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Part 2A of Form ADV
MASECO LLP
The Kodak
11 Keeley Street
London
WC2B 4BA
United Kingdom
HTTP://WWW.MASECOPRIVATEWEALTH.COM
Part 2A of Form ADV: Firm Brochure
19 November 2025
This brochure provides information about the
qualifications and business practices of MASECO
LLP. If you have any questions about the contents
of this brochure, please contact:
marc.cane@masecopw.com
Tel: +44 (0) 20 7043 0455
The information in this brochure has not been
approved or verified by the United States Securities
and Exchange Commission (the “SEC”) or by any
state securities authority.
Additional information about MASECO LLP is also
available on the SEC’s website at:
www.adviserinfo.sec.gov. An investment adviser’s
registration with the SEC does not imply a certain
level of skill or training.
1 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 2 – Material Changes
Certain material changes have occurred since the last
updated brochure dated June 2024.
Changes to the executive management team.
In April 2025, Damian Barry, Patrick Adam Ronald Bowen,
Marc Simon Cane, Charles (Ollie) George Oliver Cutting,
Stephen Duffy Johnson, Cormac Ronan Aidan Naughten and
Kyle Daniel McClellan became Partners at MASECO LLP. In
October 2025, Adrian Edwards became a Partner at MASECO
LLP.
2 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 3 – Table of Contents
Item 1
Cover Page
Page 1
Item 2
Material Changes
Page 2
Item 3
Table of Contents
Page 3
Item 4
Advisory Business
Page 4
Item 5
Fees and Compensation
Page 6
Item 6
Performance-Based Fees and Side-by-Side Management
Page 7
Item 7
Types of Clients
Page 8
Item 8
Methods of Analysis, Investment Strategies and Risk of Loss
Page 9
Item 9
Disciplinary Information
Page 14
Item 10
Other Financial Industry Activities and Affiliations
Page 15
Item 11
Code of Ethics, Participation or Interest in Client Transaction and Personal Trading
Page 17
Item 12
Brokerage Practices
Page 18
Item 13
Review of Accounts
Page 19
Item 14
Client Referrals and Other Compensation
Page 20
Item 15
Custody
Page 21
Item 16
Investment Discretion
Page 22
Item 17
Voting Client Securities
Page 23
Item 18
Financial Information
Page 24
3 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 4 - Advisory Business
client’s circumstances in order to form a solid foundation for
investment recommendations.
About MASECO LLP
Wealth Planning will in general address any or all of the
following areas:
Tax & Cash Flow: Income and spending analysis and
planning for current and future years. We will also
illustrate the impact of various investments on a client’s
current income tax and future tax liability.
Personal: Family records, budgeting, personal liability,
estate information and financial goals.
MASECO LLP was established in 2008 and is an investment
advisory firm providing fee-based wealth management
services primarily for private clients based either in the US or
in the UK. It is a limited liability partnership established in the
UK (UK Companies House No. OC337650) and has its
registered office and principal place of business in the
UK. Joshua E. Matthews and James Sellon are the Managing
Partners and majority owners of MASECO LLP directly and,
in the case of Mr Matthews, through affiliated entities.
Education: Education IRAs, financial aid, state savings
in
and 529 plans, grants and general assistance
preparing to meet dependents continuing educational
needs through development of an education plan.
MASECO LLP is a Registered Investment Advisor with the
SEC. MASECO LLP, which uses the trading names of
MASECO Private Wealth and MASECO Institutional, is also
authorised and regulated by the Financial Conduct
Authority (FCA) in the United Kingdom.
Services offered by MASECO LLP
Death & Disability: Cash needs at death, income needs
of surviving dependents, estate planning and disability
income analysis.
Retirement: Analysis of current
strategies and
investment plans to help the client achieve his or her
retirement goals.
MASECO LLP (MASECO) offers Wealth Management,
including Financial Planning Services (“Private Wealth
Service” or “PWS”) for its clients. The PWS is designed for
clients with $1mm or more to invest.
A. Investment Management
Investments: Analysis of investment alternatives and
their effect on a client’s portfolio.
Wealth Transfer: Provide an assessment of the most
efficient estate planning strategies and outline ways to
efficiently pass on wealth based on individual needs,
objectives and priorities.
Charitable Giving:
If there are charitable giving
intentions, we can discuss available options and outline
effective ways to meet charitable goals.
MASECO manages discretionary and / or non- discretionary
portfolios on behalf of our clients. MASECO adopts a multi-
asset approach to portfolio construction creating a range of
risk-graded model portfolios which generally use
institutional asset class strategies to mirror the various sub-
asset classes that it believes are suitable for a particular
model portfolio. Funds are selected on the basis of various
criteria, such as management style, investment philosophy,
track record, investment objectives, portfolio composition,
risk management, portfolio construction and fees and
expenses.
time horizon,
liquidity needs,
include
is constructed primarily of, exchange
Each portfolio
traded funds (ETFs) and other pooled investment vehicles
but may also
individual equities (including
exchange-listed securities, securities and bonds (including
warrants, corporate debt securities, certificates of deposit,
municipal securities and United States governmental
securities).
Through personal discussion and a comprehensive
information gathering process, MASECO establishes a
client’s attitude to risk and capacity for loss, their goals,
objectives,
income
requirements and investment needs and by using the
information gathered, MASECO determines which of its
model portfolios or tailored portfolio is best suited to meet
those individual and multiple needs. It may be in certain
circumstances that MASECO suggests either making
modifications to a portfolio (create a bespoke portfolio) or
recommend the portfolio allocation is spread between two
or more accounts if this means it can more effectively
achieve the required outcome.
included within their
Whilst each portfolio is designed to achieve a particular goal
and the investments within the portfolio are in turn selected
to help achieve that goal, clients are given the opportunity
to place reasonable restrictions on the types of investments
to be
individual account. Clients
retain beneficial ownership of all portfolio securities.
When portfolios have been determined, MASECO provides
the client with an Investment Policy Statement (IPS) that
outlines its recommendation. MASECO then manages the
portfolio(s) in accordance with the mandate described in the
IPS.
investment
the
assets
accordance with
MASECO regularly monitors the underlying securities in
client accounts and rebalance portfolios as necessary. If
is required, for
MASECO believes that a reallocation
example, that a particular
is performing
inadequately, or that a different investment may be more
appropriate, it may recommend a different investment and
reinvest
the
in
discretionary/non- discretionary authority granted by the
client.
B. Wealth Planning
In order to ensure that MASECO’s initial recommendation of
an appropriate portfolio continues to be suitable on an
ongoing basis and that the account continues to be
managed in a manner fitting the client’s circumstances,
MASECO maintains up-to-date client suitability information
by scheduling a client review at least once a year. MASECO
also gathers information on vulnerable clients to ensure that
any vulnerable clients are treated fairly and are provided
with the correct service level.
Wealth Planning is part of MASECO’s Private Wealth Service
and is designed to provide MASECO with a holistic view of the
4 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
MASECO asks clients, on an annual basis, to confirm that
their circumstances have not changed to ensure that the
portfolio remains suitable. MASECO requests prompt
notification from clients of any material changes in their
financial circumstances in the meantime that may affect
their position.
MASECO does not provide custody services and at no time
will it accept or maintain custody of a client’s portfolio or
account. MASECO will introduce clients to a non-affiliated
third-party platform provider who will be responsible for the
safe-keeping and administration of the client’s account.
The client is responsible for all custodian and execution fees
charged by the platform and executing broker/dealer.
C. Amount of managed assets
As of 31 March 2025, MASECO managed $2,800,952,295 of
clients’ assets on a discretionary basis and $1,233,891,442
on a non-discretionary basis.
5 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 5 - Fees and Compensation
and a possible distribution fee. If the fund also imposes sales
charges, a client may pay an initial or deferred sales charge.
MASECO charges its fees on the basis of the sliding scale set
out below. Whilst MASECO believes its fees to be
competitive, clients should be aware that lower fees for
comparable services may be available from other sources.
First $500,000
1.25%
$500,001 - $1,000,000
1.00%
A client could invest in a fund directly without MASECO’s
services. In that case, the client would not receive the
services provided by MASECO which are designed, among
other things, to assist the client in determining which fund
or funds are most appropriate to each client’s financial
condition and objectives.
$1,000,001 - $2,500,000
0.90%
$2,500,001 - $5,000,000
0.80%
Over $5,000,001
0.70%
Private Wealth Service Fees
Accordingly, the client should review both the fees charged
by the funds and the fees charged by MASECO to understand
fully the total amount of fees to be paid by the client and to
thereby evaluate the advisory services being provided. Fees
and charges levied by the platform or custodian selected by
the client are charged separately to the client’s account.
Such fees may
limited to, any
include, but are not
transaction charges, fees for duplicate statements and
transaction confirmations, and fees for electronic data feeds
and reports.
Each client’s fee schedule is agreed on a client-by-client
basis dependent on various factors including the size of
portfolio and will typically fall within the ranges provided
above.
Clients are also responsible for the charges imposed by
broker dealers for the execution of trades on their behalf.
Clients should refer to the Schedule of Fees and
Commissions for further information.
The specific annual fee schedule will be identified in the
contract between MASECO and each client. A minimum of
$1,000,000 of assets under management
is generally
required for this service. This minimum account size may be
negotiable under certain circumstances.
Different fees and charges will apply for non-US resident
clients. Details are available upon request.
We may group certain related client accounts (household)
for the purposes of achieving the minimum account size and
determining the annualized fee.
The firm uses testimonials regarding its services which it
receives from its clients. It does not make any payments in
return for such testimonials.
For all accounts, an annual Account Maintenance fee of
$50/£50/€50 (plus VAT, where applicable) will be applied.
Except in certain cases, such as 529 Plans, where MASECO
may invoice the client directly, client accounts will be
directly debited, as authorised, in advance at the beginning
of each calendar quarter based upon the value (market
value or fair market value in the absence of market value) of
the client’s account at the end of the previous quarter.
The firm participates in industry award programmes relating
to the provision of its investment services in connection
therewith the firm may be required to pay an administration
fee for the submission of its application. Where such
payments are made, they will be nominal in value and will
not be in exchange for any form of guarantee or promise
that the firm will receive the award for which it has applied.
The firm only participates in award programmes where
there is an independent panel of judges.
There is a minimum quarterly fee of £1,875 /€1,875/ $1,875
(plus VAT, where applicable). This fee is payable in advance.
Please refer to Item 12 of this brochure for additional
information regarding brokerage practices.
General information
Termination
Negotiability of Fees
In exceptional circumstances, fees may be negotiated.
A client agreement may be cancelled at any time, by either
party, for any reason upon receipt of written notice to the
other party. As disclosed above, certain fees are paid in
advance of services provided.
MASECO reserves the right to adjust the fee schedule for
accounts depending on the size and type of account and the
services required. In some cases, negotiation of fees may
result in different fees being charged for similar services and
may be less than the stated fees.
Upon termination of any account, any prepaid, unearned
fees will be promptly refunded to the client. In calculating a
client’s reimbursement of fees, MASECO will pro rate the
reimbursement according to the number of days remaining
in the billing period. Clients always have the right to
terminate an agreement without penalty within five
business days after entering into the agreement.
family members and personal
In addition, certain
acquaintances of MASECO’s affiliated persons may receive
advisory services at a discounted rate which is not available
to advisory clients generally.
Other Fees and Expenses
All fees paid to MASECO for investment advisory services are
separate and distinct from the fees and expenses charged by
the collective investment schemes, such as Exchange Traded
Funds (ETFs), in which MASECO invests its clients’ portfolios.
In the case of mutual funds, these fees and expenses are
described
in each fund’s prospectus. These fees will
generally include a management fee, other fund expenses,
6 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 6: Performance-Based Fees and Side-by-Side
Management
MASECO does not charge performance-based fees.
7 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 7: Types of Clients
MASECO provides advisory services primarily to individuals,
including high net worth individuals, as well as trusts,
estates and charitable organizations.
For the purposes of the rules of the UK’s Financial Conduct
Authority, MASECO is required to classify its clients as either
Retail Clients or Professional Clients.
The client
classification determines the type of service MASECO is able
to provide the client, the way in which it is provided (for
example, the frequency of certain reports) and the level of
protection afforded to the client under the UK regulatory
system. In general, we classify our clients as Retail Clients,
which affords clients the highest level of protection under
the UK regulatory system. Due to regulatory constraints in
the UK, currently MASECO may only provide a discretionary
service level for a client who has been classified as a Retail
Client and whose investment portfolio will hold shares in
collective investment schemes which are not regulated by
the UK FCA, such as US Mutual Funds.
Before MASECO provides the Private Wealth Service, each
client is required to enter into a written agreement setting
forth the terms and conditions under which MASECO
provides its services.
As previously disclosed in Item 5 of this Brochure, MASECO
generally imposes a minimum account balance requirement
of $1,000,000 for its Private Wealth Service, however,
MASECO may, at its discretion, accept accounts below the
minimum required amount.
8 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 8: Methods of Analysis, Investment Strategies and
Risk of Loss
Methods of analysis and associated risks
key determinant to the overall risk of a portfolio and its
performance outcome. The risks which apply to a particular
risk-graded model portfolio or specific transaction are set
out in the IPS sent to the client. These include:
General Risks
Performance of returns – Volatility
MASECO selects investments based on its investment
philosophy, which is grounded in academic evidence and
theory. In short, MASECO’s approach to portfolio design is
systematic driven by empirical evidence and investment
theory.
MASECO holds a number of enduring convictions that form
the basis of our investment philosophy, which guide the
decisions it makes on behalf of its clients.
The value of investments and the amount of income derived
from them may go down as well as up. All investments can
be affected by a variety of factors, including macro-
economic market conditions such as the
interest or
exchange rate environment, or other general political
factors in addition to more company or investment specific
factors.
Generally, asset classes that are backed by theoretical or
empirical support and which have a solid rationale for
inclusion are included in MASECO’s portfolios.
Liquidity and non-readily realisable securities
The high-level criteria used in the selection of MASECO’s
asset classes are described below.
Economic rationale
Asset classes where returns are understood and are, in an
economic sense, expected, are favoured over asset classes
where manager skill is required to deliver all or some of the
return.
Useful data insight
Long and clean data series provide the best insight available
for establishing the likely characteristics of an individual
asset class.
Adequate rewards
Identification of the expected return for each asset class is
considered with respect to the incremental risks being
taken on, compared to other alternatives.
Portfolio contribution
Some investments may be very illiquid, meaning that they
are infrequently traded, and so it may be difficult to sell
them on within a reasonable timeframe or at a price which
reflects “fair” value. In stressed market conditions the ability
to liquidate from a fund may be subject to certain fund
restrictions. Likewise exchange traded securities, like shares
or ETFs, are subject to additional risks that do not apply to
conventional mutual funds, including the risks that the
market price of an ETF’s shares may trade at a premium or
discount to its net asset value, an active secondary trading
market may not develop or be maintained, or trading may
be halted by the exchange in which they trade, which may
impact an ETF's ability to sell its shares. Shares of any ETF
are bought and sold at market price (not NAV) and are not
individually redeemed from the ETF. In extreme cases, an
investment may be non-readily realisable. This means that
the investment is neither a government security, nor a listed
investment, nor an investment that regularly trades on an
exchange. In this case there may be no secondary market
available, and it may be difficult to obtain any reliable
information about the value and risks
independent
associated with such an investment.
Asset classes that are likely to perform the task assigned to
them within the portfolio are favoured over those which, on
their own, may seem like viable portfolio choices.
Investment leverage, or gearing
Robust products
Use of borrowing to invest increases both the volatility and
the risk of an investment. This applies if a company has
significant borrowings, or if an investment vehicle otherwise
allows an investor to gain much greater economic exposure
to an asset than is paid for at the point of sale. It also applies
if an investor borrows money for the specific purpose of
investing. The impact of leverage can be as follows:
Well understood vehicle structures are preferred. MASECO
looks to allocate capital to funds or ETFs with high liquidity
and direct holdings in underlying securities, rather than
derivative exposure. In the event that robust tax efficient
products are not available, decisions will be made on the
risk/reward assessment between the benefits of holding
exposure to certain risk factors and the costs of owning less
robust or actively managed products.
Movements in the price of an investment leads to much
greater volatility in the value of the leveraged position,
and this could lead to sudden and large falls in value;
Governance budget
The impact of interest costs could lead to an increase in
any rate of return required to break even; or
Each asset class will be considered in the context of the skills
sets, knowledge, time, access and resource available to
manage it effectively over time.
A client may receive back nothing at all if there are
significantly large falls in the value of the investment.
Dimensions of risk
Foreign exchange
All investment strategies involve risk. No assurance or
guarantee can be given regarding the performance of a
particular investment strategy.
Investments denominated in foreign currencies open up
additional risks related to the relevant exchange rate.
to
fluctuate either
in a
MASECO’s clients’ portfolios are exposed to various
investment as well as operational and market risk.
Understanding, monitoring and managing those risks is a
Movements in exchange rates may cause the value of an
investment
favourable or
unfavourable manner.
9 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Legal obligations and tax affairs
decline in the value of its position, a loss of income and
possible additional costs associated with asserting its rights.
Emerging Markets Risks and Political and Economic Risks
Clients have sole responsibility for the management of your
legal obligations and tax affairs including making any
applicable filings and payments and complying with any
applicable laws and regulations.
Where a portfolio invests in funds with exposure to
emerging markets or increased political or economic issues,
the risk to the performance of the Fund could be greater.
Diversification Risk
Investing in a small number of assets or in only one asset
class or only one market exposes an investor to the risk that
these assets under perform. Investing in a broader range of
investments can help to mitigate some of this risk.
We have not, and will not, provide clients with tax or legal
advice and we recommend that clients obtain your own
independent tax and legal advice tailored to their individual
circumstances. The tax treatment of investment products
can be complex, and the level and basis of taxation may alter
during the term of any product. Clients should therefore
obtain professional tax advice appropriate to your own their
circumstances before investing.
Manager Risk
Investment specific risks
Investing in funds
There is the risk that the Fund manager the client invests
with or the appointed investment manager may not perform
according to the client’s expectations.
Market Risk
Investment Funds can generally effectively reduce the risk of
being exposed to a single security, by investing in a portfolio
of securities, thereby reducing the impact of a poor
performance by any single security.
Market risk is the risk of investing in a market which may
decline in value. Where a Fund is exposed to a single country
market, this risk may increase.
Regulatory Risk
However, all investments involve varying degrees of risk.
There is a risk that after you have invested in a Fund the
value of its underlying investments may fall overall. If that
occurs the Fund’s unit price will also fall to reflect the lower
value of the underlying investments.
If clients were to sell (redeem) their investment in that Fund
at that time you may incur a loss. In other words, they may
receive back less than they initially invested.
Where Funds are domiciled in other jurisdictions, the
regulatory protections provided by the local regulatory
authorities may not apply. Conversely, Funds may be subject
to more restrictive regulatory regimes which may prevent
the Fund from making the fullest possible use of investment
limits.
Security Risk
impact on the
There are many factors, which may
performance of a Fund. The risks that apply will largely be
determined by the asset class you invest in, and the
selection of investments the manager makes. These risks
include, but are not limited to:
Securities may perform differently. The individual securities
selected for a Fund will ultimately determine its risk level
and performance.
Closed End Fund Risk
Suspension of Share Class Dealing
Investors are reminded that in certain circumstances their
right to redeem from or switch Funds may be suspended.
Fees and Funds Investing in Other Investment Funds
A Closed-End Fund is a Fund that issues a limited amount of
shares/units and is valued typically like an individual share
on a stock-exchange. The Fund is not required to buy back
shares directly from investors. Closed-end Funds may be
allowed to invest in illiquid underlying investments (this
means the underlying investment may not be realisable
within 7 days).
A Fund incurs costs of its own, comprising the fees paid to
the Management Company and other service providers. It
should be noted that, in addition, where such a Fund invests
in other Funds, it incurs similar costs as these Funds in turn
pay similar fees to their manager and other service
providers.
Investment Funds may
Shares/Units can only be sold if there are buyers, they can
only be bought if there are sellers willing to sell. So a
proposed transaction may not occur. This could mean that
in times where an investor needs to raise monies, this may
not be possible. Likewise, as the price of these shares is
determined by both supply and demand, an investor may
not get the expected price (shares may trade at discount or
premium to the net asset value (NAV) of the funds).
Overall, this means that investors may not be able to
liquidate their holdings on request.
Furthermore, the investment strategies and techniques
employed by certain
involve
frequent changes in positions and a consequent portfolio
turnover. This may result in brokerage commission expenses
which exceed significantly those of other Investment Funds
of comparable size. Investment Funds may be required to
pay performance fees to their manager.
Counterparty Risk
Funds may enter into contracts that entail a credit exposure
to certain counterparties. To the extent that a
counterparty defaults on its obligation and the Fund is
delayed or prevented from exercising its rights with respect
to the investments in its portfolio, it may experience a
Under these arrangements the managers will benefit from
the appreciation, including unrealised appreciation of the
investments of such Investment Funds, but they may not be
similarly penalised for realised or unrealised losses. As a
consequence, the direct and indirect costs borne by a Fund
investing in Investment Funds are likely to represent a
higher percentage of the Net Asset Value than would
10 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
typically be the case for a Fund which invests directly in the
relevant underlying investments (and not through other
Investment Funds).
common use of a bond is to provide a reliable yield, or
source of income until maturity. For example, the value of a
bond can be adversely affected by a number of factors, such
as:
These are just some of the risks that are associated with an
investment in Funds. Individual Funds will have their own
individual risks. It is critical that clients understand the effect
that these risks can have on their investments and review
the relevant Fund Documentation that we supply to you.
The issuer’s credit rating, which reflects their ability to
repay the amounts payable when they fall due; The
market expectations about future interest and inflation
rates;
Investing in equity securities
Amount of interest payable (the coupon);
The length of time until the debt falls due for repayment;
or
The seniority of a bond within the capital structure of a
company, and the quality of any security available.
The factors which are likely to have a major impact on
the value of a bond are the perceived financial position
of the issuer and changes to market interest rate
expectations.
Ownership of an equity security represents a direct stake in
the company concerned. Such an investment will participate
fully in the economic risk of the company and its value can
therefore fall as well as rise. The price volatility of equity
markets can change quickly and cannot be assumed to
follow historic trends.
In adverse market conditions,
irrecoverable capital losses could be incurred. In the worst
case, a company could fail and, if this happens, its equity can
become worthless. Equity securities are commonly used by
investors seeking longer term capital growth. Examples of
typical company characteristics which could heighten equity
investment risks are:
A low market capitalisation;
A product set that is undiversified or reliance on single
markets as a major source of income;
Bonds issued by major governments or supranational bodies
tend to be lower risk investments, while the risks of other
debt securities (such as those with emerging market or
corporate issuers) can vary greatly. For example, if an issuer
is in financial difficulty, there is an increased risk that they
may default on their repayment obligations. In this event,
little or no capital may be recovered.
A significant reliance on borrowing as a source of
finance;
Additional risks specific to investing in portfolios which
adopt a Low Carbon Centric Strategy
A significant level of fixed costs to pay, irrespective of
output, production or turnover levels;
Major income sources which are seasonal “cyclical” in
nature; and
Companies trading primarily
in emerging markets,
particularly during poor market conditions, or
in
countries where legal property rights may be difficult to
enforce.
The equity of some smaller companies may trade in very
small sums per share, and an investment into this kind of
equity will usually involve a proportionately large difference
between the market buying and selling price. The effect of
this difference means that an immediate sale may realise
significant losses.
MASECO offers clients model portfolios which have a tilt
towards companies with lower than industry average carbon
emissions if clients express their interest in this area. Such
Low Carbon Centric (LCC) looks at all major sectors,
emphasising investment in companies with low carbon
emission metrics and minimising or excluding investment in
companies with high metrics, the portfolio may forego
certain
Such
investment opportunities as a result.
portfolio’s performance results may be lower than other
portfolios that do not seek to invest in issuers based on LCC
characteristics or that use different criteria when screening
out particular companies and industries. There may be
limitations with respect to the readiness of LCC data in
certain sectors, as well as limited availability of investments
with relevant LCC characteristics in certain sectors. While
MASECO views LCC considerations as having the potential to
contribute to a portfolio’s long-term performance, there is
no guarantee that such results will be achieved.
Additional risks specific to investing in alternative income
funds
Fraud
Other smaller companies may not be subject to the rules of
a listing authority. Such companies are likely to be high risk
ventures and may have an unproven trading history or
management team. These equity shares may not be readily
sold, and it could be difficult to realise or to value them
independently due to the lack of a secondary trading
market.
Such
inaccuracy or
The risks involved in equity investment can often be
managed through investment via diversified investment
vehicles, or by investing directly in a wide range of different
companies, industries, countries and currencies.
Investing in debt securities and fixed income
A primary concern in relation to loans is the possibility of
material misrepresentation or omission on the part of a
borrower.
incompleteness may
adversely affect the valuation of the collateral underlying
the loans or may adversely affect the likelihood that a lien
on the collateral securing the loans has been properly
created and perfected. Under certain circumstances,
payments to a portfolio may be reclaimed if any such
payment or distribution is later determined to have been
made with intent to defraud or prefer creditors.
Competition Risk
The value of debt investments (or “bonds”) can generally be
expected to be more stable than that of equity investments.
However, in some circumstances, particularly when interest
rate expectations are changing, the value of most bonds will
fluctuate (they could go down as well as up). The most
11 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
focus on developing diversified portfolios, principally using
asset class specific funds that are available only to
institutional investors and clients of a network of selected
investment advisors.
The credit industry and the varied strategies and techniques
to be engaged in are extremely competitive and each
involves a degree of risk. The competition for investment
opportunities may result in a downward pressure on yields,
and generally affect the terms of the investments. Such
competition may also prevent finding enough attractive
investments to meet their investment objectives.
Credit Quality Risk
A risk of asset allocation is that the client may not participate
in sharp increases in a particular security, industry or market
sector. Another risk is that the ratio of securities, fixed
income, and cash will change over time dependent on stock
and market movements and, if not corrected, will no longer
be appropriate for the client’s goals.
investors will receive timely
Clients may come to us with legacy assets that do not fit
within our normal core investment strategy.
In these situations, we will work with the client to formulate
a wealth/financial plan that may require the sale of legacy
assets in order to bring the client’s portfolio in line with our
portfolios over time.
The higher the credit quality of the borrower, the higher the
probability that
interest
payments and principal repayments. Conversely, the lower
the credit quality of the borrower, the higher the risk of a
delay or default on interest payments and the greater the
risk of a loss of principal. Performance depends upon
correctly assessing the credit quality of the underlying
borrower. It cannot guarantee that credit analysis will be
accurate.
High Yield Risk
Tax consequences as well as suitability play a paramount
role in deciding when and which assets are sold.
Long-term purchases
We purchase securities with the intention of holding them
in the clients account for a year or longer. We may do this
because we believe the securities to be currently
undervalued. We may do this because we want exposure to
a particular asset class over time, regardless of the current
projection for this class.
High yielding assets are considered speculative with respect
to the underlying borrower’s continued capacity to pay
interest and repay principal. Such assets are subject to a
greater risk of loss of principal and interest than higher-
grade assets. They are also generally considered to be
subject to greater risk in the case of deterioration of general
economic conditions. High-yield assets can be expected to
have a substantial rate of default. There can be no assurance
that the default rate across high yielding assets can be
accurately predicted.
The actual default rate may significantly exceed historical or
expected levels, resulting in lower returns or loss of
principal.
A risk in a long-term purchase strategy is that, by holding the
security for this length of time, we may not take advantage
of short-term gains and volatility that could be profitable to
a client. Moreover, if our expectations are incorrect, a
security may decline sharply in value before we make the
decision to sell.
Risk relating to the timing of loan payments
Clients should be aware that investing in securities carries
with it the risk of loss and therefore clients should also be
prepared and able to bear a loss.
For a more detailed description of the nature and risks of
investments which may be included in a client’s portfolio,
please refer to our Terms of Business.
Some of the assets that are not repaid at a fixed maturity but
as a function of certain event; for example, the pay out from
an insurance policy or the settlement of a litigation. The
profitability of such assets can depend on the timing of the
actual repayment, and the risks relating to the payment of
interest, funding of premiums and other on- going costs can
increase.
Technology and Cybersecurity Risk
Risks for all forms of analysis
and
availability
of
its
computer
Our securities analysis method relies on the assumption that
the companies whose securities we purchase and sell, the
rating agencies that review these securities, and other
publicly- available sources of information about these
securities, are providing accurate and unbiased data. While
we are alerted to indications that data may be incorrect,
there is always a risk that our analysis may be compromised
by inaccurate or misleading information.
Investment strategies and associated risks
Asset Allocation
result
corruption or
MASECO
is dependent on the effectiveness of the
information and cybersecurity policies, procedures and
capabilities it maintains to protect the confidentiality,
integrity
and
telecommunications systems and the data that resides on or
is transmitted through them.
An externally caused
information security
incident, such as a cyber-attack
including a phishing scam, malware or denial-of-service
attack or an internally caused incident, such as a failure to
control access to sensitive systems, could materially
interrupt business operations or cause disclosure or
modification of sensitive or confidential client or proprietary
MASECO’s use of mobile and cloud
information.
technologies could heighten these and other operational
risks as certain aspects of the security of such technologies
may be beyond MASECO’s control. A failure to adequately
safeguard MASECO’s systems and prevent cyber-attacks
in
could disrupt MASECO’s operations and
misappropriation,
loss of personal,
confidential or proprietary information. Although MASECO
Rather than focusing primarily on securities selection, we
attempt to create value by combining different asset classes
in different proportions appropriate for each risk-graded
model portfolio. Through the information provided by
clients and our assessment of their investment objectives,
financial requirements, attitude to risk, investment time
horizon and capacity for loss, we determine the model
portfolio we believe is best suited to the client. As such, we
12 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
has implemented policies and controls and takes protective
measures to strengthen its computer systems, processes,
software and technology to prevent and address potential
data breaches, inadvertent disclosures, cyber-attacks and
cyber-related fraud, there can be no assurance that these
measures prove effective.
In addition, due to MASECO’s interconnectivity with third
party vendors, MASECO may be adversely affected if any of
them are subject to a successful cyber-attack or other
information security event.
MASECO also routinely
transmits and receives personal, confidential or proprietary
information by email and other electronic means. MASECO
collaborates with clients, vendors and other third parties to
develop secure transmission capabilities and protect against
cyber-attacks however MASECO cannot ensure that it or
such third parties have all appropriate controls in place to
protect unauthorised access to such information.
Any information security incident or cyber-attack against
MASECO may cause disruption and
impact business
operations, potentially resulting in financial losses, the
inability to transact business, breaches of applicable privacy
and other laws, regulatory fines and/or sanctions, breach of
client contracts, reputational harm
13 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 9 - Disciplinary Information
Neither MASECO nor its management personnel have any
reportable disciplinary events to disclose.
14 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 10 - Other Financial Industry Activities and Affiliations
individual engaged
MASECO’s officers and employees endeavour at all times to
act in the client’s best interests pursuant to our fiduciary
duty. However, conflicts of interest may arise in the course
of providing our Private Wealth Service. Clients should be
aware that the receipt of additional compensation itself
creates an inherent conflict of interest and may affect the
in making
judgment of any
recommendations, consciously or not. MASECO will take all
steps necessary to ensure that conflicts of interest are
identified and managed in order to give the best outcome to
clients.
MASECO’s Investment and Product Governance Committee,
of which Messrs. Matthews and Sellon are members,
reviews and considers, amongst other things, the collective
investment schemes in which its clients’ portfolios will invest
or which will be recommended to clients. The conflict of
interest which arises due to Messrs. Matthews and Sellon
interests in MAM
is managed through a number of
measures, including requiring Messrs. Matthews and Sellon
to recuse themselves from any discussions in the Investment
and Product Governance Committee regarding the Funds
managed by MAM and disclosing the specific conflict of
interest clearly and in writing to clients before they invest
and by requiring that clients confirm in writing that they
understand and accept the conflict of interest.
Certain associated persons of MASECO, in their separate
capacities as licensed insurance agents or brokers of various
insurance companies, are able to recommend and purchase
insurance products for MASECO clients.
Insurance contracts with an investment element
Mr. Matthews and Mr. Sellon own, in aggregate, 50% of
MASECO Asia Limited (“MASECO Asia”). MASECO Asia is a
firm based in Hong Kong and is regulated by the Hong Kong
Securities and Futures Commission and is registered with
the SEC as a Registered Investment Advisor. It provides
wealth management services to clients based in the Asiatic
region. MASECO has considered any conflicts of interest that
could arise from Mr. Matthews and Mr. Sellon’s ownership
of MASECO Asia. The firm may refer clients to MASECO Asia
where it is not authorised to provide investment services in
the client’s home jurisdiction, but MASECO Asia is and vice
versa. In addition, the firm provides administrative services
for MASECO Asia pursuant to a written agreement
negotiated on commercial terms in respect of which the firm
receives some compensation but not material in the context
of its overall revenue.
Other than the referral of clients between the parties and
the provision of administrative services, the firm has no
other business dealings with MASECO Asia and does not
share premises with MASECO Asia. Accordingly, the firm
believes that its business relationship with MASECO Asia
does not create a conflict of interest with its clients.
In most but not all cases, recommended investment- related
Insurance contracts (e.g., variable life insurance, variable
annuity contracts) will be limited to those products offered
by a single
insurer based on our evaluation of the
investment options available within the products and the
access permitted to manage the investments within the
account after receiving appropriate approvals and authority
from the client. If granted the authority to manage the
client’s assets within the insurance product, we will charge
a non-refundable one-time fee to cover the
initial
arrangement and administration costs when the policy
commences and an ongoing management fee thereafter in
the same manner and in accordance with the same fee
schedule agreed to with the client for managing other
investments in the client’s portfolio.
The client’s insurance product assets will be aggregated with
existing portfolio investments for fee charging purposes and
where possible, on a household basis. In addition to the
MASECO fees, the insurer will also charge fees.
Mr. Scher and Mrs. Scher are directors of MASECO Asia. In
this capacity they perform certain statutory duties for
MASECO Asia. They also provide wealth management
services to clients of MASECO Asia in connection with which
they receive remuneration.
MASECO has considered
whether their involvement in providing investment services
for MASECO Asia as well as the firm creates a conflict of
interest in that these individuals may act in preference to
MASECO Asia rather than the firm.
Typical fees charged by the insurer will be Mortality and
Expense (M&E) fees, underlying cost of the funds to be held
within the portfolio and in some instances for certain
annuity contracts the insurer will include a basis points fee
(bps) (currently c10bps) for the guaranteed death benefit.
As the clients of MASECO Asia are in jurisdictions where the
firm is unable to operate, the firm believes that the conflict
of interest is appropriately managed.
The M&E and other associated costs will be product specific
and will be detailed in the product prospectus/buyer’s
guide.
Clients should be aware that the layering of these fees into
the policy will affect underlying performance.
Insurance contracts without an investment element
Members of MASECO’s Investment and Product Governance
Committee, may, in their individual capacities and through
their pensions, make investments in investment-related
limited partnerships and/or collective investment schemes
in which they invest or may recommend an investment in
such limited partnerships or similar entities (hereinafter
“Investment Entities”) to clients of MASECO as part of a
client’s overall asset allocation.
For insurance contracts without an investment element i.e.
(term insurance protection long-term care), we will not
charge a fee but instead will receive commission from the
insurer. The amount, frequency, terms and details regarding
clawbacks on the policy for early termination will be clearly
disclosed to the client before any commitment is made.
Clients are not under any obligation to engage these
individuals when considering implementation of advisory
The
recommendations
for
insurance
products.
Mr Matthews’ family and Mr Sellon’s family each have a
trust of which they are beneficiaries (collectively, the
“trusts”). These trusts are owners of MASECO Asset
Management Limited (“MAM”), a company incorporated in
the Cayman Islands which acts as general partner and
investment advisor to two private fund of hedge funds.
15 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
implementation of any or all such recommendations is solely
at the discretion of the client.
16 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 11 - Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
is also available to the investing public on reasonable
inquiry. No person of MASECO shall prefer his or her
own interest to that of the advisory client.
MASECO provides its investment services in accordance with
its fiduciary obligations to its clients.
2. MASECO maintains a list of all securities holdings for
itself, and anyone associated with this advisory practice
with access to advisory recommendations. These
holdings are reviewed on a regular basis by the Chief
Compliance Officer of the firm.
MASECO has adopted a Code of Ethics which sets forth high
ethical standards of business conduct that we require of our
employees, including compliance with applicable federal
securities laws.
the client,
firm emphasizes
3. Except where MASECO has been granted discretionary
authority to act on behalf of the client without first
contacting
the
the
unrestricted right of the client to decline to implement
any advice provided.
MASECO and its personnel owe a duty of loyalty, fairness
and good faith towards its clients, and have an obligation to
adhere not only to the specific provisions of the Code of
Ethics but to the general principles that guide the Code.
MASECO’s Code of Ethics includes policies and procedures
for the review of quarterly securities transactions reports as
well as initial and annual securities holdings reports that
must be submitted by the firm’s access persons.
4. MASECO requires that all individuals act in accordance
with applicable Federal and State regulations governing
registered investment advisory practices.
5. Any individual not in observance of the above may be
subject to disciplinary action up to and including
termination.
Among other things, MASECO’s Code of Ethics also requires
the prior approval of any acquisition of securities in a limited
offering (e.g., private placement) or an initial public offering.
MASECO’s code also provides for oversight, enforcement
and recordkeeping provisions.
MASECO’s Code of Ethics further includes the firm’s policy
prohibiting the use of material non-public information.
While MASECO does not believe that it has any particular
information, all employees are
access to non-public
reminded that such information may not be used in a
personal or professional capacity.
A copy of MASECO’s Code of Ethics is available to its advisory
clients and prospective clients. Client’s may request a copy
by email sent to marc.cane@masecopw.com or by calling
the firm at +44 (0)20 7043 0455.
MASECO, and individuals associated with the firm, are
prohibited from engaging in principal or agency cross
transactions.
MASECO’s Code of Ethics is designed to assure that the
personal securities transactions, activities and interests of its
employees will not interfere with (i) making decisions in the
best interest of advisory clients and (ii) implementing such
decisions while, at the same time, allowing employees to
invest for their own accounts.
MASECO and/or individuals associated with the firm may
buy or sell for its proprietary or their personal accounts
securities identical to or different from those recommended
to its clients. In addition, any related person(s) may have an
interest or position in a certain security(ies) which may also
be recommended to a client. It is the expressed policy that
neither the firm nor any person employed by the firm may
purchase or sell any security prior to a transaction(s) being
implemented for an advisory account, thereby preventing
such employee(s) from benefiting from transactions placed
on behalf of advisory accounts.
As these situations present potential conflicts of interest,
MASECO has established the following restrictions in order
to ensure its fiduciary responsibilities:
1. No director, officer or employee of MASECO shall buy or
sell securities for their personal portfolio(s) when their
decision is substantially derived, in whole or in part, by
reason of his or her employment unless the information
17 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 12- Brokerage Practices
Private Wealth Service
distribute the units (in the case of purchases) over the
individual client accounts in accordance with the trade
requests.
Through the written agreement entered into between each
client and us, MASECO has the permission of its clients to
execute trades on their behalf in accordance with its Best
Execution Policy.
Non-discretionary client trades are authorized by the client
and executed by us in a timely manner in accordance with
the FCA’s Conduct of Business Sourcebook. The trades are
distributed to the trading team and all trades are conducted
on a first in first traded basis.
Typically, MASECO will route orders to the client’s platform
who will then execute the trade in the market in accordance
with their Best Execution Policy. MASECO will take all
sufficient steps to obtain the best possible result when
carrying out transactions for its clients taking into account a
number of execution factors (price, cost, speed, likelihood of
execution and settlement, size of the order, nature of the
order and any other relevant consideration).
For clients seeking an introduction to a firm which can
provide them with custody services, MASECO may introduce
the client to one of several custodians subject to its fiduciary
duty to the client. The factors MASECO considers when
making these recommendations are a custodian’s ability to
effect professional services,
its experience with the
custodian, reputation, strength, best execution policy and
costs of such services, among other factors as well as the
total consideration of the client’s needs. Based on these
criteria and the firm’s periodic brokerage reviews, MASECO
anticipates that it will recommend, and that a large number
of its client accounts will be custodied with, Pershing Advisor
Solutions LLC. Discretionary accounts will be traded by the
custodian following receipt of a trade request from us. Most
trades executed will be exchange traded securities, such as
Exchange Traded Funds (ETFs) and to a lesser extent US
Mutual Funds.
Trades generally may come about as a result of an ad-hoc
review, annual review or a portfolio rebalance.
A rebalance may be required following for example a
decision of the
Investment and Product Governance
Committee decision to do so.
Mutual Fund trades generated from an ad-hoc review or
annual review will be gathered by the firm throughout the
day and a bulk-trade is submitted to the custodian at the end
of the day.
The custodian in turn may aggregate these trades with those
of other clients on their books and submit to the fund
in bulk. Exchange Traded Funds (ETFs) are
company
generally traded on an individual basis at market.
possibility
of
individual
client
Where discretionary account trades are to be made as a
result of a portfolio rebalancing following a decision by the
Chief Investment Officer. Trades will be aggregated with
those of other clients (where possible) in order to counter
any
price
advantage/disadvantage in respect of positions where a
price variation may apply (for example ETFs, stocks and
other such exchange traded securities).
Individual client price variation is not the case in respect of
mutual funds and ETFs trades as on receipt of the bulk-trade
request from us, the custodian will allocate the mutual fund
or ETF trades across different mutual funds or ETF to be
traded altogether that day, which means that our clients will
be block traded by the custodian along with other of the
custodian’s clients. The custodian will, when executed,
18 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 13 - Review of Accounts
The underlying securities within model portfolios are
In addition, these positions are
regularly monitored.
reviewed at the Investment and Product Governance
Committee meetings at
least quarterly and by the
investment team on a weekly basis.
In addition, individual accounts are reviewed by the advisors
in the context of the strategy’s model parameters as well as
each client’s stated investment objectives and guidelines.
More frequent reviews may be triggered by material
changes
individual
in variables such as the client’s
the market, political or economic
circumstances,
environment.
Non-Discretionary Private Wealth Service
At all Progress Meetings the Wealth Manager will review the
client’s portfolios.
If trades are needed to be made the Wealth Manager will
discuss these trades with the client and assess the suitability
of the recommended trades. Once approved by the client,
MASECO will execute the trades. There is the potential for
the client to be disadvantaged because MASECO must
obtain the client’s approval prior to effecting investment
transactions on their behalf. In some instances, MASECO
may not receive consent from the client to such trades until
after MASECO’s discretionary accounts have finished
dealing. Therefore, non-discretionary clients may not
always benefit from aggregated orders, resulting in a delay
in arranging the deal and resulting in their accounts
receiving a price that potentially is less favourable than that
obtained for discretionary accounts. In addition, non-
discretionary retail clients are precluded from investing in
certain products that are available to discretionary clients.
As a result of these and other factors, the performance of
non-discretionary accounts can differ from (and be better or
worse than) the performance of discretionary accounts
following a similar investment strategy.
Discretionary Private Wealth Service
All portfolios will be reviewed for rebalancing twice a year to
ensure that portfolios are kept in line with the target
strategic asset allocation.
Clients will receive quarterly performance reports which
include a valuation of their portfolio and, where selected,
confirmations of transactions from their broker dealer and/
or custodian/platform.
MASECO will not provide clients with additional, regular
reports, however, significant changes, for example to a
client’s investment strategy, will generate a suitability
report setting out the rationale for any changes required.
19 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 14 - Client Referrals and Other Compensation
interest, MASECO has established the
Therefore, MASECO may be referred to a prospective client
even though its advisory services may not best suited to the
prospective client’s circumstances or when entering into an
advisory relationship with the firm is not, overall, in the best
interest of the client. As these situations represent a conflict
of
following
procedures to ensure that payments are only made in
compliance with the firm’s fiduciary responsibilities to its
US resident clients.
1. All such referral fees are paid in accordance with the
requirements of Rule 206(4)-3 of the
Investment
Advisers Act of 1940, and any applicable state securities
law requirements.
MASECO does not receive compensation from third parties
for providing investment advice to clients. However, where
permitted by applicable law and regulations and subject to
any requirements (including disclosure to clients) the firm
may from time to time receive certain reasonable non-
monetary benefits. For example, tickets to events, and
monetary benefits, such as the 12b-1 distribution fees as
disclosed at item 10 of this document, from financial firms.
MASECO’s internal procedures stipulate that any monetary
or non-monetary benefit offered to any employee, adviser,
partner or contractor must be declared and pre-approved by
Compliance and must comply with the terms of the MASECO
Inducements Policy.
MASECO’s Conflict of Interest Policy is also considered as
part of the Gifts and Corporate Hospitality clearance process
and if a conflict of interest is identified it is dealt with in
accordance with the policy rules and procedures, this could
mean that the proposed benefit is declined if accepting it
would not be in the firm’s clients’ best interests.
2. All such referral fees are paid in accordance with the
requirements of the rules of the FCA which require,
amongst other things, that any such payment is designed
to enhance the quality of the relevant service to the client
and does not impair compliance with the firm’s duty to
act honestly, fairly and professionally in the best interests
of the client.
3. Any such referral fee will be paid solely from the firm’s
investment management fee and will not result in any
additional charge to the client.
the
4. Where the solicitor is based in the US, MASECO will
confirm, at the time of the solicitation, that the solicitor
provided each prospective client with a copy of its Form
ADV Part 2 Brochure, together with a copy of the written
disclosure statement disclosing
terms of the
solicitation arrangement between the firm and the
solicitor, including the compensation to be received by
the solicitor from MASECO.
5. All referred clients will be carefully screened to ensure
that MASECO’s fees, services, and investment strategies
are suitable for their investment needs and objectives.
Subject to applicable law and regulations, MASECO may pay
referral fees to unaffiliated third parties (each a “solicitor”)
for referring advisory clients to the firm. With respect to
client solicitation arrangements, the Advisers Act requires
that, amongst other things, compensation to a solicitor is
made pursuant to a written agreement and that the solicitor
provides to each person solicited for MASECO, a written
disclosure statement (the ‘Solicitor’s Disclosure Statement’)
and this Brochure. The Solicitor’s Disclosure Statement
contains important information with respect to, amongst
other things, the material terms of the compensation
arrangement between the solicitor and the advisor, the
nature of the relationship, including any affiliation between
the solicitor and the advisor, whether the client bears any
costs with respect to the solicitation and whether the fees
paid by such a client may differ from fees paid by other
similarly situated clients who are not so introduced, as a
result of the solicitation and these Solicitor’s Disclosure
Statements should be reviewed carefully by prospective
clients.
for example,
Referral fees may be paid depending on the relationship
between the client and the solicitor. Where the solicitor
introduces a client to the firm but has no ongoing
relationship, MASECO may pay a one-off fee determined by
it by reference to the complexity of the client’s financial
situation,
the number of pension
arrangements, the number of existing investment portfolios,
the number of tax jurisdictions involved.
Where the solicitor introduces a client to MASECO and
provides ongoing continuous relevant services to the client,
as long as such services do not include investment advice,
the firm may compensate that solicitor an ongoing referral
fee based on a percentage of its annual management fee
revenue generated from the client’s assets managed by
MASECO for a maximum period of 3 years.
Where the solicitor introduces a client to MASECO and
provides ongoing investment advice, no referral fee is paid.
Payment of referral fees for client referrals creates a
potential conflict of interest to the extent that such a referral
is not unbiased, and the solicitor is, at least partially,
motivated by financial gain.
20 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 15 - Custody
MASECO does not have actual custody of any client’s
account. However, as disclosed in Item 5 of this brochure,
MASECO may directly debit its fees from client accounts as
authorized.
As part of the billing process, the client’s custodian is advised
by MASECO of the amount to be deducted and paid to the
firm in respect of its fees. The custodian then debits the
amount from the client’s account.
On at least a quarterly basis, the custodian is required to
send a statement to the client that shows all transactions in
the account during the reporting period.
important
Because the custodian does not calculate the amount of
the fee to be deducted, it is
for clients to
carefully review their custodial statements and to compare
the custodial statement against any statement provided by
us, to verify the accuracy of the calculation, among other
things.
Clients should contact the firm directly if he/she believes
that there may have been an error in the calculation of the
MASECO fee or any other information provided in the
statement/s.
21 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 16 - Investment Discretion
As disclosed in Item 4 of this brochure, MASECO offers its
services on both a discretionary and non-discretionary basis.
For clients granting discretionary authority, MASECO places
trades in the client’s account without contacting the client
prior to each trade, to obtain the client’s permission.
MASECO’s discretionary authority includes the ability to
carry out the following without contacting the client:
• Determine the security to buy or sell; and/or
• Determine the amount of the security to buy or sell.
Clients grant the firm discretionary authority by signing
MASECO’s discretionary agreement and may limit this
authority by giving MASECO written instructions. Clients may
also change/amend such limitations by providing the firm
with written instructions.
22 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 17 - Voting Client Securities
As a matter of firm policy, MASECO does not vote proxies on
behalf of clients.
Therefore, although MASECO may provide investment
advisory services relative to client investment assets, clients
maintain exclusive responsibility for: (1) directing the
manner in which proxies solicited by issuers of securities
beneficially owned by the client shall be voted, and (2)
making all elections relative to any mergers, acquisitions,
tender offers, bankruptcy proceedings or other type events
pertaining to the clients are responsible for instructing each
custodian of the assets, who forward to the client copies of
all proxies and shareholder communications relating to the
client’s investment assets.
Other Corporate Matters: MASECO will neither advise nor
act on behalf of the client in legal proceedings involving
in the clients
companies whose securities are held
account(s), including, but not limited to, the filing of Proofs
of Claim in class action settlements. If desired, clients may
direct MASECO to transmit copies of class action notices to
the client or a third party. Upon such direction, MASECO will
make commercially reasonable efforts to forward such
notices in a timely manner.
23 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
Part 2A of Form ADV
Item 18 - Financial Information
MASECO has no adverse financial circumstances to report.
Under no circumstances does the firm require or solicit
payment of fees in excess of $1,200 per client more than six
months in advance of services rendered. Therefore,
MASECO is not required to include a financial statement.
MASECO has not been the subject of a bankruptcy petition
at any time during the past sixteen years.
24 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025
enquiries@masecopw.com
enquiries@masecopw.com
25 | FORM ADV | © 2025 MASECO LLP. All rights reserved
November 2025