity, and First Trust. On a quarterly, rotating basis, the Investment Committee invites representatives from these firms to seek thought leadership on an ever-changing macro-economic landscape. As part of these meetings, our partners also provide in-depth analysis and stress-testing of MWM's investment portfolios to ensure our core holdings remain appropriate for the current economic conditions and capital market expectations. Common themes among our partners are identified to mitigate partnership bias, and then evaluated for potential portfolio implementation. When assessing potential investments, we consider various criteria beyond performance, such as expense ratio, liquidity, risk and volatility metrics, and Morningstar ratings, to ensure they meet our stringent standards. Prior to adding any new Exchange Traded Funds to our offering, the Investment Committee may place them on a monitoring list for vetting purposes. During this period, the Investment Committee closely monitors the investments before deciding whether to approve them for firm-wide use. As an added layer of due diligence, the Investment Committee uses Moody's Analytics to provide independent interpretations of economic data. In addition to reviewing the approved investment lists, we regularly examine our signature portfolio suite. These portfolios represent our best thinking for each risk objective at a given point in time.  9    Mascoma Wealth Management holds monthly team meetings, during which the Investment Committee provides updates on the firm's economic opinion and core investment holdings. The Committee also shares insights that our advisors can apply when communicating with clients and the community. This ensures that advisors are equipped with the latest information to effectively address clients' questions and concerns.  Mascoma Wealth Management recognizes the importance of proper asset allocation, geographic diversification, and diligent risk control in targeting an appropriate risk-adjusted investment return. Diversifying across non-correlated assets within a portfolio can enhance expected returns for a given level of risk and lower the risk for a given expected rate of return. This philosophy drives our approach to asset allocation. Our Investment Committee identifies investment opportunities and assesses associated risks. The Committee is responsible for analyzing various asset classes and making informed decisions on the allocation of investment capital. By carefully considering different asset classes among the global markets that offer uncorrelated rates of return, our objective is to optimize risk-adjusted returns for our clients. Investment Vehicles Informed by our commitment to delivering consistent results, we consider industry data and research on the performance of active investment strategies. According to SPIVA® (S&P Indices Versus Active) data as of June 30, 2025, over the last 15 years, 88.29% of domestic funds have underperformed the S&P Composite 500. This evidence highlights the challenges faced by active investors in consistently outperforming the market. As a fiduciary, we prioritize our clients' best interest and believe that implementing a predominantly passive approach to investing through Exchange Traded Funds (ETFs) is advantageous. Exchange traded funds offer several key benefits: 1. Diversification: ETFs are often designed to track market indices, allowing investors to access hundreds or thousands of securities within a single investment. 2. Transparency: ETFs report their holdings daily, providing investors with visibility into their portfolio's composition and ensuring close tracking of respective benchmarks. This transparency sets ETFs apart from mutual funds, which typically report holdings on a monthly or quarterly basis. 3. Lower Trading Costs: ETFs eliminate the need for minimum investments and do not charge front-end loads or redemption fees. This cost structure can translate into significant savings for investors. 4. Lower Expense Ratio: Traditional mutual funds often carry expense ratios between 0.50% and 2.00%, significantly impacting the clients' portfolio return. The average expense ratio for our client portfolios falls within the range of 0.10% to 0.25%. 5. Tax Efficiency: Compared to traditional Mutual Funds, ETFs typically distribute fewer capital gains to shareholders. This tax efficiency is a result of many ETFs being based on fixed passive indices. As a result, ETF investors typically only realize capital gains or losses when they sell their shares. By incorporating ETFs into our investment strategy, we strive to harness these advantages to benefit our clients. This approach aligns with our fiduciary duty and our commitment to providing cost-effective investment solutions while aiming for optimal risk-adjusted returns. 10  Risk of Loss Market Risks Investing in securities involves risk, including the potential loss of principal. We do not represent or guarantee that our services or methods of analysis can or will insulate clients from losses due to market corrections or declines. Past performance is not an indication of future performance. The profitability of our recommendations and/or investment decisions may depend upon correctly assessing the future course of price movements of stocks, bonds and other asset classes. There can be no assurance that MWM will be able to predict those price movements accurately or capitalize on any such assumptions. Stocks There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, better established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Bonds Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on: the financial health of the issuer; the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Mutual Funds and ETFs An investment in a mutual fund or exchange traded fund involves risk, including the loss of principal. Mutual fund and exchange-traded fund shareholders are necessarily subject to the risks stemming from the individual issuers of the fund's underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and exchange traded funds are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund's stated daily per share net asset value ("NAV"), plus any shareholders fees (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intra-day changes to the market value of the fund's holdings. The trading prices of a mutual fund's shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund's shares trading at a premium or discount to actual NAV. Shares of exchange traded funds are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, exchange traded fund shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed based exchange traded funds and potentially more frequently for actively managed exchange traded funds. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. If a liquid secondary market ceases to exist for shares of a particular exchange traded fund, a shareholder may have no way to dispose of such shares. 11  ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of its Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their underlying indices or benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all the securities included in its underlying index, or its weighting of investment exposure to such securities may vary from that of the underlying index. Some ETFs may invest in securities or financial instruments that are not included in the underlying index, but which are expected to yield similar performance. Cash Management In managing the cash maintained in your account, we utilize cash vehicles (money markets) made available by the custodian. There may be other cash management options away from the custodian available to you with higher yields or safer underlying investments. Item 9 Disciplinary Information MWM and its employees have not been involved in any legal or disciplinary events. Item 10 Other Financial Industry Activities and Affiliations MWM is a subsidiary of and affiliated with Mascoma Bank, a mutually owned community bank headquartered in Lebanon, NH. Mascoma Bank may provide traditional banking, credit/lending, and/or trustee services to mutual clients of MWM. MWM and its employees have limited access to Mascoma Bank customer's bank account information. Details of the information shared between MWM and its affiliates is outlined on our most recent Privacy Notice. A copy of this notice is available on our website and can also be provided upon request by contacting us using details found on the cover page of this document. MWM may recommend that you use a sub-adviser or third-party money manager ("TPMM") based on your needs and suitability. We will not receive separate compensation, directly or indirectly, from any sub-adviser or TPMM for recommending that you use their services. Moreover, we do not have any other business relationships or affiliations with the recommended sub-advisers/TPMM(s). • MWM utilizes 55I, LLC ("55ip") as a sub-adviser for tax loss management and tax harvesting strategies. 55ip's services include ongoing trading and rebalancing accounts, with a focus on tax efficiency, in accordance with your stated annual tax budget and the model portfolio strategy assigned by MWM as the "Model Provider". Please note that 55ip provides this service at no cost to you or MWM due to the allocation of JPMorgan funds within our current portfolios. This may present a conflict of interest in that we are incentivized to utilize JPMorgan funds in client accounts in order to continue being able to offer 55ip's services to clients at no added cost. • MWM also utilizes J.P. Morgan Investment Management Inc. ("JPMIM") as sub-adviser and TPMM for direct indexing strategies. JPMIM builds and manages investment model portfolios designed to track specific indexes, selected by you as the client, and may use one or more of their model portfolios to manage your account. JPMIM may invest certain client accounts and funds in certain JPMorgan Affiliated Funds managed by affiliated advisers which is a conflict of interest because JPMIM and its affiliates receive compensation when clients invest in these funds. While MWM does not receive separate compensation, directly or indirectly, from 55ip or JPMIM, we are making this disclosure to help you understand any 12  potential conflicts of interest as a result of these relationships. Please refer to 55ip's and JPMIM's ADV Disclosure Brochures for additional information and potential conflicts of interest. Additional information about both Advisers is also available on the SEC's website at www.adviserinfo.sec.gov and can be found using 55ip's CRD # 286620 or JPMIM's CRD # 107038. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics MWM and its affiliates expect all directors, officers, employees, and agents to act in accordance with the highest standards of personal and professional integrity in all aspects of their activities and to comply with all applicable laws, regulations and company policies. We must never compromise that integrity, either for personal benefit or for MWM's purported benefit. In accepting a position with MWM, each of us becomes accountable for compliance with all applicable industry laws and the MWM Code of Ethics. Personal Trading Practices Our firm has adopted a Code of Ethics that sets forth the standards of conduct for our supervised persons and addresses personal trading practices. MWM must collect information regarding the personal trading activities and holdings of all related Access Persons. MWM's Code of Ethics is designed to mitigate material conflicts of interest associated with Access Persons' personal trading activities. The CCO, or designee, is responsible for monitoring personal trading reports for potential conflicts of interest and for overseeing compliance with, and enforcement of, our Code of Ethics. Our Code of Ethics is available to you upon request by contacting us using details found on the cover page of this document. Participation or Interest in Client Transactions Neither our firm nor any of our Associated Persons has any material financial interest in client transactions beyond the provision of services as disclosed in this brochure. Item 12 Brokerage Practices We require that your transactions be placed through Fidelity Institutional Wealth Services and its affiliates (collectively referred to as "Fidelity"). We will only use the brokerage and custodial services of Fidelity, a securities broker-dealer and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. We will only implement our investment management recommendations after you have arranged for and furnished our firm with all information and authorization regarding accounts with the appropriate financial institution. Factors that we consider in utilizing Fidelity as our securities broker-dealer for you include their financial strength, reputation, execution, pricing, research, and service. Fidelity enables our firm to obtain many mutual funds without transaction charges and other securities at nominal transaction charges. The commissions and/or transaction fees charged by Fidelity may be higher or lower than those charged by other broker-dealers. You may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction. Not all advisers require their clients 13  to direct trades to a particular broker. By requiring that your transactions be placed with Fidelity, we may be unable to achieve the most favorable execution of your transactions and this practice may cost you more money. We will periodically review our brokerage arrangement in light of our duty to obtain best execution for your transactions. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer's services, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while we will seek competitive rates, we may not necessarily obtain the lowest possible commission rates for client transactions. The receipt of investment research products and/or services as well as the allocation of the benefit of such investment research products and/or services poses a conflict of interest. We may receive from Fidelity, without cost to our firm, computer software and related systems support, which allow us to better monitor your accounts maintained at Fidelity. We may receive the software and related support without cost because we render investment management services to clients that maintain assets at Fidelity. The software and related systems support may benefit our firm, but not you directly. In fulfilling our duties to you, we endeavor at all times to put your interests first. You should be aware, however, that our receipt of economic benefits from a broker-dealer creates a conflict of interest since these benefits may influence our choice of broker-dealer over another broker-dealer that does not furnish similar software, systems support, or services. Additionally, we may receive the following benefits from Fidelity through the Fidelity Institutional Wealth Services Group: receipt of duplicate client confirmation and bundled duplicate statements; access to a trading desk that exclusively services its Institutional Wealth Services Group participants; and access to an electronic communication network for client order entry and account information. Block Trades We do not combine multiple orders for shares of the same securities purchased for advisory accounts we manage (the practice of combining multiple orders for shares of the same securities is commonly referred to as "aggregated trading" or "block trading"). Accordingly, you may pay different prices for the same securities transactions than other clients pay. Furthermore, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than other clients. Item 13 Review of Accounts For those clients to whom we provide discretionary and non-discretionary investment management services, we monitor portfolios and security positions on a regular basis as part of an ongoing process. You are encouraged to regularly discuss your needs, goals, and objectives with your Advisor, and to keep us informed of any changes in information or your financial state. All personal discretionary and non-discretionary client relationships are subject to a comprehensive annual review with the intent of determining whether there have been any notable changes in your goals, risk appetite, or financial situation, and to discuss the potential impact they may have on your current investment objectives. We will contact you at least annually regarding the need for this review. Additional reviews may be conducted at your request, or based on various circumstances, including, but not limited to, contributions and withdrawals, year-end tax planning, market moving events, security specific events, and/or changes in your risk/return objectives. 14  Also, at your request, we will provide you with a written report containing relevant account and/or market-related information such as inventory of account holdings and account performance. Please note: these reports use trade date when measuring performance. For books and records purposes, please refer to account statements provide by the Qualified Custodian. Item 14 Client Referrals and Other Compensation Our firm maintains an arrangement to pay compensation to certain employees for successfully onboarding new clients and/or assets. The compensation is for a limited period and is based on a percentage of projected annual fees. MWM does not pay any compensation to related or outside parties for receiving referrals. Item 15 Custody Deduction of Fees As paying agent for our firm, your independent custodian will directly debit your account(s) for the payment of our investment advisory fees for accounts we manage on a discretionary or non- discretionary basis. We are deemed to have custody of your assets only because we have the ability to deduct our advisory fees from your account. Other than the deduction of advisory fees, we do not deduct any other fees from, nor have physical custody of, any of your funds and/or securities. Your funds and securities will be held with an independent, qualified custodian. (I) We will only deduct fees as provided by your written authorization as granted through signing our advisory agreement; (II) You will receive account statements from the independent, qualified custodian(s) holding your funds and securities no less than quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. If you have a question regarding your account statement or if you did not receive a statement from your custodian, please contact us using the details found on the cover page. Standing Letter of Authorization An adviser with authority to conduct third-party transfers has access to the client's assets and therefore has custody of the client's assets in any related accounts. Transfers to one or more third parties may be effected by our firm and its associated persons, only after the client has provided the account custodian written authorization to do so, otherwise client signature will be required for each individual transaction. Such written authorization is known as a Standing Letter of Authorization (SLA) or Standing Payment Instruction (SLI). Because MWM has the ability to conduct third-party transactions for certain clients, we are considered to have custody. However, we do not have to obtain a surprise annual audit for these accounts, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria: 1. You provide a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian; 2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the 15  address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Trustee Services Mascoma Bank, an affiliate of Mascoma Wealth Management, serves a Trustee to certain accounts for which MWM provides investment advisory services. Our firm is deemed to have custody of accounts for which Mascoma Bank serves as Trustee as those employees' acting in the capacity of Trust Officer for Mascoma Bank's Trust Department are related persons of MWM. These accounts are held with a bank, broker-dealer, or other qualified custodian. You should carefully review account statements for accuracy. MWM complies with the SEC's Custody Rule for the trustee services described above. Annually, the Firm is subject to a Surprise Examination by an independent accountant for these accounts. Item 16 Investment Discretion If your account is managed on a discretionary basis, you grant our firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain reasonable conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. These requests must be provided to us in writing. We may also manage advisory accounts on a non-discretionary basis, meaning specific client instruction must be granted prior to each transaction. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Item 17 Voting Client Securities We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. Item 18 Financial Information Our firm does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. 16