Overview
Assets Under Management: $350 million
High-Net-Worth Clients: 87
Average Client Assets: $5 million
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Clients
Number of High-Net-Worth Clients: 87
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 97.05
Average High-Net-Worth Client Assets: $5 million
Total Client Accounts: 439
Discretionary Accounts: 426
Non-Discretionary Accounts: 13
Regulatory Filings
CRD Number: 288215
Last Filing Date: 2024-02-02 00:00:00
Website: https://mayport.com
Form ADV Documents
Additional Brochure: MAYPORT FORMADV2A2B (2025-08-04)
View Document Text
Form ADV Part 2A – Disclosure Brochure
Effective: August 4, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Mayport, LLC (“Mayport Wealth Management” or the “Advisor”). If you have any questions about the
contents of this Disclosure Brochure, please contact the Advisor at (617) 545-5700.
Mayport Wealth Management is a registered investment advisor registered with the U.S. Securities and
Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified
by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific
level of skill or training. This Disclosure Brochure provides information about Mayport Wealth Management to
assist you in determining whether to retain the Advisor.
Additional information about Mayport Wealth Management and its Advisory Persons is available on the SEC’s
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 288215.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
http://www.mayport.com/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to the Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Mayport Wealth Management. For convenience, the Advisor has combined these documents into a
single disclosure document.
Mayport Wealth Management believes that communication and transparency are the foundation of its
relationship with clients and will continually strive to provide you with complete and accurate information at all
times. Mayport Wealth Management encourages all current and prospective clients to read this Disclosure
Brochure and to discuss any questions you may have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the annual amendment filing
on March 24, 2025.
• The Advisor has updated their fee billing. Please see Item 5 for additional information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to each client annually and if a
material change occurs.
You may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 288215. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at (617) 545-5700.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Services
A. Firm Information
B. Advisory Services Offered
C. Client Account Management
D. Wrap Fee Programs
E. Assets Under Management
Item 5 – Fees and Compensation
A. Fees for Advisory Services
B. Fee Billing
C. Other Fees and Expenses
D. Advance Payment of Fees and Termination
E. Compensation for Sales of Securities
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
A. Methods of Analysis
B. 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
A. Code of Ethics
B. Personal Trading with Material Interest
C. Personal Trading in Same Securities as Clients
D. Personal Trading at Same Time as Client
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
B. Aggregating and Allocating Trades
Item 13 – Review of Accounts
A. Frequency of Reviews
B. Causes for Reviews
C. Review Reports
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Mayport Wealth Management
B. Compensation for Client Referrals
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Privacy Policy
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Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 3
Item 4 – Advisory Services
A. Firm Information
Mayport, LLC (“Mayport Wealth Management” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission, which is organized as a Limited Liability Company (“LLC”) under the laws
of Delaware. Mayport Wealth Management was founded in March 2017 and is owned and operated by Adam M.
Grossman (“Founder and Chief Compliance Officer”). This Disclosure Brochure provides information regarding
the qualifications, business practices, and the advisory services provided by Mayport Wealth Management.
B. Advisory Services Offered
Mayport Wealth Management offers advisory services to individuals, high net worth individuals, corporations,
trusts and estates (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate conflicts
of interest. Mayport Wealth Management’s fiduciary commitment is further described in the Advisor’s Code of
Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or
Interest in Client Transactions and Personal Trading.
Wealth Management Services
Mayport Wealth Management provides customized wealth management services for its Clients pursuant to a
wealth management agreement. These services consist of two components: comprehensive financial planning
and investment management.
Comprehensive Financial Planning: Mayport Wealth Management’s comprehensive financial planning consists of
the following steps: The Advisor first reviews and analyzes relevant areas of a Client’s financial situation,
depending upon their goals and objectives. The Advisor then prepares a lifetime cash flow plan to assess the
Client's ability to meet their stated goals. The Advisor discusses with the Client the results of the cash flow
analysis and then decides on an appropriate asset allocation to help the Client achieve their goals. As part of this
analysis, the Advisor also reviews both market risk and the Client's own personal tolerance for volatility. Mayport
Wealth Management may also refer Clients to an accountant, attorney or another specialist, as appropriate, to
help meet the needs of their unique situation. Mayport Wealth Management will also consult with these
specialists in order to provide a comprehensive approach to the wealth management services.
Investment Management: Mayport Wealth Management’s investment management services consists of
discretionary management of the Client’s account or accounts. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance
by the Advisor. Mayport Wealth Management works closely with each Client to identify their investment goals
and objectives, as well as risk tolerance and financial situation in order to create an asset allocation strategy.
There are four elements that go into Mayport Wealth Management Management’s portfolio construction:
1. Low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) – Mayport Wealth
Management evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. Mayport Wealth Management believes that Clients are in a zero-sum
game with the investment industry. Each dollar that a Client saves on fees is an additional dollar that
they can keep in their account. For that reason, Mayport Wealth Management advises Clients to choose
low-cost investments to achieve their investment goals, primarily mutual funds and/or ETFs. The Advisor
may also utilize individual stocks and retain certain types of investments based on a Client’s legacy
portfolio construction.
2. Simplicity – Mayport Wealth Management believes that straightforward and understandable investments
are ideal for Clients. These investments are usually low-cost, transparent, less likely to cause a Client to
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 4
panic in a downturn, and generally have high liquidity.
3.
Intrinsic value – Mayport Wealth Management recommends investments with measurable intrinsic value
because Mayport Wealth Management believes that this is what separates a true investment from a
speculative bet.
4. Not dependent upon predictions of the future – Mayport Wealth Management does not believe that it is
possible to accurately and consistently predict the future direction of the economy, of markets or of
individual securities. For that reason, Mayport Wealth Management’s investment approach is primarily
long-term focused and does not rely on market timing. However, the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Mayport Wealth Management may also redistribute allocations to diversify the portfolio or
recommend specific positions to increase sector or asset class weightings or employ cash positions as a
possible hedge against market movement.
Mayport Wealth Management may retain other types of investments from the Client’s legacy portfolio due to fit
with the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the
Client.
Use of Independent Managers: Mayport Wealth Management may recommend that a Client utilize one or more
unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a
portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into
an advisory agreement with the Independent Manager[s] that defines the terms in which the Independent
Manager[s] will provide investment advisory and related services. The Advisor may also assist in the
development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will
perform initial and ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the
Independent Managers’ strategies and target allocations remain aligned with its Clients’ investment objectives
and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s]
or investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that
makes the appropriate disclosures).
At no time will Mayport Wealth Management accept or maintain custody of a Client’s funds or securities, except
for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within their
designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. For additional
information, please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Donor Advised Fund Services – The Advisor also provides the Fidelity Charitable Donor Advised Fund (“DAF”)
and the Schwab Charitable Donor Advised Fund (“DAF”) to Clients via Fidelity Charitable and Schwab
Charitable, both are a web-based interface and administrative solution for charitable giving to philanthropic
vehicles via the Fidelity Charitable Fund (“FCF”) and the Schwab Charitable Fund (“SCF”), both are IRS
approved philanthropic vehicle established for the purpose of managing charitable donations contributed by or on
behalf of donor clients. The DAF allows the Advisor to actively manage assets that have been donated to and are
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 5
owned by FCF or SCF, while charging an investment management fee. The Advisor’s DAF participation is in
conjunction with approval by the FCF or SCF Investment Committee for the Advisor to operate as an advisory
manager on the platform. Both the Fidelity Charitable Fund and Schwab Charitable Fund are independent
companies and unaffiliated with the Advisor.
C. Client Account Management
Prior to engaging Mayport Wealth Management to provide advisory services, each Client is required to enter into
one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the
Advisor and the Client.
These services may include:
● Establishing an Investment Strategy – Mayport Wealth Management, in collaboration with the Client, will
develop a strategy that seeks to achieve the Client’s investment goals and objectives.
● Asset Allocation – Mayport Wealth Management will develop a strategic asset allocation that is targeted
to meet the investment objectives, time horizon, financial situation and tolerance for risk of each Client.
● Portfolio Construction – For each Client, Mayport Wealth Management will construct a portfolio intended
to help them meet their stated goals and objectives.
●
Investment Management and Supervision – Mayport Wealth Management will provide investment
management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Mayport Wealth Management does not manage or place Client assets into a wrap fee program. Investment
advisory services are provided directly by Mayport Wealth Management.
E. Assets Under Management
As of December 31, 2024, Mayport Wealth Management manages $481,532,920 in Client assets, $457,902,583
of which are managed on a discretionary basis and $23,630,337 on a non-discretionary basis. Clients may
request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a one or
more written agreements with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid monthly, in arrears, pursuant to the terms of the wealth management
agreement. Wealth management fees generally range from $10,000 to $25,000 annually based on several
factors, including: the complexity of the services to be provided, the level and nature of assets to be managed,
and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting
requirements, portfolio restrictions and other complexities may be charged a higher fee. Fees may be negotiable
at the discretion of the Advisor.
Each January 1st, Mayport will adjust the Management Fee to account for inflation. All adjustments are as of
January 1 of each calendar year, effective until the next adjustment pursuant to the Client’s Wealth Management
Agreement. The adjustment will be calculated using the yearly percentage change in the most recently published
Consumer Price Index (services less energy services in U.S. city average, all urban consumers, seasonally
adjusted), published by the U.S. Bureau of Labor Statistics (“CPI”). The adjustment will not be less than 0% or
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 6
more than 5% of the prior Management Fee, and will be rounded to the nearest $50 regardless of the CPI.
Communication of the Client’s fee adjustment will be provided prior to the new fee being implemented.
Certain clients may be subject to a legacy hourly fee that may differ from the range of fees listed above.
The Advisor imposes a minimum fee of $10,000, which can be waived at the sole discretion of the Advisor.
The Advisor’s fee is exclusive of, and in addition to, any applicable securities transaction and custody fees, and
other related costs and expenses, which may be incurred by the Client. However, the Advisor shall not receive
any portion of these commissions, fees, and costs.
Use of Independent Managers: For Clients referred by the Advisor to an Independent Manager, the Client’s fee
may be separately billed or deducted from the Client’s account[s] by the Independent Manager.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor and deducted from the Client’s account[s] at the
Custodian. The Client authorizes the Custodian to deduct the Advisor’s fees. The Advisor shall send an invoice
to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the end of the
calendar month. The amount due is calculated by dividing the annual fee by 12. Clients will be provided with a
statement, at least quarterly, from the Custodian reflecting deduction of the wealth management fee. It is the
responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement
as the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory
fees to be deducted by Mayport Wealth Management and to be paid directly from their account[s] held by the
Custodian as part of the wealth management agreement and separate account forms provided by the Custodian.
Alternatively, at the Client’s request, the Advisor will send an invoice directly to the Client on a quarterly basis.
The amount due is calculated by dividing the annual fee by 4. Advisory fees will be due within 30 days of receipt.
Use of Independent Managers: For Clients referred by the Advisor to an Independent Manager, the Client’s fee
may be separately billed or deducted from the Client’s account[s] with the respective manager.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Mayport Wealth Management, in
connection with investments made on behalf of the Client’s account[s]. The Client is responsible for all custody
and securities execution fees charged by the Custodian. The Advisor's recommended Custodian does not
charge securities transaction fees for ETF and equity trades in a Client's account, provided that the account
meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically
charges for mutual funds and other types of investments. The fees charged by Mayport Wealth Management are
separate and distinct from these custody and execution fees.
In addition, all fees paid to Mayport Wealth Management for advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees
for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and
a possible distribution fee. A Client may be able to invest in these products directly, without the services of
Mayport Wealth Management, but would not receive the services provided by Mayport Wealth Management
which are designed, among other things, to assist the Client in determining which products or services are most
appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the
fees charged by the fund[s] and the fees charged by Mayport Wealth Management to fully understand the total
fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 7
D. Advance Payment of Fees and Termination
Wealth Management Services
Mayport Wealth Management is compensated for its services at the end of each calendar month or quarter in
which wealth management services are rendered. Either party may terminate the wealth management
agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the
wealth management agreement within five (5) business days of signing the wealth management agreement at no
cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered
to the point of termination and such fees will be due and payable by the Client. The Client’s wealth management
agreement with the Advisor is non-transferable without the Client’s prior consent.
Use of Independent Managers: In the event that a Client should wish to terminate their relationship with the
Independent Manager, the terms for termination will be set forth in the respective agreements between the Client
and that Independent Manager. Mayport Wealth Management will assist the Client with the termination and
transition as appropriate.
E. Compensation for Sales of Securities
Mayport Wealth Management does not buy or sell securities and does not receive any compensation for
securities transactions in any Client account, other than the wealth management fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
Mayport Wealth Management does not charge performance-based fees for its wealth management services. The
fees charged by Mayport Wealth Management are as described in Item 5 above and are not based upon the
capital appreciation of the funds or securities held by any Client.
Mayport Wealth Management does not manage any proprietary investment funds or limited partnerships (for
example, a mutual fund or a hedge fund) and has no financial incentive to recommend any particular investment
options to its Clients.
Item 7 – Types of Clients
Mayport Wealth Management offers advisory services to individuals, high net worth individuals, corporations,
trusts and estates. The amount of each type of Client is available on the Advisor's Form ADV Part 1A. These
amounts may change over time and are updated at least annually by the Advisor. Mayport Wealth Management
generally does not impose a minimum relationship size; however, the Advisor does impose a minimum fee for
wealth management services of $10,000, which can be waived at the sole discretion of the Advisor.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Mayport Wealth Management employs goals-based and cash flow-based financial planning to help inform asset
allocation recommendations for clients.
The Advisor believes that stocks are the most effective asset class to grow capital and that bonds are the most
effective asset class to preserve capital. Because of the very low, and sometimes negative, correlation between
stocks and bonds, Mayport believes that these two asset classes are most effective in combination. The Advisor
may also include allocations to cash to meet investors’ short-term needs.
The Advisor believes that it is difficult to construct a portfolio of individual securities that can outperform a
relevant benchmark. This view is based on studies including Standard & Poor’s SPIVA Scorecards as well as on
academic research by, among others, William Sharpe, Brad Barber and Terrance Odean. For that reason, the
Advisor constructs portfolios using primarily low-cost, broadly-diversified index funds and index-based exchange-
traded funds.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 8
In evaluating funds for each asset class and sub-asset class, the Advisor considers, among other factors: a
fund’s benchmark, performance relative to its benchmark, reputation of the adviser, expense ratio, assets under
management and liquidity.
In evaluating third-party managers, the Advisor considers, among other factors: adviser’s reputation, assets
under management, strategies, each strategy’s performance relative to its benchmark, cost and customer
service.
As noted above, Mayport Wealth Management generally employs long-term investment approach for its Clients,
as consistent with their financial goals. Mayport Wealth Management will typically hold all or a portion of a
security for more than a year, but may hold for shorter periods in order to rebalance a portfolio or to meet the
cash needs of Clients. At times, Mayport Wealth Management may also buy and sell positions that are more
short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset
class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Mayport Wealth Management will assist Clients in
determining an appropriate strategy based upon their tolerance for risk and on other factors noted above.
However, there is no guarantee that a Client will meet their investment goals. Please see Item 8.B. for risks
associated with the Advisor’s investment strategies as well as general risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process
are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
Individual Stock Risks
Investments in individual stocks have a higher risk of losing value that in a relatively short amount of time than
investments in diversified funds. Stocks also do not provide diversification to protect against market fluctuations,
unless a large number of individual stocks across multiple sectors and industries are utilized in the construction
of a portfolio.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 9
Mutual Fund Risks
The performance of mutual funds is subject to market risks, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily. Therefore, a mutual fund purchased at one point in the day will typically have
the same price as a mutual fund purchased later that same day.
ETF Risks
The performance of ETFs is subject to market risks, including the possible loss of principal. The price of the
ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a
trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have
a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market
movements and may dissociate from the index being tracked by the ETF or the price of the underlying
investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF
purchased or sold a short time later. There is also a risk that Authorized Participants are unable to fulfill their
responsibilities. Authorized Participants are one of the major parties involved with ETF creation/redemption
mechanism in the markets. The Authorized Participants play a critical role in the liquidity of ETFs and essentially
have the exclusive right to change the supply of ETF shares in the market. If the Authorized Participants does not
fulfill this expected role, there could be an adverse impact on liquidity and the valuation of an ETF.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will
fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the
coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower
rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at
a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk,
i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting
on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of
the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6)
Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the
bond.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Mayport Wealth Management or any of its
owner. Mayport Wealth Management values the trust Clients place in the Advisor. The Advisor encourages
Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The
backgrounds of the Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 288215.
In addition, Clients may also obtain information relating to the disciplinary history of any investment advisor
representative conducting business in Massachusetts by contacting the Commonwealth of Massachusetts
Securities Division at (617) 727-3548.
Item 10 – Other Financial Industry Activities and Affiliations
Mr. Grossman teaches adult education classes in the town of Brookline and also writes for a third-party blog. He
receives nominal compensation for each of these activities. These activities do not account for more than 10% of
Mr. Grossman’s time.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Mayport Wealth Management has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary
commitment to each Client. This Code applies to all persons associated with Mayport Wealth Management
(“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions
regarding the Advisor’s duties to the Client. Mayport Wealth Management and its Supervised Persons owe a duty
of loyalty, fairness and good faith towards each Client. It is the obligation of Mayport Wealth Management’s
Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles
that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest.
To request a copy of the Code, please contact the Advisor at (617) 545-5700.
B. Personal Trading with Material Interest
Mayport Wealth Management allows Supervised Persons to purchase or sell the same securities that may be
recommended to and purchased on behalf of Clients. Mayport Wealth Management does not act as principal in
any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment
company. Mayport Wealth Management does not have a material interest in any securities traded in Client
accounts.
C. Personal Trading in Same Securities as Clients
Mayport Wealth Management allows Supervised Persons to purchase or to sell the same securities that are
recommended to and purchased on behalf of Clients. Owning the same securities that are recommend (purchase
or sell) to you presents a conflict of interest that, as fiduciaries, must be discloses to Clients and mitigated
through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading
(material, non-public information controls); gifts and entertainment; outside business activities and personal
securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading
in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades
are made with more advantageous terms than Client trades, or by trading based on material, non-public
information. This risk is mitigated by Mayport Wealth Management requiring reporting of personal securities
trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or by conducting a
coordinated review of personal accounts and the accounts of the Clients. The Advisor has also adopted written
policies and procedures to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Mayport Wealth Management allows Supervised Persons to purchase or sell the same securities that are
recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or
traded afterward. At no time will Mayport Wealth Management, or any Supervised Person of Mayport
Wealth Management, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Mayport Wealth Management does not have discretionary authority to select the broker-dealer/custodian for
custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to
safeguard Client assets and authorize Mayport Wealth Management to direct trades to the Custodian as agreed
upon in the investment advisory agreement. Furthermore, Mayport Wealth Management does not have the
discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis.
While Mayport Wealth Management does not exercise discretion over the selection of the Custodian, it may
recommend the Custodian[s] to Clients for execution and custody services. Clients are not obligated to use the
Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian
not recommended by Mayport Wealth Management. However, the Advisor may be limited in the services it can
provide if the recommended Custodian is not engaged. Mayport Wealth Management may recommend the
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 11
Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client,
services made available to the Client, its reputation and/or the location of the Custodian’s offices.
Mayport Wealth Management generally recommends that Clients establish their account[s] at Charles Schwab &
Co., Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s
“qualified custodian.” Mayport Wealth Management maintains an institutional relationship with Schwab, whereby
the Advisor receives economic benefits from Schwab. Please see Item 14 below.
Where Mayport Wealth Management does not exercise discretion over the selection of the Custodian, it may
recommend the Custodian[s] to Clients. Clients are not obligated to use the recommended Custodian and will not
incur any extra fee or cost associated with using a broker-dealer/custodian not recommended by Mayport Wealth
Management. However, if the recommended Custodian is not utilized the Advisor may be limited in the services it
can provide to the Client comparable to other Clients. Mayport Wealth Management may recommend the
Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client,
services made available to the Client, its reputation, and/or location of the Custodian’s offices.
Mayport Wealth Management will generally recommend that Clients establish their account[s] at Fidelity Clearing
and Custody Solutions and related divisions and entities of Fidelity Investments, Inc., including National Financial
Services LLC, and Fidelity Brokerage Services LLC (collectively “Fidelity”), a FINRA-registered broker-dealer and
member SIPC. Fidelity will serve as the Client’s “qualified custodian.” Mayport Wealth Management maintains an
institutional relationship with Fidelity, whereby the Advisor receives economic benefits from Fidelity.
Mayport Wealth Management has established an institutional relationship with Fidelity to assist the Advisor in
managing Client account[s]. Access to the Fidelity platform is provided at no charge to the Advisor. The Fidelity
platform includes brokerage, custody, administrative support, record keeping, technology, and related services
designed to support registered investment advisors like Mayport Wealth Management in serving Clients. These
services are intended to serve the best interests of the Advisor’s Clients.
Fidelity may charge brokerage commissions (securities transaction fees) for effecting certain securities
transactions. Fidelity enables the Advisor to obtain certain no-load mutual funds without securities transaction
fees and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally
considered discounted from customary retail commission rates. However, the commissions and transaction fees
charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. Please
see Item 14 below for additional information.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars – Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. Mayport Wealth Management does not participate in soft dollar programs sponsored or offered by
any broker-dealer/custodian. However, the Advisor receives certain economic benefits from the Custodian.
Please see Item 14 below.
2. Brokerage Referrals – Mayport Wealth Management does not receive any compensation from any third party
in connection with recommendations to establish an account.
3. Directed Brokerage – All Clients are serviced on a “directed brokerage basis,” where Mayport Wealth
Management will place trades within the established account[s] at the Custodian designated by the Client.
Further, all Client accounts are traded within their respective account[s]. The Advisor will not engage in any
principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with
other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]).
Mayport Wealth Management will not be obligated to select competitive bids on securities transactions and does
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 12
not have an obligation to seek the lowest available transaction costs. These costs are determined by the
Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results, taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the Custodian. Mayport Wealth Management will execute its
transactions through the Custodian as authorized by the Client.
Mayport Wealth Management may aggregate orders into a block trade or trades when securities are purchased
or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade
cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of
each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written
statement. This must be done in a way that does not consistently advantage or disadvantage any particular
Client accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Adam M. Grossman, Founder
and Chief Compliance Officer of Mayport Wealth Management. Formal reviews are generally conducted at least
annually or more frequently depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Mayport Wealth
Management if changes occur in the Client’s personal financial situation that might affect the Client’s investment
plan. Additional reviews may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Mayport Wealth Management
Mayport Wealth Management is a fee-only advisory firm that is compensated solely by its Clients and does not
receive compensation from any investment product. Mayport Wealth Management does not receive commissions
or other compensation from product sponsors, broker-dealers or any unrelated third party. Mayport Wealth
Management may refer Clients, on a non-compensated basis, to various unaffiliated, non-advisory professionals
(e.g. attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of
its Clients. Likewise, Mayport Wealth Management may receive non-compensated referrals of new Clients from
various third parties.
Participation in Institutional Advisor Platform
Mayport Wealth Management has established an institutional relationship with Schwab through its “Schwab
Advisor Services” unit, a division of Schwab dedicated to serving independent advisory firms like Mayport Wealth
Management. As a registered investment advisor participating on the Schwab Advisor Services platform,
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 13
Mayport Wealth Management receives access to software and related support without cost because the Advisor
renders investment management services to Clients that maintain assets at Schwab. Services provided by
Schwab Advisor Services benefit the Advisor and many, but not all services provided by Schwab will benefit
Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first.
Clients should be aware, however, that the receipt of economic benefits from a custodian creates a conflict of
interest since these benefits may influence the Advisor's recommendation of this custodian over one that does
not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds
and other investments without having to adhere to investment minimums that might be required if the Client were
to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for
Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its
relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for
its Clients, but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services to Mayport Wealth Management
that may not benefit the Client, including: educational conferences and events and consulting services and
discounts for various service providers. Access to these services creates an incentive for the Advisor to
recommend Schwab, which results in a conflict of interest. Mayport Wealth Management believes, however, that
the selection of Schwab as Custodian is in the best interests of its Clients.
Participation in Institutional Advisor Platform
As noted in item 12, Mayport Wealth Management has established an institutional relationship with Fidelity to
assist the Advisor in managing Client account[s].
As part of the arrangement, Fidelity also makes available to the Advisor, at no additional charge to the Advisor,
certain research and brokerage services, including research services obtained by Fidelity directly from
independent research companies. The Advisor may also receive additional services and support from Fidelity. As
a result of receiving such services for no additional cost, the Advisor may have an incentive to continue to use or
expand the use of Fidelity's services. The Advisor examined this potential conflict of interest when it chose to
enter into the relationship with Fidelity and has determined that the relationship is in the best interests of the
Advisor’s Clients and satisfies its Client obligations, including its duty to seek best execution. Please see Item 12
above.
The Advisor receives access to software and related support without cost because the Advisor renders
investment management services to Clients that maintain assets at Fidelity. The software and related systems
support may benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor
endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of
economic benefits from a Custodian creates a conflict of interest since these benefits may influence the Advisor's
recommendation of this Custodian over one that does not furnish similar software, systems support, or services.
In addition, Fidelity has provided the Advisor with financial support in the launch of the Advisor and
reimbursements for various third-party service providers.
B. Compensation for Client Referrals
Mayport Wealth Management does not compensate, either directly or indirectly, any persons who are not
supervised persons, for Client referrals.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 14
Item 15 – Custody
Mayport Wealth Management does not accept or maintain custody of any Client accounts, except for the limited
circumstances outlined below:
Deduction of Advisory Fees - To ensure compliance with regulatory requirements associated with the deduction
of advisory fees, all Clients for whom Mayport Wealth Management exercises discretionary authority must hold
their assets with a "qualified custodian." Clients are responsible for engaging a “qualified custodian” to safeguard
their funds and securities and must instruct Mayport Wealth Management to utilize that Custodian for securities
transactions on their behalf. Clients are encouraged to review statements provided by the Custodian and
compare to any reports provided by Mayport Wealth Management to ensure accuracy, as the Custodian does not
perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage
Practices.
Money Movement Authorization - For instances where Clients authorize Mayport Wealth Management to move
funds between their accounts, Mayport Wealth Management and the Custodian have implemented safeguards to
ensure that all money movement activities are conducted strictly in accordance with the Client’s documented
instructions.
Item 16 – Investment Discretion
Mayport Wealth Management generally has discretion over the selection and amount of securities to be bought
or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases
or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the
Client and agreed to by Mayport Wealth Management. Discretionary authority will only be authorized upon full
disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of a wealth
management agreement containing all applicable limitations to such authority. All discretionary trades made by
Mayport Wealth Management will be in accordance with each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Mayport Wealth Management does not accept proxy-voting responsibility for any Client. Clients will receive proxy
statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies,
however, the Client retains the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Mayport Wealth Management, nor its owner, have any adverse financial situations that would reasonably
impair the ability of Mayport Wealth Management to meet all obligations to its Clients. Mayport Wealth
Management has not been subject to a bankruptcy or financial compromise. Mayport Wealth is not required to
deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of
$1,200 or more for services to be performed six months or more in the future.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 15
Form ADV Part 2B – Brochure Supplement
for
Adam M. Grossman, CFA®
Founder and Chief Compliance Offer
Effective: March 24, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Adam M. Grossman, CFA® (CRD# 5621622) in addition to the information contained in the Mayport, LLC
(“Mayport Wealth Management” or the “Advisor”, CRD# 288215) Disclosure Brochure. If you have not received a
copy of the Disclosure Brochure or if you have any questions about the contents of the Mayport Wealth
Management Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (617) 545-5700.
Additional information about Mr. Grossman is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5621622.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 16
Item 2 – Educational Background and Business Experience
Adam M. Grossman, CFA®, born in 1971, is dedicated to advising Clients of Mayport Wealth Management as its
Founder and Chief Compliance Officer. Mr. Grossman earned a Bachelor of Arts from Williams College in 1993.
Mr. Grossman also earned a Master of Business Administration from the Massachusetts Institute of Technology,
Sloan School of Management in 2008. Additional information regarding Mr. Grossman’s employment history is
included below.
Employment History:
Founder, Chief Compliance Officer, Mayport, LLC
Research Analyst & Portfolio Manager, Middleton & Company, Inc.
Research Analyst, Ballentine Partners
Research Analyst, Balletine, Finn & Co.
04/2017 to Present
12/2010 to 04/2017
02/2010 to 12/2010
09/2008 to 02/2010
Chartered Financial Analyst™ (“CFA®”)
The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and
awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour
examinations over two to four years. The three levels of the CFA® Program test a wide range of investment
topics, including ethical and professional standards, fixed-income analysis, alternative and derivative
investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four
years of acceptable professional experience in the investment decision-making process and must commit to
abide by, and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of
Professional Conduct. CFA® is a trademark owned by CFA® Institute.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Grossman. Mr. Grossman has
never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Grossman.
Securities laws require an advisor to disclose any instances where the advisor or its Advisory Persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Grossman.
However, the Advisor does encourage you to independently view the background of Mr. Grossman on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 5621622.
Item 4 – Other Business Activities
Mr. Grossman teaches adult education classes in the town of Brookline, Massachusetts and writes for a third-
party blog. He receives nominal compensation for each of these activities. Mr. Grossman also serves on the
investment committees of Torah Academy in Brookline, Massachusetts and of Families First Parenting
Programs, Inc. in Watertown, Massachusetts.
Item 5 – Additional Compensation
Mr. Grossman has additional business activities where compensation is received that are detailed in Item 4
above.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 17
Item 6 – Supervision
Mr. Grossman serves as the Founder and Chief Compliance Officer of Mayport Wealth Management. Mr.
Grossman can be reached at (617) 545-5700.
Mayport Wealth Management has implemented a Code of Ethics, an internal compliance document, that guides
each Supervised Person in meeting their fiduciary obligations to Clients of Mayport Wealth Management.
Furthermore, Mayport Wealth Management is subject to regulatory oversight by various agencies. These
agencies require registration by Mayport Wealth Management and its Supervised Persons. As a registered entity,
Mayport Wealth Management is subject to examinations by regulators, which may be announced or
unannounced. Mayport Wealth Management is required to periodically update the information provided to these
agencies and to provide various reports regarding the business activities and assets of the Advisor.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 18
Form ADV Part 2B – Brochure Supplement
for
Shane P. Kelly, CFP®
Wealth Management Associate
Effective: August 4, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Shane P. Kelly, CFP®, (CRD# 6976646) in addition to the information contained in the Mayport, LLC (“Mayport
Wealth” or the “Advisor”, CRD# 288215) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the Mayport Wealth Disclosure Brochure or this
Brochure Supplement, please contact us at (617) 545-5700.
Additional information about Mr. Kelly is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6976646.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 19
Item 2 – Educational Background and Business Experience
Shane P. Kelly, CFP®, born in 1996, is dedicated to advising Clients of Mayport Wealth as a Wealth
Management Associate. Mr. Kelly earned a Bachelor of Arts from Boston College in 2019. Additional information
regarding Mr. Kelly’s employment history is included below.
Employment History:
Wealth Management Associate, Mayport, LLC
Portfolio Associate, HarbourVest Partners, LLC
Associate Consultant, Sr. Associate Consultant, Putnam Investments
Regional Associate, Putnam Investments
Summer Intern, Putnam Investments
Student, Boston College
07/2023 to Present
8/2022 to 6/2023
9/2020 to 8/2022
9/2019 to 8/2020
6/2018 to 8/2018
08/2015 to 05/2019
Chartered Financial Analyst™ (“CFA®”)
The Chartered Financial Analyst™ (“CFA®”) charter is a professional designation established in 1962 and
awarded by CFA® Institute. To earn the CFA® charter, candidates must pass three sequential, six-hour
examinations over two to four years. The three levels of the CFA® Program test a wide range of investment
topics, including ethical and professional standards, fixed-income analysis, alternative and derivative
investments, and portfolio management and wealth planning. Also, CFA® charter holders must have at least four
years of acceptable professional experience in the investment decision-making process and must commit to
abide by, and annually reaffirm their adherence to the CFA® Institute Code of Ethics and Standards of
Professional Conduct. CFA® is a trademark owned by CFA® Institute.
CERTIFIED FINANCIAL PLANNER® professional
I am certified for financial planning services in the United States by Certified Financial Planner
Board of Standards, Inc. (“CFP Board”). Therefore, I may refer to myself as a CERTIFIED FINANCIAL
PLANNER® professional or a CFP® professional, and I may use these and the other certification marks (the “CFP
Board Certification Marks”) that Certified Financial Planner Board of Standards Center for Financial Planning,
Inc. has licensed to CFP Board in the United States. The CFP® certification is voluntary. No federal or state law
or regulation requires financial planners to hold the CFP® certification. You may find more information about the
CFP® certification at www.cfp.net.
CFP® professionals have met CFP Board’s high standards for education, examination, experience, and ethics.
To become a CFP® professional, an individual must fulfill the following requirements:
• Education – Earn a bachelor’s degree or higher from an accredited college or university
and complete CFP Board-approved coursework at a college or university through a CFP
Board Registered Program. The coursework covers the financial planning subject areas
CFP Board has determined are necessary for the competent and professional delivery of
financial planning services, as well as a comprehensive financial plan development
capstone course. A candidate may satisfy some of the coursework requirement through
other qualifying credentials. CFP Board implemented the bachelor’s degree or higher
requirement in 2007 and the financial planning development capstone course requirement
in March 2012. Therefore, a CFP® professional who first became certified before those dates may not have
earned a bachelor’s or higher degree or completed a financial planning development capstone course.
• Examination – Pass the comprehensive CFP® Certification Examination. The examination is designed to
assess an individual’s ability to integrate and apply a broad base of financial planning knowledge in the
context of real-life financial planning situations.
• Experience – Complete 6,000 hours of professional experience related to the personal
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 20
financial planning process, or 4,000 hours of apprenticeship experience that meets
additional requirements.
• Ethics – Satisfy the Fitness Standards for Candidates for CFP® Certification and Former CFP®
Professionals Seeking Reinstatement and agree to be bound by CFP Board’s Code of Ethics and
Standards of Conduct (“Code and Standards”), which sets forth the ethical and practice standards for
CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics
requirements to remain certified and maintain the right to continue to use the CFP Board
Certification Marks:
• Ethics – Commit to complying with CFP Board’s Code and Standards. This includes a
commitment to CFP Board, as part of the certification, to act as a fiduciary, and therefore,
act in the best interests of the client, at all times when providing financial advice and
financial planning. CFP Board may sanction a CFP® professional who does not abide by this
commitment, but CFP Board does not guarantee a CFP® professional's services. A client
who seeks a similar commitment should obtain a written engagement that includes a
fiduciary obligation to the client.
• Continuing Education – Complete 30 hours of continuing education every two years to
maintain competence, demonstrate specified levels of knowledge, skills, and abilities, and
keep up with developments in financial planning. Two of the hours must address the Code
and Standards.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Kelly. Mr. Kelly has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Kelly.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Kelly.
However, we do encourage you to independently view the background of Mr. Kelly on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
6976646.
Item 4 – Other Business Activities
Mr. Kelly is dedicated to the investment advisory activities of Mayport Wealth’s Clients. Mr. Kelly does not have
any other business activities.
Item 5 – Additional Compensation
Mr. Kelly is dedicated to the investment advisory activities of Mayport Wealth’s Clients. Mr. Kelly does not receive
any additional forms of compensation.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 21
Item 6 – Supervision
Mr. Kelly serves as a Wealth Management Associate of Mayport Wealth and is supervised by Adam Grossman,
the Chief Compliance Officer. Mr. Grossman can be reached at (617) 545-5700.
Mayport Wealth has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Mayport Wealth. Further, Mayport Wealth is
subject to regulatory oversight by various agencies. These agencies require registration by Mayport Wealth and
its Supervised Persons. As a registered entity, Mayport Wealth is subject to examinations by regulators, which
may be announced or unannounced. Mayport Wealth is required to periodically update the information provided
to these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
Page 22
Privacy Policy
Effective: March 24, 2025
Our Commitment to You
Mayport, LLC (“Mayport Wealth Management” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Mayport Wealth Management (also
referred to as "we," "our" and "us”) protects the security and confidentiality of the personal information we have
and implements controls to ensure that such information is used for proper business purposes in connection with
the management or servicing of our relationship with you.
Mayport Wealth Management does not sell your non-public, personal information to anyone. Nor does the
Advisor provide such information to others except for discrete and reasonable business purposes in connection
with the servicing and management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal, non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing, and they require RIAs to
disclose how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information that they
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
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receive from us.
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
We may share non-public, personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
No
Not Shared
Marketing Purposes
Mayport Wealth Management does not disclose, and does not intend to
disclose, personal information with non-affiliated third parties to offer you
services. Certain laws may give us the right to share your personal
information with financial institutions where you are a customer and
where Mayport Wealth Management or the client has a formal agreement
with the financial institution. We will only share information for
purposes of servicing your accounts, not for marketing purposes.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
Not Shared
Information About Former Clients
Mayport Wealth Management does not disclose and does not intend to
disclose non-public, personal information to non-affiliated third parties
with respect to persons who are no longer our Clients.
State-specific Regulations
Massachusetts
In response to a Massachusetts law, clients must “opt-in” to share non-public, personal
information with non-affiliated third parties before any personal information is disclosed.
Client opt-in is obtained through the Client’s execution of authorization forms provided by the
third parties, by executing an Information Sharing Authorization Form, or by other written
consent by the Client, as appropriate and consistent with applicable laws and regulations.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically, we may revise this Policy and will provide you with a revised Policy if the changes materially alter
the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public,
personal information, other than as described in this notice, unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy
Policy by contacting the Advisor at (617) 545-5700.
Mayport, LLC
300 Washington Street, Suite 814, Newton, MA 02458
Phone: (617) 545-5700
www.mayport.com
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