Overview
- Headquarters
- Portsmouth, NH
- Average Client Assets
- $2.4 million
- Minimum Account Size
- $500,000
- SEC CRD Number
- 128868
Fee Structure
Primary Fee Schedule (2025 ADV PART 2A BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.30% |
| $500,001 | $1,000,000 | 1.00% |
| $1,000,001 | $2,500,000 | 0.60% |
| $2,500,001 | $5,000,000 | 0.40% |
| $5,000,001 | and above | 0.30% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,500 | 1.15% |
| $5 million | $30,500 | 0.61% |
| $10 million | $45,500 | 0.46% |
| $50 million | $165,500 | 0.33% |
| $100 million | $315,500 | 0.32% |
Clients
- HNW Share of Firm Assets
- 67.95%
- Total Client Accounts
- 2,066
- Discretionary Accounts
- 2,066
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection
Regulatory Filings
Additional Brochure: 2025 ADV PART 2A BROCHURE (2026-03-24)
View Document Text
Nvest Financial, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: March 24, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Nvest Financial, LLC (“Nvest” or the “Advisor”). If you have any questions about the content of this
Disclosure Brochure, please contact the Advisor at 207-985-8585 or by email at info@nvestfinancial.com.
Nvest is a registered investment advisor with 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 Nvest to assist you in determining whether to retain the Advisor.
Additional information about Nvest 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# 128868.
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Nvest.
Nvest 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. Nvest encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the last filing on August 14,
2025:
• The Advisor has changed its SIMPLE IRA fee. Please see Item 5 for more information.
• The Advisor has redrafted its Disclosure Brochure to streamline its disclosures.
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 you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 128868. You
may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 207-985-8585 or by
email at info@nvestfinancial.com.
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents .................................................................................................................................... 3
Item 4 – Advisory Services ................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 6
D. Wrap Fee Programs ....................................................................................................................................................... 6
E. Assets Under Management ............................................................................................................................................ 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ............................................................................................................................................. 6
B. Fee Billing ....................................................................................................................................................................... 8
C. Other Fees and Expenses ............................................................................................................................................. 8
D. Advance Payment of Fees and Termination .................................................................................................................. 9
E. Compensation for Sales of Securities ............................................................................................................................ 9
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 10
Item 7 – Types of Clients ..................................................................................................................................... 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 10
A. Methods of Analysis ..................................................................................................................................................... 10
B. Risk of Loss .................................................................................................................................................................. 11
Item 9 – Disciplinary Information ....................................................................................................................... 12
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 12
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .............. 13
A. Code of Ethics .............................................................................................................................................................. 13
B. Personal Trading with Material Interest ........................................................................................................................ 13
C. Personal Trading in Same Securities as Clients .......................................................................................................... 13
D. Personal Trading at Same Time as Client ................................................................................................................... 13
Item 12 – Brokerage Practices ............................................................................................................................ 13
A. Recommendation of Custodian[s] ................................................................................................................................ 13
B. Aggregating and Allocating Trades .............................................................................................................................. 14
Item 13 – Review of Accounts ............................................................................................................................ 14
A. Frequency of Reviews .................................................................................................................................................. 14
B. Causes for Reviews ..................................................................................................................................................... 14
C. Review Reports ............................................................................................................................................................ 14
Item 14 – Client Referrals and Other Compensation ........................................................................................ 15
A. Compensation Received by Nvest ............................................................................................................................... 15
B. Compensation for Client Referrals ............................................................................................................................... 15
Item 15 – Custody ................................................................................................................................................ 16
Item 16 – Investment Discretion ......................................................................................................................... 16
Item 17 – Voting Client Securities ...................................................................................................................... 16
Item 18 – Financial Information .......................................................................................................................... 16
Privacy Policy ...................................................................................................................................................... 17
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 3
Item 4 – Advisory Services
A. Firm Information
Nvest Financial, LLC (“Nvest” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under the laws of the State
of New Hampshire. Nvest was founded in May 2003 and is owned and operated by Nichole Raftopoulos (Chief
Executive Officer and Chief Compliance Officer and George Raftopoulos (President). This Disclosure Brochure
provides information regarding the qualifications, business practices, and the advisory services provided by Nvest.
B. Advisory Services Offered
Nvest offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
charitable organizations, and retirement plans (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 potential
conflicts of interest. Nvest's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
Nvest provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. Nvest works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. Nvest will then construct an investment
portfolio, consisting of diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s
investment goals. The Advisor may also utilize individual stocks or bonds to meet the needs of its Clients. The
Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the overall portfolio
strategy, tax-related reasons, or other reasons as identified between the Advisor and the Client.
Nvest’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. Nvest
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Nvest evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Nvest may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Nvest may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement.
Nvest may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
At no time will Nvest 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 the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. 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
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 4
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. In situations where the Advisor makes a rollover
recommendation, the Advisor will provide a Rollover Recommendation Summary Form.
Use of Independent Managers – The Advisor will recommend that Clients utilize one or more unaffiliated
investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s
investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing
oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients
investment objectives and overall best interests. The Advisor will also assist the Client in the development of the
initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the
Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate
disclosures).
Financial Planning Services
Nvest will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written
financial planning agreement. Services are offered in several areas of a Client’s financial situation, depending on
their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or
rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Nvest may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract date,
assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Consulting Services
The Advisor provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and
the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
• Ongoing Investment Recommendation and Assistance
• Performance Reports
• ERISA 404(c) Assistance
• Benchmarking Services
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 5
These services are provided by the Advisor serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of the Advisor’s fiduciary status, the specific services to be rendered
and all direct and indirect compensation the Advisor reasonably expects under the engagement
C. Client Account Management
Prior to engaging Nvest to provide investment advisory services, each Client is required to enter into an agreement
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 – Nvest, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Nvest will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Nvest will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
•
Investment Management and Supervision – Nvest will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Nvest does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by Nvest.
E. Assets Under Management
As of December 31, 2025, Nvest manages $688,288,833 in Client assets, all of which is managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
investment advisory agreement. Investment advisory fees are based on the market value of assets under
management at the end of the prior calendar quarter. Investment advisory fees are based on the following schedule:
Standard Fee Schedule
Assets Under Management ($)
First $500,000
$500,001 to $1,000,000
$1,000,001 to $2,500,000
$2,500,001 to $5,000,000
Above $5,000,001
Annual Rate (%)
1.30%
1.00%
0.60%
0.40%
0.30%
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 6
Fee Schedule for Non-Profit Organizations
Assets Under Management ($)
First $2,500,000
$2,500,001 to $5,000,000
Above $5,000,001
Annual Rate (%)
0.65%
0.30%
0.25%
Fee Schedule for SIMPLE IRA Plans
Assets Under Management ($)
Any and All Amounts
Annual Rate (%)
0.88%
The investment advisory fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into
consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by
Nvest will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s
valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other
related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor
shall not receive any portion of these commissions, fees, and costs.
Use of Independent Managers – As noted in Item 4, the Advisor may implement all or a portion of a Client’s
investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor
does not earn any compensation from an Independent Manager. The Advisor will only earn its wealth management
fee as described above. Independent Manager fees are separate and in addition to the Advisor’s wealth
management fees. Independent Managers typically do not offer any fee discounts but may have a breakpoint
schedule which will reduce the fee with an increased level of assets placed under management with an
Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure
brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s
fee and the Independent Manager’s fee, will not exceed 1.65% annually.
Contributions and Withdrawals – Clients may make additions to and withdrawals from their account(s) at any time,
subject to Nvest’s right to terminate an account. Additions may be in cash or securities provided that Nvest reserves
the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account(s).
Clients may withdraw account assets with prior written notice to Nvest, subject to the usual and customary securities
settlement procedures. However, Nvest designs its portfolios as long-term investments, and the withdrawal of assets
may impair the achievement of a Client’s investment objectives. Nvest may consult with its Clients about the options
and ramifications of transferring securities. However, Clients are advised that when transferred securities are
liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred
sales charge) and/or tax ramifications. The Advisor will adjust its fees for contributions or withdrawals if the assets
exceed $250,000 during the billing period.
The Advisor’s fee is exclusive of, and in addition to, brokerage commissions, transaction 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.
Financial Planning Services
Nvest offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly fees range from
$350 to $475 per hour. Fixed fees range from $1,750 to $15,000. Fees may be negotiable based on the nature and
complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours
and/or total costs will be provided to the Client prior to engaging for these services.
Retirement Plan Consulting Services
Retirement plan advisory fees are charged an annual asset-based fee based on the following schedule:
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 7
Standard Fee Schedule
Assets Under Management ($)
Under $1,000,000
$1,000,001 to $3,000,000
$3,000,001 to $5,000,000
$5,000,001 to $10,000,000
$10,000,001 to $20,000,000
Above $20,000,001
Annual Rate (%)
0.75%
0.50%
0.45%
0.40%
0.35%
0.30%
Fees may be billed monthly or quarterly (“Billing Period”) in advance or arrears pursuant to the terms of the
retirement plan advisory agreement. Retirement plan fees are based on the market value of assets under
management at the end of the Billing Period. Fees may be negotiable depending on the size and complexity of the
Plan but shall not exceed the fee range stated above.
Contributions and Withdrawals – Clients may make additions to and withdrawals from their account(s) at any time,
subject to Nvest’s right to terminate an account. Additions may be in cash or securities provided that Nvest reserves
the right to liquidate any transferred securities or decline to accept particular securities into a Client’s account(s).
Clients may withdraw account assets with prior written notice to Nvest, subject to the usual and customary securities
settlement procedures. However, Nvest designs its portfolios as long-term investments, and the withdrawal of assets
may impair the achievement of a Client’s investment objectives. Nvest may consult with its Clients about the options
and ramifications of transferring securities. However, Clients are advised that when transferred securities are
liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level (i.e. contingent deferred
sales charge) and/or tax ramifications. The Advisor will adjust its fees for contributions or withdrawals during the billing
period.
The Advisor may charge an advisory fee on assets held within self-directed brokerage accounts associated with
employer-sponsored retirement plans (as described in Item 4 above), in accordance with the Client’s advisory
agreement. Such fees are separate from, and in addition to, any fees and expenses associated with the retirement
plan, including administrative, custodial, and underlying investment expenses.
The Advisor’s fee is exclusive of, and in addition to, brokerage commissions, transaction 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.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the
Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from
the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the
quarterly rate (annual rate divided by 4) to the total assets under management with Nvest at the end of each quarter.
Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment
advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage
statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written
authorization permitting advisory fees to be deducted by Nvest to be paid directly from their account[s] held by the
Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian.
Financial Planning Services
Financial planning fees may be invoiced up to fifty percent (50%) of the expected total fee upon execution of the
financial planning agreement. The balance shall be invoiced upon completion of the agreed upon deliverable[s].
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Nvest, 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, as applicable. Depending on the Custodian and account type, Clients may be subject to
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 8
either asset-based pricing or transaction-based pricing for securities trades. Under asset-based pricing
arrangements, the Custodian may not charge separate 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 may charge for certain mutual funds and other types of investments. In
transaction-based pricing arrangements, including certain accounts held in cash, the Custodian generally charges
transaction-based fees for securities trades, including purchases and sales of equities, exchange-traded funds
(“ETFs”), mutual funds, and other investment products, as applicable. The Custodian may charge transaction fees if
there are transactions in such accounts. The fees charged by Nvest are separate and distinct from these custody
and execution fees.
In addition, all fees paid to Nvest for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of Nvest, but would
not receive the services provided by Nvest 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 Nvest to fully
understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Investment Management Services
Nvest may be compensated for its investment management services in advance of the quarter in which services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business
days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges
for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the
Client. Upon termination, the Advisor will refund any unearned, prepaid investment advisory fees from the effective
date of termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-
transferable without the Client’s prior consent.
Financial Planning Services
Nvest requires an advance deposit as described above. Either party may terminate the financial planning agreement,
at any time, by providing advance written notice to the other party. The Client may also terminate the financial
planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the
five-day period, the Client will incur charges for bona fide advisory services rendered to the point of termination and
such fees will be due and payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid
planning fees from the effective date of termination to the end of the quarter. The Client’s financial planning agreement
with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Nvest does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Broker Dealer Affiliation
Certain Advisory Persons are also Registered Representatives of Purshe Kaplan Sterling Investments, Inc. (“PKS”).
PKS is a registered broker-dealer (CRD# 35747) member FINRA, SIPC. In one’s separate capacity as a Registered
Representative, the Advisory Person will implement securities transactions under PKS and not through the Advisor.
In this capacity, the Advisory Person will receive commission-based compensation in connection with the purchase
and sale of securities, including 12b-1 fees for the sale of investment company products. Compensation earned by
the Advisory Person in one’s capacity as a Registered Representative is separate and in addition to investment
advisory fees. This practice presents a conflict of interest because the Advisory Person who is a Registered
Representative has an incentive to effect securities transactions for the purpose of generating commissions rather
than solely based on the Client’s needs. Clients are not obligated to implement any recommendation provided by the
Advisor nor Advisory Persons. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory fees
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 9
in connection with any products or services implemented in the Advisory Person’s separate capacity as a Registered
Representative. Please see Item 10 below.
Insurance Agency Affiliation
Certain Advisory Persons are licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person may earn commission-based compensation for selling insurance products,
including insurance products offered to Clients. Insurance commissions earned by the Advisory Person are separate
and in addition to investment advisory fees. This practice presents a conflict of interest as an Advisory Person who
is also an insurance professional will have an incentive to recommend insurance products to the Client for the purpose
of generating commissions rather than solely based on the Client’s needs. Clients are under no obligation, contractual
or otherwise, to purchase insurance products through any Advisory Person affiliated with the Advisor. Please see
Item 10 below.
Item 6 – Performance-Based Fees and Side-By-Side Management
Nvest does not charge performance-based fees for its investment advisory services. The fees charged by Nvest
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client.
Nvest 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
Nvest offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses,
charitable organizations, and retirement plans. Nvest generally does not impose a minimum relationship size.
Nvest generally requires a minimum relationship size of $500,000 to effectively implement its investment process.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Nvest primarily employs a fundamental, technical, cyclical, charting analysis methods in developing investment
strategies for its Clients. Research and analysis from Nvest are derived from numerous sources, including financial
media companies, third-party research materials, Internet sources, and review of company activities, including
annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with
a value discounted by the market. While this type of analysis helps 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
the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors
these economic 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.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and
trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk
in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if
the trend will eventually reoccur, there is no guarantee that Nvest will be able to accurately predict such a
reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro
(entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 10
health of the particular company that Nvest is recommending. The risks with cyclical analysis are similar to those of
technical analysis.
Charting analysis utilizes various market indicators as investment selection criteria. These criteria are generally
pricing trends that may indicate movement in the markets. Assets are deemed suitable if they meet certain criteria
to indicate that they are a strong investment with a value discounted by the market. While this type of analysis
helps 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 the technical and charting analysis may lose value and may
have negative investment performance. The Advisor monitors these market indicators to determine if adjustments
to strategic allocations are appropriate.
As noted above, Nvest generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. Nvest will typically hold all or a portion of a security for more than a year but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Nvest 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. Nvest will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will
meet their investment goals. 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 economic 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 investment 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.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large 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.
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
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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.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Digital Assets Risks
Digital assets (i.e., cryptocurrencies) are highly speculative and volatile investments that may become illiquid at any
time. Digital assets are loosely regulated. Clients could lose the entire value of their investment in digital assets and
is only suitable for Clients with a high risk tolerance.
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 Nvest or its owner [OR] management
persons. Nvest 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
or 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# 128868.
Item 10 – Other Financial Industry Activities and Affiliations
Broker-Dealer Affiliation
As noted in Item 5, certain Advisory Persons are also Registered Representatives of PKS. In one’s separate
capacity as a Registered Representative, Advisory Persons will receive commissions for the implementation of
recommendations for commissionable transactions. Clients are not obligated to implement any recommendation
provided by the Advisory Person. Neither the Advisor nor Advisory Persons will earn ongoing investment advisory
fees in connection with any services implemented in the Advisory Person’s separate capacity as a Registered
Representative.
Insurance Agency Affiliation
As noted in Item 5, certain Advisory Persons are licensed insurance professionals. Implementations of insurance
recommendations are separate and apart from one’s role with the Advisor. As an insurance professional, the
Advisory Person will receive customary commissions and other related revenues from the various insurance
companies whose products are sold. Advisory Persons are not required to offer the products of any particular
insurance company. Commissions generated by insurance sales do not offset investment advisory fees. This
presents a conflict of interest in recommending certain products of the insurance companies. Clients are under no
obligation to implement any recommendations made by the Advisor or Advisory Persons.
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 12
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Nvest 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 Nvest (“Supervised Persons”). The Code was developed to
provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Nvest and
its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of
Nvest’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 207-985-8585 or via email at
info@nvestfinancial.com.
B. Personal Trading with Material Interest
Nvest allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Nvest 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. Nvest does not have a material interest
in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Nvest allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed 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 Nvest requiring reporting of personal securities trades by its Supervised Persons for review by the
Chief Compliance Officer (“CCO”) or delegate. 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 Nvest allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no
time will Nvest, or any Supervised Person of Nvest, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Nvest 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 Nvest to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, Nvest does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-
by-trade basis.
Where Nvest does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the
Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Nvest.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged.
Nvest 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, and its reputation and/or the location of the Custodian’s
offices.
Nvest will generally recommend that Clients establish their account[s] with Fidelity Clearing & Custody
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 13
Solutions and affiliated entities of Fidelity Investments, Inc. (collectively “Fidelity”), or Charles Schwab & Co., Inc.
(“Schwab”) where the Advisor maintains an institutional relationship Fidelity, whereby the Advisor receives
economic benefits from Fidelity and Schwab. Please see Item 14 below. In addition, Nvest maintains Prime
Brokerage relationships with several institutions primarily utilized for Client’s fixed income needs.
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. Nvest 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 - Nvest does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Nvest 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]). Nvest will not be obligated to select competitive
bids on securities transactions and does not have an obligation to seek the lowest available transaction costs.
These costs are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. Nvest will execute its transactions through the Custodian as
authorized by the Client. Nvest may aggregate orders in 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 Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by an Advisory Person of the
Advisor. 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 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify Nvest if changes occur in the Client’s
personal financial situation that might adversely 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
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 14
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Nvest
Participation in Institutional Advisor Platform - Fidelity
The Advisor has established an institutional relationship with Fidelity to assist the Advisor in managing Client
account[s]. Access to the Fidelity Institutional platform is provided at no charge to the Advisor. The Advisor receives
access to software and related support without cost because the Advisor renders investment management services
to Clients that maintain assets at Fidelity. The software and related systems support may benefit the Advisor, but
not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its
Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian creates a
potential conflict of interest since these benefits may influence the Advisor’s recommendation of this Custodian over
one that does not furnish similar software, systems support, or services.
Additionally, the Advisor may receive the following benefits from Fidelity: receipt of duplicate Client confirmations
and bundled duplicate statements; access to a trading desk that exclusively services its institutional participants;
access to block trading which provides the ability to aggregate securities transactions and then allocate the
appropriate shares to Client accounts; and access to an electronic communication network for Client order entry
and account information.
Participation in Institutional Advisor Platform - Schwab
Nvest has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like Nvest. As a registered investment advisor
participating on the Schwab Advisor Services platform, Nvest 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 potential 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 Nvest that may not benefit the
Client, including: educational conferences and events, consulting services and discounts for various service
providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which
results in a potential conflict of interest. Nvest believes, however, that the selection of Schwab as Custodian is in
the best interests of its Clients.
B. Compensation for Client Referrals
The Advisor does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 15
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
Nvest 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 Nvest.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will
be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to
such authority. All discretionary trades made by Nvest will be in accordance with each Client's investment
objectives and goals.
Item 17 – Voting Client Securities
Nvest 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 Nvest, nor its management, have any adverse financial situations that would reasonably impair the ability of
Nvest to meet all obligations to its Clients. Neither Nvest, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. Nvest 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.
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 16
Privacy Policy
Effective: March 24, 2026
Our Commitment to You
Nvest Financial, LLC (“Nvest” 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. Nvest (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.
Nvest does not sell your non-public personal information to anyone. Nor do we 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 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
Tax returns and tax documents
Estate, Will, and POA documents
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
SMS Messaging
Nvest’s SMS messaging provides Client with timely and relevant communications directly from the Advisor. Clients
can expect to receive periodic messages that may include notifications about upcoming meetings, responses to
inquiries, and important account-related information. These messages are sent via an SMS application, where all
sensitive data is delivered securely, to maintain the confidentiality and integrity of the Client’s data. No mobile
information will be shared with third parties or affiliates for marketing or promotional purposes, and all other
information, excluding text messaging originator opt-in data and consent, will not be shared with any third parties.
Please note that the frequency and content of these messages will be related to the services to the Client. Clients
have the option to opt out of any SMS communications from Nvest. SMS opt-in and phone numbers collected for
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 17
SMS consent will not be shared with any third party and affiliate company.
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 they 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
Yes
Yes
No
Not Shared
Marketing Purposes
Nvest 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 Nvest or the
client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
Nvest 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
California
In response to a California law, to be conservative, we assume accounts with California addresses do not want us to
disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit
the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws.
Massachusetts
In response to Massachusetts law, the Client 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.
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 18
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
us at 207-985-8585 or via email at info@nvestfinancial.com.
Nvest Financial, LLC
2 International Drive, Suite 110, Portsmouth, NH 03801
Phone: 207-985-8585 * Fax: 207-985-8595
https://www.planwithnvest.com/
Page 19