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Peddock Capital Advisors, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: June 3, 2025
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Peddock Capital Advisors, LLC (“PCA” or the “Advisor”). If you have any questions about the
contents of this Disclosure Brochure, please contact the Advisor at (781) 848-0288 or by email at
msimmons@peddock.com.
PCA is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information about PCA to assist you in determining whether to retain the Advisor.
Additional information about PCA 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# 148216.
NOTE: This document includes PCA’s Form ADV 2A (“Disclosure Brochure”), each Investment Advisor
Representative’s Form ADV 2Bs (“Brochure Supplement”) and PCA’s Privacy Policy.
Peddock Capital Advisors, LLC
1
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.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 Advisory
Persons of PCA. For convenience, the Advisor has combined these documents into a single disclosure
document.
PCA 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. PCA encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the
Advisor.
Material Changes
There have been no material changes to this Disclosure Brochure since the last annual amendment filing on
February 2nd, 2024.
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 in the business practices of PCA.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at http://www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 148216.
You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (781) 848-
0288 or by email at msimmons@peddock.com.
Peddock Capital Advisors, LLC
2
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
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 ...........................................................................................................................................2
D. Wrap Fee Programs ........................................................................................................................................................2
E. Assets Under Management .............................................................................................................................................2
Item 5 – Fees and Compensation .......................................................................................................................... 2
A. Fees for Advisory Services ..............................................................................................................................................3
B. Fee Billing ........................................................................................................................................................................3
C. Other Fees and Expenses...............................................................................................................................................4
D. Advance Payment of Fees and Termination ...................................................................................................................4
E. Compensation for Sales of Securities .............................................................................................................................5
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 5
Item 7 – Types of Clients ........................................................................................................................................ 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 5
A. Methods of Analysis ........................................................................................................................................................5
B. Risk of Loss .....................................................................................................................................................................6
Item 9 – Disciplinary Information .......................................................................................................................... 7
Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 8
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 8
A. Code of Ethics .................................................................................................................................................................8
B. Personal Trading with Material Interest ...........................................................................................................................8
C. Personal Trading in the Same Securities as Clients .......................................................................................................8
D. Personal Trading at the Same Time as Clients ...............................................................................................................8
Item 12 – Brokerage Practices ............................................................................................................................... 8
A. Recommendation of Custodian[s] ...................................................................................................................................8
B. Aggregating and Allocating Trades ...............................................................................................................................10
Item 13 – Review of Accounts.............................................................................................................................. 10
A. Frequency of Reviews ...................................................................................................................................................10
B. Causes for Reviews.......................................................................................................................................................10
C. Review Reports .............................................................................................................................................................10
Item 14 – Client Referrals and Other Compensation ......................................................................................... 10
A. Compensation Received by PCA ..................................................................................................................................10
B. Compensation for Client Referrals ................................................................................................................................10
Item 15 – Custody.................................................................................................................................................. 11
Item 16 – Investment Discretion .......................................................................................................................... 11
Item 17 – Voting Client Securities ....................................................................................................................... 11
Item 18 – Financial Information ........................................................................................................................... 11
Form ADV Part 2B – Brochure Supplements ..................................................................................................... 12
Privacy Policy ........................................................................................................................................................ 26
Peddock Capital Advisors, LLC
3
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Item 4 – Advisory Services
A. Firm Information
Peddock Capital Advisors, LLC (“PCA” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a limited liability company (“LLC”)
under the laws of the Commonwealth of Massachusetts. PCA was founded in September 2008 and is primarily
owned and operated by Peter E. Simmons (President and Managing Shareholder) and Matthew E. Simmons
(Chief Operating Officer and Wealth Advisor). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by PCA. For information regarding this
Disclosure Brochure, please contact John DeSimone, Chief Compliance Officer, at (781) 848-0288 or by email at
jdesimone@peddock.com.
B. Advisory Services Offered
PCA offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses 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. PCA’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
PCA provides customized wealth management solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary and non-discretionary investment
management and related advisory services, including family office bill pay services and a broad range of
comprehensive consultative services.
Investment Management Services - PCA works closely with each Client to identify their investment goals and
objectives, risk tolerance, and financial situation in order to create a portfolio strategy. PCA will then construct a
portfolio consisting of mutual funds, exchange-traded funds (“ETFs”), individual stocks, bonds, and derivatives to
achieve the Client’s investment goals. The Advisor may also utilize other investments types, as appropriate, 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.
Additionally, PCA may render non-discretionary investment management services to Clients relative to variable
life/annuity products that they may own, their individual employer-sponsored retirement plans, and/or 529 plans
or other products that may not be held by the Client’s primary custodian. In so doing, PCA either directs or
recommends the allocation of client assets among the various investment options that are available with the
product. Client assets are maintained at the specific insurance company or custodian designated by the product.
PCA’s investment approach is primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. PCA
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.
PCA evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. PCA may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. PCA may recommend specific positions to increase/decrease sector or asset class weightings. The
Advisor may recommend employing cash positions as a possible hedge against market movement. PCA 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
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk
deemed unacceptable for the Client’s risk tolerance.
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.
Family Office Services - PCA may also offer family office bill pay services to certain Clients as part of the
Advisor’s wealth management services, pursuant to a wealth management agreement. PCA does accept and
maintain custody of Client accounts that have engaged the Advisor for these services. Please see Item 15 for
more information.
PCA will provide investment advisory services and portfolio management services and will not provide securities
custodial services. All Clients must establish a custody and trading relationship with a “qualified custodian”.
Please see Item 12 – Brokerage Practices.
Consulting Services - PCA will typically provide a variety of consulting services to Clients as a part of the
Advisor’s wealth management services. Clients may also engage with PCA for consulting services as a separate,
stand-alone engagement, pursuant to a written agreement. Services are offered in several areas of a Client’s
financial situation, depending on their goals and objectives.
Generally, such consulting services involve rendering a specific financial consultation based on the Client’s
financial goals and objectives. Consulting seeks to address various needs of the Client’s situation, which may
encompass one or more areas of need, including but not limited to: Wealth Transfers; Philanthropy; Estate
Planning; Trust Administration; Real Estate Transfers; Succession Planning; Educational Funding; Insurance
needs; Retirement Planning; Family Governance; Risk Management.
A 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.
PCA may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique
situation. For consulting or ad-hoc engagements, the Advisor may not provide a written summary.
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 wealth
management services or to increase the level of investment assets, 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.
Non-Purpose Loans – When deemed to be in the Client’s best interest, the Advisor will introduce Clients to
available to non-purpose loan programs (“Lending Program”). In such instances, the Client’s assets in their
account[s] at the Custodian will be utilized as collateral for a non-purpose loan. The recommendation of a
Lending Program presents a conflict of interest as the Advisor will continue to receive investment advisory fees
for managing the collateralized assets in the Client’s account[s]. Clients are not obligated to engage the Advisor
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
for the Lending Program. For additional information related to the risks involved non-purpose loans, please see
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss.
Retirement Plan Advisory Services
PCA provides 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 Oversight Services (ERISA 3(21))
Investment Due Diligence and Oversight
•
•
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
These services are provided by PCA 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 PCA’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 PCA to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and
the Client. These services may include:
• Establishing an Investment Policy Statement – PCA, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s investment goals and objectives.
• Asset Allocation – PCA 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 – PCA will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
•
Investment Management and Supervision – PCA will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
PCA does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by PCA.
E. Assets Under Management
As of December 31, 2024 PCA manages $731,548,995 in Client assets, $704,705,474 of which are managed on
a discretionary basis and $26,843,521 on a non-discretionary basis. PCA also oversees and advises on
$2,322,985 in assets under advisement. 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 one or
more written agreements with the Advisor.
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
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 are based on the market value of assets under management at the end of each month.
Wealth management fees range up to 1.00% annually based on several factors, including: the scope and
complexity of the services to be provided; the level 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.
The wealth management fee in the first month is prorated from the inception date of the account to the end of the
month. All securities held in accounts managed by PCA will be independently valued by the Custodian. The Advisor
will conduct periodic reviews of the Custodian’s valuation to ensure accurate billing. Fees are determined at the
sole discretion of the Advisor. Fees may vary from the fee rate above, depending on the nature and complexity of
each Client’s circumstances.
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, or costs.
The Client may make additions or withdrawals from the account[s] at any time, subject to the Advisor’s right to
terminate an account or the overall relationship. Additions may be in cash or securities provided that the Advisor
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 upon notice to PCA, subject to the usual and customary securities
settlement procedures. However, the Advisor typically designs its investment portfolios as long-term investments
and the withdrawal of assets may impair the achievement of a Client’s investment objectives. PCA may consult the
Client about the implications of such transactions. Clients are advised that when such securities are liquidated, they
may be subject to securities transaction fees, short-term redemption fees, and/or tax ramifications.
Consulting Services
PCA’s consulting services are generally included under a wealth management engagement, and provided as part
of the annual asset-based fee set forth above. PCA may, however, pass along certain administrative or overhead
costs to clients that the firm incurs in the course of providing these services (e.g., expenses for an audit of the
accounts over which PCA maintains custody).
Under certain limited circumstances, PCA also charges an hourly-based fee for consulting services. PCA may
charge this hourly fee in the event 1) a non-investment management client engages the firm to provide these
services, or 2) an existing client engages PCA to provide services requiring an excessive amount of time and/or
substantial resources. PCA offers consulting services at rates ranging from $150 to $500 per hour. Fees are based
on the nature and complexity of the services to be provided and the overall relationship with the Advisor.
Retirement Plan Advisory Services
Retirement plan advisory fees are typically paid quarterly, at the end of each calendar quarter, pursuant to the
terms of the retirement plan advisory agreement. Retirement plan advisory fees are either charged a fixed fee or an
annual asset-based fee. Fixed fees range up to $10,000 per year and asset-based fees range up to 0.75% of
assets under management at the end of the quarter. Retirement plan advisory fees are based on the scope and
complexity of the services provided to the Plan and are negotiable at the sole discretion of the Advisor.
B. Fee Billing
Wealth Management Services
Wealth management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at
the Custodian. The Advisor or its delegate shall communicate with the Custodian indicating the amount of the fees
to be deducted from the Client’s account[s] at the respective month-end date. The amount due is calculated by
applying the monthly rate (annual rate divided by 12) to the total market value of each account at the end of each
month. 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
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Custodian’s brokerage statement as the Custodian does not assume this responsibility. Clients provide written
authorization permitting advisory fees to be deducted by PCA 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.
Consulting Services
Consulting fees are invoiced by the Advisor and are billed periodically in arrears based on the number of hours
completed, pursuant to a consulting agreement.
Retirement Plan Advisory Services
Fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the Plan, depending on the terms
of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than PCA, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and execution
fees charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities
transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and
conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds
and other types of investments. The investment advisory fee charged by PCA is separate and distinct from these
custody and execution fees.
In addition, all fees paid to PCA 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 PCA,
but would not receive the services provided by PCA 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
PCA 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
Wealth Management Services
PCA is compensated for its services at the end each month after 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 will incur charges for bona fide advisory services rendered to the point of termination and
such fees will be due and payable by the Client. Upon termination, the Client shall be responsible for wealth
management fees up to and including the effective date of termination. The Client’s wealth management agreement
with the Advisor is non-transferable without the Client’s prior consent.
Consulting Services
PCA is compensated for its consulting services in arrears. Either party may terminate the written agreement, at any
time, by providing advance written notice to the other party. The Client will incur charges for bona fide advisory
services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination,
the Client shall be billed for actual hours logged on the planning project multiplied by the contractual hourly rate.
The Client’s written agreement with the Advisor is non-transferable without the Client’s prior consent.
Retirement Plan Advisory Services
PCA is compensated for its services at the end of the quarter after retirement plan advisory services are rendered.
Either party may request to terminate their services with PCA at any time by providing advance written notice to
the other party. The Client shall be responsible for advisory fees up to and including the effective date of
termination. The Client’s retirement plan services agreement with the Advisor is non-transferable without the
Client’s prior consent.
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
E. Compensation for Sales of Securities
PCA does not buy or sell securities and does not receive any compensation for securities transactions in any
Client account[s], other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
PCA does not charge performance-based fees for its investment advisory services. The fees charged by PCA
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held
by any Client.
PCA 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
PCA offers investment advisory services to individuals, high net worth individuals, trusts, estates, charitable
organizations, businesses and retirement plans. 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.
PCA does not impose a minimum size for establishing a relationship.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
PCA primarily employs a combination of inherently fundamental and technical analysis methods in developing
investment strategies for its Clients. Research and analysis from PCA is 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. These criteria
are generally 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 PCA will be able to accurately predict
such a reoccurrence.
As noted above, PCA generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. PCA determines an appropriate asset allocation target for each client, consisting of target
weightings for both equity and fixed income holdings. The target allocation is based upon an evaluation of the
Client’s individual investment goals, risk tolerance, and anticipated liquidity needs. The allocation mix is generally
kept as close to the target as possible, giving consideration to the transaction costs of rebalancing. The firm uses
a tactical allocation approach when relative market valuations fall outside pre-determined thresholds.
Peddock Capital Advisors, LLC
PCA generally retains discretion over client assets and, where liquidity and account size are sufficient, invests
client assets directly in a portfolio of stocks and bonds. The equity portion of client portfolios is generally in large
capitalization U.S. stocks, and is generally benchmarked against the S&P 500 Index. PCA’s determines its
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
security selection utilizing a variety of sources, ranging from internal capital market expectations and analysis, to
outside research services subscriptions from Zack’s Advisor Tools and FactSet.
For a portion of Client assets managed in the “Global Macro” investment program, holdings consist of liquid, U.S.
traded vehicles, such as ETFs or mutual funds. The Global Macro investment process is intended to reflect the
firm’s top-down or macroeconomic investment views. PCA develops said views through a variety of channels,
including wide reading (newspapers, third-party research, blogs, SEC filings, etc.), primary research on economic
data gathered from the Federal Reserve. This portion of a client’s portfolio is designed in an effort to take
advantage of alpha generating ideas and is not intended to be income tax sensitive. Depending upon the client’s
situation, this portion of the portfolio may be relatively small as compared to portfolio-wide holdings.
When constructing client bond portfolios, PCA considers the client’s tax status to determine whether tax-exempt
municipal bonds, U.S. Treasury bonds, or taxable corporate, municipal, or agency bonds are most appropriate.
Once tax issues have been addressed, the firm selects individual bonds with yield, liquidity, duration, and time-
to-maturity that meet the client’s individual goals and needs. For those clients with large, identifiable cash
outflows on the horizon, PCA attempts to coordinate these cash needs using bonds of equal maturity.
Accordingly, PCA generally does not invest in bonds below investment grade (i.e., S&P BBB-; Moody’s Baa3).
In those client accounts for which a portfolio of direct stock and bond investments is impractical (due to small
account size), PCA uses liquid, U.S. traded ETFs or mutual funds to attain the target equity and fixed income
allocations.
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. PCA 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.
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 discussed with 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 approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETF has a large
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
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.
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.
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 or bond redemptions must be
reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that cost of living and
inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s real 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 market’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 and there could be material implications on execution price.
Derivative Risks
Derivatives are difficult to define but are present in a wide variety of investments. In finance, derivatives refer to
contracts whose value is derived from another asset, which include stocks, bonds, currencies, interest rates,
commodities, and related indexes. Often times derivatives are used as a hedge to protect against downside risk,
but derivatives can also be used to speculate. Purchasers of derivatives are essentially wagering on the future
performance of that asset. Derivatives include such widely accepted products as futures and options. Due to the
speculative nature of derivatives, even when they are being employed to hedge, unique risks are present
including a party’s misunderstanding of the contract, inability of the derivative to match or derive its value from
the other asset, liquidity risks, and the counterparty risk between the parties to the transaction.
Non-Purpose Loans
Non-Purpose Loans carry a number of risks, including but not limited to the risk of a market downturn, tax
implications if collateralized securities are liquidated, and an increase in interest rates. A decline in the market
value of collateralized assets held in the account[s] at the Custodian, may result in a reduction in the draw
amount of the Client’s loan, a demand from the Lending Program that the Client deposit additional funds or
securities in the Client’s collateral account[s], or a forced sale of securities in the Client’s collateral account[s].
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 PCA or any of its management persons.
PCA 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# 148216.
Peddock Capital Advisors, LLC
7
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Item 10 – Other Financial Industry Activities and Affiliations
Tax and Accounting Services
The Advisor offers tax and accounting services, which is made available through Peddock Tax Services, LLC
(“PTS”), a firm under the ownership of PCA and John DeSimone. The cost for these services are separate and in
addition to our investment advisory fees noted above. The Advisor and Mr. DeSimone is entitled to the additional
revenue generated by PTS, presenting a conflict of interest. Clients are under no obligation to engage the
Advisor and PTS for these services.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
PCA 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 PCA (“Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the Client. PCA
and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation
of PCA’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 (781) 848-0288 or via email at
jdesimone@peddock.com.
B. Personal Trading with Material Interest
PCA allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. PCA 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. PCA does not have a material
interest in any securities traded in Client accounts.
C. Personal Trading in the Same Securities as Clients
PCA 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 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 PCA requiring reporting of personal securities trades made by its Supervised Persons for review by
the Chief Compliance Officer (“CCO”) or delegate. The Advisor also has adopted written policies and procedures
to detect the misuse of material non-public information.
D. Personal Trading at the Same Time as Clients
While PCA 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 traded either at the same time or afterwards. At no time
will PCA, or any Supervised Person of PCA, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
PCA does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will select the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize PCA to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, PCA does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-
by-trade basis.
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Where PCA does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. Clients are not obligated to use the recommended Custodian and will
not incur any extra fee or cost from the Advisor associated with using a custodian not recommended by PCA.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not
engaged. PCA may recommend the Custodian based on criteria such as, but not limited to, reasonableness of
commissions charged to the Client, services made available to the Client, its reputation, and/or the location of the
Custodian’s offices.
PCA will generally recommend that Clients establish their account[s] with Fidelity Clearing & Custody
Solutions and affiliated entities of Fidelity Investments, Inc. (collectively “Fidelity”), where the Advisor maintains
an institutional relationship Fidelity, whereby the Advisor receives economic benefits from Fidelity. Please see
Item 14 below. In addition, PCA 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. PCA does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodians. However, the Advisor may receive certain economic benefits from Fidelity. Please see
Item 14 below.
2. Brokerage Referrals - PCA 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 PCA 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). PCA 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.
From time to time, the Client may need to sell a security that the Advisor thinks is a good fit for another Client’s
account. In this case, PCA may wish to execute an internal cross transaction of fixed income securities between
clients. PCA will only do this when the proposed transaction is in the best interests of both clients. PCA
acknowledges its duty to seek best execution for Clients and acknowledges that the use of cross transactions
raises conflict of interest concerns under the Investment Advisers Act of 1940, Section 206(3) and Section
206(4). Therefore, cross transactions are only considered when the need to liquidate securities results in an
availability of securities that are appropriate for another Client account[s]. PCA prohibits the need to purchase
securities as the sole reason for identifying sale candidates nor does it allow the need to sell an issue as the sole
reason for purchase of such by another client. When affecting a cross transaction, PCA does not act either as
principal or agent through a broker/dealer or otherwise receive commissions or any type of compensation for
effecting cross trades. PCA’s sole intent for doing a cross trade is to act in the best interest of each client in
accordance with their respective investment objectives. Cross trades are an exception to PCA’s normal operating
procedures and are only used when it is advantageous to both Client accounts in the absence of appropriate and
comparable alternatives. PCA prospectively requires written consent from all participating parties to authorize
cross trades. Additionally, PCA will deliver written confirmations before or at the completion of the cross trade
that includes 1) the nature of the trade; 2) the date of the transaction; 3) an offer to furnish the time of the trade;
and 4) the source and amount of any remuneration received by the Advisor. The Advisor will deliver annual
written reports to each client that participated in cross transactions containing the total number of transactions
enacted since the last distribution. All confirmations and reports provided by the Advisor will contain language
that the cross transaction may be revoked upon written notice.
Peddock Capital Advisors, LLC
9
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
B. Aggregating and Allocating Trades
PCA may aggregate or “batch” trades as 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. PCA
will execute each transaction through the Custodian designated by the Client. PCA will seek to execute securities
transactions by the close of each business day and securities will 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 Advisory Persons of PCA.
Formal reviews are generally conducted at least annually. For those clients for whom PCA provides family office
and/or consulting services, reviews are conducted on an “as needed” basis.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13A above, 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 PCA 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 online. 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 detailing their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by PCA
Participation in Institutional Advisor Platform
The Advisor has established an institutional relationship with Fidelity to assist the Advisor in managing Client
account[s]. Access to the Fidelity Institutional platform is provided at no charge to the Advisor. The Advisor
receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Fidelity. The software and related systems support may
benefit the Advisor, but not its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all
times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic
benefits from a Custodian creates a 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.
B. Compensation for Client Referrals
If a Client is introduced to the Advisor by either an unaffiliated or affiliated party (herein a “Promoter”), the Advisor
compensates that Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
state securities requirements. Any such compensation shall be paid solely from the investment advisory fees
earned by the Advisor, and shall not result in any additional charge to the Client.
Item 15 – Custody
PCA has “custody” of client accounts as defined in Rule 206(4)-2 under the Investment Advisers Act of 1940 as
the Advisor may also serve as Trustee of certain Client’s account[s]. In addition, the Advisor offers family office
bill pay services to certain Clients as part of its comprehensive wealth management services. All Clients must
place their assets with a “qualified custodian”. Clients are required to enter into an agreement with the Custodian
to retain their funds and securities and direct PCA to utilize the Custodian for the Client’s security transactions.
Clients should review statements provided by the Custodian and compare to any reports provided by PCA to
ensure accuracy 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 be
deemed to have custody of those assets. In order to avoid additional regulatory requirements in these cases, the
Custodian and the Advisor have adopted safeguards to ensure that the money movements are completed in
accordance with the Client’s instructions.
Surprise Independent Examination
As PCA is deemed to have custody over certain Client accounts and/or securities as part of its family office
and/or trustee services, pursuant to securities regulations the Advisor is required to engage an independent
accounting firm to perform an annual surprise examination of those assets and accounts over which PCA
maintains custody. Any related opinions issued by an independent accounting firm are filed with the SEC and are
publicly available on the SEC’s Investment Adviser Public Disclosure website (http://adviserinfo.sec.gov).
Item 16 – Investment Discretion
PCA 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 PCA.
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 PCA will be in accordance with each Client's investment
objectives and goals.
Item 17 – Voting Client Securities
PCA may vote client securities (proxies) on behalf of its clients. When PCA accepts such responsibility, it
generally will cast proxy votes in alignment with management, and in a manner consistent with the best interest
of its clients. Clients may contact PCA to request information about how PCA voted proxies for that client’s
securities. If PCA and/or its Advisory Persons have interest in the outcome of certain proxy votes due to business
or personal relationships, this is a conflict of interest, where PCA takes appropriate steps to ensure that its proxy
voting decisions are made in the best interest of its clients and are not the product of such conflict.
Item 18 – Financial Information
Neither PCA, nor its management has any adverse financial situations that would reasonably impair the ability of
PCA to meet all obligations to its Clients. Neither PCA nor any of its Advisory Persons has been subject to a
bankruptcy or financial compromise. PCA is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect fees of $1,200 or more for services to be performed six months or more
in advance.
Peddock Capital Advisors, LLC
11
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Form ADV Part 2B – Brochure Supplement
for
Peter E. Simmons
Chief Executive Officer
Effective: June 3, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Peter E. Simmons (CRD# 4379811) in addition to the information contained in the Peddock Capital Advisors,
LLC (“PCA” or the “Advisor”, CRD# 148216) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the PCA Disclosure Brochure or this
Brochure Supplement please contact the Advisor at (781) 848-0288 or by email at msimmons@peddock.com.
Additional information about Mr. Simmons 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# 4379811.
Peddock Capital Advisors, LLC
12
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Item 2 – Educational Background and Business Experience
Peter E. Simmons, born in 1961, is dedicated to advising Clients of PCA as the Chief Executive Officer. Mr.
Simmons earned a JD from Suffolk University Law School in 1990. Mr. Simmons also earned a B.S. in Business
from University of Massachusetts Dartmouth in 1984. Additional information regarding Mr. Simmons’s
employment history is included below.
Employment History:
10/2008 to Present
01/1999 to 03/2008
Chief Executive Officer, Peddock Capital Advisors, LLC
President, Investment Advisor, Wilmington Trust (FKA Bingham Legg Advisers LLC)
Director of Fiduciary Services, Bingham McCutchen LLP (FKA Bingham Dana &
Gould)
Senior Vice-President and Senior Trust Officer, Bangor Saving Bank
Vice-President of Investment Services, Fleet Investment Services, Inc
Trust Legal Analyst, Boston Safe Deposit & Trust Company
06/1996 to 01/1999
04/1992 to 06/1996
01/1988 to 04/1992
09/1984 to 01/1988
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Simmons. Mr. Simmons 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. Simmons. 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. Simmons. The Advisor encourages you to independently view the background of Mr.
Simmons on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his
full name or his Individual CRD# 4379811.
Item 4 – Other Business Activities
Treasurer/Secretary/Director:
Mr. Simmons also serves as Treasurer, Secretary, and Director of RH Investment Corporation, a personal
holding company located at 50 Braintree Hill Office Park, Suite 207, Braintree, MA 02184. Mr. Simmons
manages quarterly meetings, coordinates state filings, interacts with company accountants and auditors, and
maintains meeting minutes. Mr. Simmons does not receive any compensation for this business activity.
Pointe West Country Club
Mr. Simmons also serves a Member and owner of Pointe West Country Club, where performs financial oversight
for the club. This activity takes up less than 10% of his time.
Item 5 – Additional Compensation
Mr. Simmons has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Simmons serves as the Chief Executive Officer of PCA and is supervised by John DeSimone, the Chief
Compliance Officer. John DeSimone can be reached at (781) 848-0288.
PCA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of PCA. Further, PCA is subject to regulatory oversight by various
agencies. These agencies require registration by PCA and its Supervised Persons. As a registered entity, PCA is
subject to examinations by regulators, which may be announced or unannounced. PCA 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.
Peddock Capital Advisors, LLC
13
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Form ADV Part 2B – Brochure Supplement
for
Matthew E. Simmons, CFP®
Chief Operations Officer & Wealth Advisor
Effective: June 3, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Matthew E. Simmons (CRD# 6704411) in addition to the information contained in the Peddock Capital Advisors,
LLC (“PCA” or the “Advisor”, CRD # 148216) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the PCA Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (781) 848-0288 or by email at msimmons@peddock.com.
Additional information about Mr. Simmons 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# 6704411.
Peddock Capital Advisors, LLC
14
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Item 2 – Educational Background and Business Experience
Matthew E. Simmons, born in 1986, is dedicated to advising Clients of PCA as the Chief Operations Officer and
a Wealth Advisor. Mr. Simmons earned a B.S. in Business Administration and Management from University of
Tampa in 2008. Additional information regarding Mr. Simmons’s employment history is included below.
Employment History:
Chief Operations Officer, Wealth Advisor, Peddock Capital Advisors, LLC
Database Marketing Assistant, Quadrant Software, LLC
Investment Analyst Intern, Bingham Legg Advisers, LLC
12/2008 to Present
06/2008 to 08/2008
05/2007 to 07/2007
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 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®
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Professional’s service. 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. Simmons. Mr. Simmons 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. Simmons.
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. Simmons.
The Advisor encourages you to independently view the background of Mr. Simmons on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 6704411.
Item 4 – Other Business Activities
Mr. Simmons is dedicated to the investment advisory activities of PCA’s Clients. Mr. Simmons does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Simmons has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Simmons serves as the Chief Operations Officer and a Wealth Advisor of PCA and is supervised by John
DeSimone, the Chief Compliance Officer. John DeSimone can be reached at (781) 848-0288.
PCA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of PCA. Further, PCA is subject to regulatory oversight by various
agencies. These agencies require registration by PCA and its Supervised Persons. As a registered entity, PCA is
subject to examinations by regulators, which may be announced or unannounced. PCA 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.
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Form ADV Part 2B – Brochure Supplement
for
Katelyn S. Mahon, CFP®
Director of Relationship Management
Effective: June 3, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Katelyn S. Mahon (CRD# 620824) in addition to the information contained in the Peddock Capital Advisors, LLC
(“PCA” or the “Advisor”, CRD # 148216) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the PCA Disclosure Brochure or this Brochure
Supplement, please contact the Advisor at (781) 848-0288 or by email at msimmons@peddock.com.
Additional information about Ms. Mahon is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 620824.
Peddock Capital Advisors, LLC
17
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Item 2 – Educational Background and Business Experience
Katelyn S. Mahon, born in 1991, is dedicated to advising Clients of PCA as the Director of Relationship
Management. Ms. Mahon earned B.S. in Financial Management from Clemson University in 2013. Additional
information regarding Ms. Mahon’s employment history is included below.
Employment History:
Director of Relationship Management, Peddock Capital Advisors, LLC
Financial Advisor, Vanguard
Client Relationship Representative, Vanguard
Fitness Instructor, Clemson University
Intern, Peddock Capital Advisors
Waitress/Hostess, Country Club of New Bedford
02/2016 to Present
05/2015 to 02/2016
06/2013 to 05/2015
12/2010 to 05/2013
05/2010 to 08/2012
03/2007 to 06/2009
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 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:
Peddock Capital Advisors, LLC
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50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
• 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 service. 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 Ms. Mahon. Ms. Mahon has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Ms. Mahon.
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 Ms. Mahon.
The Advisor encourages you to independently view the background of Ms. Mahon on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual
CRD# 620824.
Item 4 – Other Business Activities
Ms. Mahon is dedicated to the investment advisory activities of PCA’s Clients. Ms. Mahon does not have any
other business activities.
Item 5 – Additional Compensation
Ms. Mahon is dedicated to the investment advisory activities of PCA’s Clients. Ms. Mahon does not receive any
additional forms of compensation.
Item 6 – Supervision
Ms. Mahon serves as the Director of Relationship management of PCA and is supervised by John DeSimone,
the Chief Compliance Officer. John DeSimone can be reached at (781) 848-0288.
PCA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of PCA. Further, PCA is subject to regulatory oversight by various
agencies. These agencies require registration by PCA and its Supervised Persons. As a registered entity, PCA is
subject to examinations by regulators, which may be announced or unannounced. PCA 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.
Peddock Capital Advisors, LLC
19
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Form ADV Part 2B – Brochure Supplement
for
Ian G. Browning, CFA®
Partner and Director of Investment Strategy
Effective: June 3, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of Ian
G. Browning (CRD# 6704499) in addition to the information contained in the Peddock Capital Advisors, LLC
(“PCA” or the “Advisor”, CRD # 148216) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the PCA Disclosure Brochure or this Brochure
Supplement, please contact the Advisor at (781) 848-0288 or by email at msimmons@peddock.com.
Additional information about Mr. Browning 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# 6704499.
Peddock Capital Advisors, LLC
20
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Item 2 – Educational Background and Business Experience
Ian G. Browning, born in 1985, is dedicated to advising Clients of PCA as a Partner and Director of Investment
Strategy. Mr. Browning earned a B.S, in Finance and a B.S. in Accounting from Northeastern University in 2008.
Additional information regarding Mr. Browning’s employment history is included below.
Employment History:
Partner and Director of Investment Strategy, Peddock Capital Advisors, LLC
Pension Fund Accountant, JPMorgan
FX Intern, State Street Global Advisors
Accounting Intern, Fidelity Investments
07/2012 to Present
01/2008 to 07/2012
01/2005 to 01/2007
01/2004 to 01/2005
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. In addition, 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. Chartered
Financial Analyst and CFA are trademarks owned by CFA Institute.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Browning. Mr. Browning 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. Browning. 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. Browning. The Advisor encourages you to independently view the background of Mr.
Browning on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his
full name or his Individual
CRD# 6704499.
Item 4 – Other Business Activities
Mr. Browning is dedicated to the investment advisory activities of PCA’s Clients. Mr. Browning does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Browning is dedicated to the investment advisory activities of PCA’s Clients. Mr. Browning does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Browning serves as a Partner and Director of Investment Strategy of PCA and is supervised by John
DeSimone, the Chief Compliance Officer. John DeSimone can be reached at (781) 848-0288.
PCA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of PCA. Further, PCA is subject to regulatory oversight by various
agencies. These agencies require registration by PCA and its Supervised Persons. As a registered entity, PCA is
subject to examinations by regulators, which may be announced or unannounced. PCA is required to periodically
Peddock Capital Advisors, LLC
21
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
update the information provided to these agencies and to provide various reports regarding the business
activities and assets of the Advisor.
Peddock Capital Advisors, LLC
22
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Form ADV Part 2B – Brochure Supplement
for
John F. DeSimone, CIMA®
President, General Counsel, & Chief Compliance Officer
Effective: June 3, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
John F. DeSimone, CIMA® (CRD# 2301047) in addition to the information contained in the Peddock Capital
Advisors, LLC (“PCA” or the “Advisor”, CRD# 148216) Disclosure Brochure. If you have not received a copy of
the Disclosure Brochure or if you have any questions about the contents of the PCA Disclosure Brochure or this
Brochure Supplement, please contact us at (781) 848-0288 or by email at msimmons@peddock.com.
Additional information about Mr. DeSimone 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# 2301047.
Peddock Capital Advisors, LLC
23
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Item 2 – Educational Background and Business Experience
John F. DeSimone, CIMA®, born in 1970, is dedicated to advising Clients of PCA as the President, General
Counsel and Chief Compliance Officer. Mr. DeSimone earned a JD MBA from University of Baltimore in 1996.
Mr. DeSimone also earned a Bachelor of Science degree in Business Adminstration from Bryant Univeristy in
1992. Mr. DeSimone also earned a LLM. in Taxation from Boston University School of Law in 2002. Additional
information regarding Mr. DeSimone’s employment history is included below.
Employment History:
01/2021 to Present
President, General Counsel, Chief Compliance Officer, Peddock Capital
Advisors, LLC
Partner, Dakota Wealth, LLC
Attorney, GML Associates, LLC
01/2007 to 12/2020
01/2019 to 12/2020
Certified Investment Management AnalystSM (CIMA®)
The CIMA certification signifies that an individual has met initial and ongoing experience, ethical, education, and
examination requirements for investment management consulting, including advanced investment management
theory and application. To earn CIMA certification, candidates must: submit an application, pass a background
check and have an acceptable regulatory history; pass an online Qualification Examination; complete an in-
person or online executive education program at an AACSB accredited university business school; pass an
online Certification Examination; and have an acceptable regulatory history as evidenced by FINRA Form U-4 or
other regulatory requirements and have three years of financial services experience at the time of certification.
CIMA certificates must adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules
and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education credits,
including two ethics hours, every two years to maintain the certification. The designation is administered through
the Investment Management Consultants Association (IMCA).
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. DeSimone. Mr. DeSimone 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. DeSimone.
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. DeSimone.
However, we do encourage you to independently view the background of Mr. DeSimone on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual
CRD# 2301047.
Item 4 – Other Business Activities
JFD Associates, PLLC
Mr. DeSimone is an attorney with JFD Associates, PLLC and is compensated in this role. Mr. DeSimone spends
less than 10% of his time in this role. Peddock will be referring business where additional compensation will be
received.
Peddock Tax Services
Mr. DeSimone has ownership interest in Peddock Tax Services, LLC (“PTS”). Mr. DeSimone is entitled to the
additional revenue generated by PTS, presenting a conflict of interest. Clients are under no obligation to engage
PTS for these services.
Peddock Capital Advisors, LLC
24
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Item 5 – Additional Compensation
Mr. DeSimone has additional business activities where compensation is received that are detailed in Item 4
above.
Item 6 – Supervision
Mr. DeSimone serves as the President, General Counsel, and Chief Compliance Officer of PCA. Mr. DeSimone
can be reached at (781) 848-0288.
PCA has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person
in meeting their fiduciary obligations to Clients of PCA. Further, PCA is subject to regulatory oversight by various
agencies. These agencies require registration by PCA and its Supervised Persons. As a registered entity, PCA is
subject to examinations by regulators, which may be announced or unannounced. PCA 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.
Peddock Capital Advisors, LLC
25
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
Privacy Policy
Effective: June 3, 2025
Our Commitment to You
Peddock Capital Advisors, LLC (“PCA” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients 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. PCA 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.
PCA 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?
Assets and liabilities
Date of Birth, Driver’s License Number, Social
Security Number or Taxpayer Identification
Number
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
Account applications and forms
Other advisory agreements and legal documents
Investment questionnaires and suitability
documents
Transactional information with us or others
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 they
receive from us.
Peddock Capital Advisors, LLC
26
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com
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
PCA 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 PCA 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
PCA 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 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.
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 (781) 848-0288.
Peddock Capital Advisors, LLC
27
50 Braintree Hill Office Park, Suite 207 Braintree, MA 02184
Phone: (781) 848-0288
https://www.peddock.com