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Item 1: Cover Page
Perennial Advisors Group, LLC
Form ADV Part 2A
Investment Adviser Brochure
270 Littleton Road, Suite 19
Westford, MA 01886
(978) 577-6025
www.perennialadvisorsgroup.com
January 2026
This Brochure provides information about the qualifications and business practices of Perennial
Advisors Group, LLC (“we”, “us”, “our”). If you have any questions about the contents of this
Brochure, please contact Kelsey L. Brennan, Chief Compliance Officer, Principal and Financial
Advisor at (978) 577-6025 or kelsey@perennialadvisorsgroup.com.
Additional information about our Firm is also available at www.adviserinfo.sec.gov. The
information in this Brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any state securities authority.
We are a registered investment adviser. Please note that use of the term “registered
investment advisor” and a description of the Firm and/or our employees as “registered” does
not imply a certain level of skill or training. For more information on the qualifications of the
Firm and our employees who advise you, we encourage you to review this Brochure and the
Brochure Supplement(s).
Item 2: Material Changes
In this Item of Perennial Advisors Group, LLC’s (“Perennial”, “we”, “us”, “our”) Form ADV 2, we
are required to discuss any material changes that have been made to Form ADV since the last
Annual Amendment.
Material Changes since the Last Update
Since the filing of our Annual Amendment on March 4, 2025, we have the following material
changes to report:
• This Form was updated to reflect a change in ownership. Please see Item 4 (Advisory
Services).
• This Form was updated to reflect a change in fees. Please see Item 5 (Fees and
Compensation).
Annual Update
You will receive a summary of any material changes to our Form ADV brochure within 120 days
of our fiscal year end. We may also provide updated disclosure information about material
changes on a more frequent basis. Any summaries of changes will include the date of the last
annual update of the ADV.
The Supplement to our Form ADV Brochure (Form ADV Part 2B) provides you with information
regarding our employees that provide investment advice.
Full Brochure Available
Our Form ADV may be requested at any time, without charge by contacting Kelsey L. Brennan,
Chief Compliance Officer, Principal and Financial Advisor, at (978) 577-6025 or
kelsey@perennialadvisorsgroup.com.
Additional information about the Firm is also available via the SEC’s website at
www.adviserinfo.sec.gov. The SEC’s website also provides information about any employees
affiliated with the Firm who are registered as investment adviser representatives.
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Item 3: Table of Contents
Item 1: Cover Page .......................................................................................................................1
Item 2: Material Changes .............................................................................................................2
Item 4: Advisory Services .............................................................................................................4
Item 5: Fees and Compensation ..................................................................................................7
Item 6: Performance-Based Fees and Side-By-Side Management ..............................................11
Item 7: Types of Clients ................................................................................................................12
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ........................................13
Item 9: Disciplinary Information ..................................................................................................15
Item 10: Other Financial Industry Activities and Affiliations .......................................................16
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 17
Item 12: Brokerage Practices .......................................................................................................19
Item 13: Review of Accounts .......................................................................................................21
Item 14: Client Referrals and Other Compensation ....................................................................22
Item 15: Custody ..........................................................................................................................23
Item 16: Investment Discretion ...................................................................................................24
Item 17: Voting Client Securities .................................................................................................25
Item 18: Financial Information ....................................................................................................26
Form ADV Part 2B: Investment Advisor Brochure Supplement ..................................................27
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Item 4: Advisory Services
Firm Information
This Disclosure Brochure (“Form ADV Part 2”) provides information regarding the qualifications,
business practices, and the advisory services provided by Perennial Advisors Group, LLC’s
(“Perennial”, or “the Firm”, “we”, “us”, “ours”).
We are a federally Registered Investment Adviser with the U.S. Securities and Exchange
Commission (“SEC”). We were founded in 1998 and are owned and operated by David A.
Carpenter, Managing Member and Principal, Kelsey L. Brennan, Chief Compliance Officer,
Principal and Financial Advisor, Tyler B. Dostie, Financial Advisor, and the Memento Trust.
We are strictly a fee-only financial planning and investment management firm. We do not sell
annuities, insurance, stocks, bonds, mutual funds, limited partnerships, or other commissioned
products. We are not affiliated with entities that sell financial products or securities. No
commissions in any form are accepted. No finder’s fees are accepted.
Types of Advisory Services
Wealth Management Services
We provide wealth management services, which generally includes a broad range of
comprehensive financial planning, consulting services in connection with discretionary
management of investment portfolios and the preparation of tax returns. These services are
described below.
Investment Management Services
We provide customized investment advisory solutions. This is achieved through continuous
personal contact and interaction while providing discretionary investment management and
related advisory services. We work closely with each client to identify their investment goals
and objectives as well as risk tolerance and financial situation in order to create a portfolio
strategy. We will then construct a portfolio comprised of diversified mutual funds, including
those offered by Dimensional Fund Advisors (“DFA”) and ETFs which follow a passive asset class
investment philosophy with low holdings turnover. The DFA fund fees are generally lower than
fees and expenses charged by other fund providers. We are under no obligation to recommend
DFA funds to clients and do so only when it is believed to be in the client’s best interest. We
may also utilize individual stocks or bonds to meet the needs of clients, and we may retain
certain legacy investments based on portfolio fit and/or tax considerations.
Our investment approach is primarily long-term focused, but we 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. We will construct, implement and monitor the portfolio to ensure it
meets the goals, objectives, circumstances, and risk tolerance agreed to by the client.
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We evaluate and select investments for inclusion in client portfolios only after applying our
internal due diligence process. We may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. We may recommend specific positions to increase sector
or asset class weightings. We may recommend employing cash positions as a possible hedge
against market movement. We may recommend selling positions for reasons that include, but
are not limited to, harvesting capital gains or losses, business or sector risk exposure to a
specific security or class of securities, overvaluation or overweighting of the position[s] in the
portfolio, change in risk tolerance of the client, generating cash to meet client needs, or any risk
deemed unacceptable for the client’s risk tolerance.
Financial Planning Services
We will typically provide a variety of financial planning services to clients as part of our wealth
management services or as a stand-alone service. Services are offered in several areas of a
client’s financial situation, depending on their goals and objectives.
Generally, financial planning services involve preparing a formal financial plan based on the
client’s financial goals and objectives. This planning or consulting may encompass one or more
areas of need, including but not limited to, investment planning, retirement planning, personal
savings, education savings and other areas of a client’s financial situation.
A financial plan developed for 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.
We may also refer clients to an accountant, attorney or another specialist, as appropriate for
their unique situation. For certain financial planning engagements, we will provide a written
summary of the client’s financial situation, observations, and recommendations. For consulting
or ad-hoc engagements, we may not provide a written summary. Plans or consultations are
typically completed within six months of contract date, assuming all information and
documents requested are provided promptly.
Tailored Relationships
We tailor investment advisory services to the individual needs of the client. Our clients are
allowed to impose restrictions on the investments in their account. All limitations and
restrictions placed on accounts must be presented to us in writing.
Wrap Fee Programs
A “wrap-fee” program is one that provides the client with advisory and brokerage execution
services for an all-inclusive fee. The client is not charged separate fees for the respective
components of the total service. We do not sponsor, manage or participate in a Wrap Fee
Program.
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Fiduciary Statement
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment
advice to you regarding your retirement plan account or individual retirement account, we are
also fiduciaries 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.
We have to act in your best interest and not put our interest ahead of yours. At the same time,
the way we make money creates some conflicts with your interests. We must take into
consideration each client’s objectives and act in the best interests of the client. We are
prohibited from engaging in any activity that is in conflict with the interests of the client. We
have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial
circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented
in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to
provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably.
Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material
fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as
fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client.
We will act with competence, dignity, integrity, and in an ethical manner, when working with
clients. We will use reasonable care and exercise independent professional judgement when
conducting investment analysis, making investment recommendations, trading, promoting our
services, and engaging in other professional activities.
Assets Under Management
As of February 6, 2025, we managed $324,022,399 in client assets, all of which are managed on
a discretionary basis.
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Item 5: Fees and Compensation
Fees for Advisory Services
We base our fees on a percentage of assets under management and various fixed fees, which
are described below.
Compensation – Wealth Management Services
For Wealth Management services, clients are assigned varying fee schedules under one of the
following fee structures: a percentage of assets under management using a tiered, graduated
fee schedule, a flat percentage-based fee, or a flat annual fee. As a result, some clients may pay
a fee that is higher or lower than other clients. Fees are negotiable based on a variety of
factors, including, but not limited to the amount of their assets, type of portfolio, the length of
the relationship, the degree of responsibility assumed, complexity of the engagement, special
skills needed to solve problems, and the application of experience and knowledge of the client’s
situation.
Some legacy clients are charged a flat Wealth Management fee ranging up to $35,000 annually.
Some clients are charged a percentage of assets under management, up to 1.5%.
Fees are billed on a quarterly basis, in arrears, based upon the market value of the accounts,
including cash, on the last day of the previous quarter as valued by the Custodian.
Compensation – Financial Planning Services
We typically offer financial planning services as part of our Wealth Management Services,
however, should the client engage us for stand-alone financial planning services, we charge a
fixed fee of $5,000. Financial planning fees are invoiced by us upon completion of the agreed
upon deliverable[s] and are due upon receipt of our invoice.
Calculation and Payment
The specific manner in which we charge fees is established in a client’s written agreement with
us. Clients may elect to be invoiced directly for fees or to authorize us to directly debit fees
from client accounts.
Other Fees
There are no additional types of fees or expenses that our clients pay in connection with the
delivery of advisory services.
Agreement Terms
Either party may terminate an agreement at any time by notifying the other in writing. If the
client made an advance payment, we would refund any unearned portion of the advance
payment. If the client made a payment in arrears, we would collect any earned yet unpaid fees.
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Investment Management Services
We are compensated for investment management services at the end of the quarter after
services are rendered. Either party may terminate the investment advisory agreement, at any
time, by providing advance written notice to the other party.
Financial Planning Services
We are compensated for financial planning services upon completion of the engagement
deliverable[s]. Either party may terminate the financial planning agreement, at any time, by
providing advance written notice to the other party. The client may also terminate the financial
planning agreement within five (5) business days of signing the agreement at no cost. After the
five-day period, the client will incur charges for bona fide advisory services rendered to the
point of termination and such fees will be due and payable by the client.
Cash Balances
Some of your assets may be held as cash and remain uninvested. Holding a portion of your
assets in cash and cash alternatives, i.e., money market fund shares, may be based on your
desire to have an allocation to cash as an asset class, to support a phased market entrance
strategy, to facilitate transaction execution, to have available funds for withdrawal needs or to
pay fees or to provide for asset protection during periods of volatile market conditions. Your
cash and cash equivalents will be subject to our investment advisory fees unless otherwise
agreed upon. You may experience negative performance on the cash portion of your portfolio if
the investment advisory fees charged are higher than the returns you receive from your cash.
Retirement Plan Rollover Recommendations
As part of our investment advisory services to our clients, we may recommend that clients roll
assets from their employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account
(collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP
IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will advise on the
client’s behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from
Plan Accounts to Plan Accounts, and from IRA Accounts to IRA Accounts.
If the client elects to roll the assets to an IRA that is subject to our advisement, we will charge
the client an asset-based fee as set forth in the advisory agreement the client executed with our
firm. This creates a conflict of interest because it creates a financial incentive for our firm to
recommend the rollover to the client (i.e., receipt of additional fee-based compensation).
Clients are under no obligation, contractually or otherwise, to complete the rollover. Moreover,
if clients do complete the rollover, clients are under no obligation to have the assets in an IRA
advised on by our firm. Due to the foregoing conflict of interest, when we make rollover
recommendations, we operate under a special rule that requires us to act in our clients’ best
interests and not put our interests ahead of our clients’.
Under this special rule’s provisions, we must:
• meet a professional standard of care when making investment recommendations (give
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prudent advice);
• never put our financial interests ahead of our clients’ when making recommendations
(give loyal advice);
• avoid misleading statements about conflicts of interest, fees, and investments;
•
follow policies and procedures designed to ensure that we give advice that is in our
clients’ best interests;
• charge no more than a reasonable fee for our services; and
• give clients basic information about conflicts of interest.
Many employers permit former employees to keep their retirement assets in their company
plan. Also, current employees can sometimes move assets out of their company plan before
they retire or change jobs. In determining whether to complete the rollover to an IRA, and to
the extent the following options are available, clients should consider the costs and benefits of
a rollover. Note that an employee will typically have four options in this situation:
1. leaving the funds in the employer’s (former employer’s) plan;
2. moving the funds to a new employer’s retirement plan;
3. cashing out and taking a taxable distribution from the plan; or
4. rolling the funds into an IRA rollover account.
Each of these options has positives and negatives. Because of that, along with the importance
of understanding the differences between these types of accounts, we will provide clients with
an explanation of the advantages and disadvantages of both account types and document the
basis for our belief that the rollover transaction we recommend is in your best interests.
General Information on Compensation and Other Fees
In certain circumstances, fees, account minimums and payment terms are negotiable
depending on client’s unique situation – such as the size of the aggregate related party
portfolio size, family holdings, low-cost basis securities, or certain passively advised investments
and pre-existing relationships with clients. Certain clients may pay more or less than others
depending on the amount of assets, type of portfolio, or the time involved, the degree of
responsibility assumed, complexity of the engagement, special skills needed to solve problems,
the application of experience and knowledge of the client’s situation. Clients’ fees may vary
under a legacy fee agreement.
Our fees are exclusive of brokerage commissions, transaction fees, and other related costs and
expenses which shall be incurred by the client. Clients may incur certain charges imposed by
custodians, brokers, third party investment and other third parties such as fees charged by
managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire
transfer and electronic fund fees, and other fees and taxes on brokerage accounts and
securities transactions. Mutual funds and exchange traded funds also charge internal
management fees, which are disclosed in a fund’s prospectus.
Such charges, fees and commissions are exclusive of and in addition to our fees, and we shall
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not receive any portion of these commissions, fees, and costs.
All fees paid to us for investment advisory services are separate and distinct from the fees and
expenses charged by mutual funds to their shareholders. These fees and expenses are
described in each fund’s prospectus. These fees will generally include a management fee, other
expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may
pay an initial or deferred sales charge.
A client could invest in a mutual fund directly, without our services. In that case, the client
would not receive our services, which are designed, among other things, to assist the client in
determining which mutual funds are most appropriate to each client’s financial condition and
objectives. Accordingly, the client should review both the fees charged by the funds and the
fees charged by us to fully understand the total amount of fees to be paid by the client and to
thereby evaluate the advisory services being provided.
Clients should note that similar advisory services may (or may not) be available from other
registered investment advisers for similar or lower fees.
Mutual Fund Share Class Selection
Similar investment management services may (or may not) be available from other investment
advisers for a lower fee. Investment management fees, which include investment management
and transaction costs, may be more or less costly than paying for the services separately,
depending upon the investment advisory fees charged, the number of transactions for the
account, the mutual fund share class you purchase and the underlying 12(b)-1 fee, and the level
of brokerage and other fees that would be payable if you obtained the services available
individually.
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Item 6: Performance-Based Fees and Side-By-Side Management
“Performance-based fees” are fees based on the capital gains or capital appreciation in an
account. We do not charge performance-based fees. “Side-by-side management” refers to the
practice of managing both accounts that are charged a performance-based fee and accounts
that are charged other types of fees, such as asset-based fees and hourly fees. Because we do
not charge performance-based fees, we do not engage in side-by-side management.
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Item 7: Types of Clients
Types of Clients
We provide services to individuals, high net worth individuals, trusts, estates and charitable
organizations.
Account Minimums
We require a minimum account under certain circumstances of $500,000 for investment
advisory clients, although this may be reduced at our sole discretion.
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Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
We use Fundamental Analysis in formulating our investment advice and/or managing client
assets.
Fundamental Analysis attempts to measure the intrinsic value of a security by looking at
economic and financial factors (including the overall economy, industry conditions, and the
financial condition and management of the company itself) to determine if the company is
underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time
to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a
potential risk, as the price of a security can move up or down along with the overall market
regardless of the economic and financial factors considered in evaluating the stock.
Investment Strategies
Strategies may include long-term purchases, short-term purchases, trading, short sales, margin
transactions, and option writing (including covered options, uncovered options or spreading
strategies).
We reserve the right to advise clients on any other type of investment that we deem
appropriate based on the client’s stated goals and objectives. We may also provide advice on
any type of investment held in a client’s portfolio at the inception of the advisory relationship
or on any investment on which the client requests advice.
Risk of Loss
Investing in securities involves risk of loss that clients should be prepared to bear.
All investments involve the risk of loss, including (among other things) loss of principal, a
reduction in earnings (including interest, dividends and other distributions), and the loss of
future earnings. Although we manage assets in a manner consistent with your investment
objectives and risk tolerance, there can be no guarantee that our efforts will be successful.
You should be prepared to bear the following risks of loss:
•
Interest-rate Risk: Fluctuations in interest rates may cause investment prices to
fluctuate. For example, when interest rates rise, yields on existing bonds become less
attractive, causing their market values to decline.
• Market Risk: The price of a security, bond, or mutual fund may drop in reaction to
tangible and intangible events and conditions. This type of risk is caused by external
factors independent of a security’s particular underlying circumstances. For example,
political, economic and social conditions may trigger market events.
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•
Inflation Risk: When any type of inflation is present, a dollar next year will not buy as
much as a dollar today, because purchasing power is eroding at the rate of inflation.
• Currency Risk: Overseas investments are subject to fluctuations in the value of the
dollar against the currency of the investment’s originating country. This is also referred
to as exchange rate risk.
• Reinvestment Risk: This is the risk that future proceeds from investments may have to
be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily
relates to fixed income securities.
• Business Risk: These risks are associated with a particular industry or a particular
company within an industry. For example, oil-drilling companies depend on finding oil
and then refining it, a lengthy process, before they can generate a profit. They carry a
higher risk of profitability than an electric company, which generates its income from a
steady stream of customers who buy electricity no matter what the economic
environment is like.
• Liquidity Risk: Liquidity is the ability to readily convert an investment into cash.
Generally, assets are more liquid if many traders are interested in a standardized
product. For example, Treasury Bills are highly liquid, while real estate properties (i.e.,
Non-traded REITs and other alternative investments) are not.
• Financial Risk: Excessive borrowing to finance a business’ operations increases the risk
of profitability, because the company must meet the terms of its obligations in good
times and bad. During periods of financial stress, the inability to meet loan obligations
may result in bankruptcy and/or a declining market value.
• Cybersecurity Risk: A breach in cyber security refers to both intentional and
unintentional events that may cause an account to lose proprietary information, suffer
data corruption, or lose operational capacity. This in turn could cause an account to
incur regulatory penalties, reputational damage, and additional compliance costs
associated with corrective measures, and/or financial loss.
• Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase
morbidity and mortality over a wide geographic area, crossing international boundaries,
and causing significant economic, social, and political disruption.
• Custodial Risk: This risk is the probability that a party to a transaction will be unable or
unwilling to fulfill its contractual obligations either due to technological errors, control
failures, malfeasance, or potential regulatory liabilities.
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Item 9: Disciplinary Information
We are required to disclose all pertinent facts regarding any legal, regulatory or disciplinary
events that would be material to your evaluation of the Firm or the integrity of our
management.
There have never been any legal, regulatory or disciplinary actions against the Firm or our
management persons.
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Item 10: Other Financial Industry Activities and Affiliations
Financial Industry Activities
We are not registered as a broker-dealer, and none of our management persons are registered
representatives of a broker-dealer. We are not registered and do not have an application
pending as a securities broker-dealer, futures commission merchant, commodity pool operator
or commodity trading advisor.
We do not have arrangements that are material to our business and clients and investors with a
related person who is a broker-dealer, investment company, other investment adviser, financial
planning firm, commodity pool operator, commodity trading adviser, futures commission
merchant, bank or thrift institution, accounting firm, law firm, insurance company or agency,
pension consultant, real estate broker or dealer, or an entity that creates or packages limited
liability companies.
Other Investment Advisors
We do not recommend or select other investment advisors for our clients.
Tax Services
We may assist clients in the preparation of tax returns and depending on the terms of the
agreement with each client, the cost for these services may or may not be included in our fees.
We receive minimal income derived from tax preparation services. This service may also be
outsourced to another accounting and tax preparation firm, where the services will be paid
solely by us. Clients are under no obligation to engage us for tax preparation services.
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Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
Code of Ethics
Our employees must comply with a Code of Ethics and Statement for Insider Trading (the
“Code”). The Code describes our high standard of business conduct, and fiduciary duty to our
clients. The Code’s key provisions include:
• Statement of General Principles
• Policy on and reporting of Personal Securities Transactions
• A prohibition on Insider Trading
• Restrictions on the acceptance of significant gifts
• Procedures to detect and deter misconduct and violations
• Requirement to maintain confidentiality of client information
Our employees must acknowledge the terms of the Code at least annually, and any employee
not in compliance with the Code may be subject to termination. We will provide a copy of our
Code upon request.
Participation or Interest in Client Transactions – Personal Securities Transactions
Both the Firm and our employees may buy or sell securities identical to those recommended to
clients for their personal accounts. The Code, described above, is designed to assure that the
personal securities transactions, activities and interests of the employees of the Firm will not
interfere with (I) making decisions in the best interest of clients and (ii) implementing such
decisions while, at the same time, allowing employees to invest for their own accounts. Under
the Code certain classes of securities, primarily mutual funds, have been designated as exempt
transactions, based upon a determination that these would materially not interfere with the
best interest of our clients. In addition, the Code requires pre-clearance of many transactions.
Nonetheless, because the Code in some circumstances would permit employees to invest in the
same securities as clients, there is a possibility that employees might benefit from market
activity by a client in a security held by an employee. The Firm may maintain a list of restricted
securities that employees may not purchase or sell based upon having (or possibly having)
access to inside information. Employee trading is continually monitored under the Code and
designed to reasonably prevent conflicts of interest between the Firm and our clients.
Participation or Interest in Client Transactions and Principal/Agency Cross Trades
We do not recommend any securities to our clients in which we have a material financial
interest. We do not affect any principal or agency cross securities transactions for client
accounts. We also do not cross trades between client accounts.
Participation or Interest in Client Transactions – Financial Interest and Principal/Agency Cross
Neither we nor our employees recommend to clients, or buy or sell for client accounts,
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securities in which they have a material financial interest.
Participation or Interest in Client Transactions – Aggregation
We and our employees may trade in the same securities with client accounts on an aggregated
basis when consistent with our obligation of best execution. In such circumstances, the
affiliated and client accounts will share commission costs equally and receive securities at a
total average price. We will retain records of the trade order (specifying each participating
account) and its allocation, which will be completed prior to the entry of the aggregated order.
Completed orders will be allocated as specified in the initial trade order. Partially filled orders
will be allocated on a pro rata basis. Any exceptions will be explained on the order.
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Item 12: Brokerage Practices
Research and Other Soft Dollar Benefits
We do not receive formal soft dollar benefits other than execution from broker/dealers in
connection with client securities transactions. See disclosure below in “Brokerage – Other
Economic Benefits”.
Brokerage for Client Referrals
We do not receive client referrals from broker/dealers.
Directed Brokerage
While not routine, the client may direct us to use a particular broker-dealer to execute some or
all transactions for the client. This brokerage direction must be requested by the client in
writing. In that case, the client will negotiate terms and arrangements for the account with that
broker-dealer, and we will not seek better execution services or prices from other broker-
dealers or be able to “batch” client transactions for execution through other broker-dealers
with orders for other accounts managed by us. By directing brokerage, the client may pay
higher commissions or other transaction costs or greater spreads, or receive less favorable net
prices, on transactions for the account than would otherwise be the case. Not all advisers
require or allow their clients to direct brokerage. Subject to our duty of best execution, we may
decline a client’s request to direct brokerage if, in our sole discretion, such directed brokerage
arrangements would result in additional operational difficulties.
If the client requests us to arrange for the execution of securities brokerage transactions for the
client’s account, we shall direct such transactions through broker-dealers that we reasonably
believe will provide best execution. We shall periodically and systematically review our policies
and procedures regarding recommending broker-dealers to our client in light of our duty to
obtain best execution.
Brokerage - Other Economic Benefits
We may have the opportunity to receive traditional “non-cash benefits” from broker/dealers
such as customized statements; receipt of duplicate client confirmations and bundled duplicate
statements; access to a trading desk servicing advisors exclusively; access to block trading
which provides the ability to aggregate securities transactions and then allocate the
appropriate shares to client portfolios; ability to have investment advisory fees deducted
directly from client portfolios; access to an electronic communication network for client order
entry and portfolio information; access to mutual funds which generally require significantly
high minimum initial investments or those that are otherwise only generally available to
institutional investors; reporting features; receipt of industry communications; and perhaps
discounts on business-related products.
Broker/dealers may also provide general access to research and perhaps discounts on research
products. Any research received is used for the benefit of all clients. We have no written or
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verbal arrangements whereby we receive soft dollars. While we endeavor at all times to put the
interest of the clients first as part of our fiduciary duty, clients should be aware that the receipt
of any additional compensation itself creates a conflict of interest and may affect the judgment
of these individuals when making recommendations.
Trade Aggregation
We may aggregate trades for multiple accounts. Trade aggregation is the act of trading a large
block of a security in a single order. Shares of a purchased security are then allocated to the
appropriate accounts in the appropriate proportion. The main purposes of order aggregation
are (i) for ease of trading and (ii) to obtain a lower transaction cost associated with trading a
larger quantity.
Orders for the same security entered on behalf of more than one client may be aggregated (i.e.,
blocked or bunched) subject to the aggregation being in the best interests of all participating
clients. If the order is filled at different prices during the day, the prices are averaged for the
day so that all participating accounts receive the same price. If an order has not been filled
completely so that there are not enough shares to allocate among all the clients equally, shares
will be allocated in good faith, based on the following considerations: amount of cash in the
account, existing asset allocation and industry exposure, risk profile, and type of security. If a
partial execution is attained at the end of the trading day, we will generally allocate shares on a
pro rata basis but may fill small orders entirely before applying the pro rata allocation. All
clients participating in each aggregated order shall receive the average price and subject to
minimum ticket charges, pay a pro-rata portion of commissions.
Our allocation procedure seeks to be fair and equitable to all clients with no particular group or
client(s) being favored or disfavored over any other clients.
Accounts for us or our employees will not be included in a block trade with client accounts.
20
Item 13: Review of Accounts
Reviews
We monitor client portfolios as part of an ongoing process, and regular account reviews are
generally conducted on a quarterly basis. Reviews could also occur at the time of new deposits,
material changes in the client’s financial information, changes in economic cycles, at our
discretion or as often as the client directs. Reviews entail analyzing securities, sensitivity to
overall markets, economic changes, investment results, asset allocation, etc., to ensure the
investment strategy and expectations are structured to continue to meet the client’s objectives.
These reviews are conducted by one of our Investment Advisor Representatives.
Clients are encouraged to discuss their needs, goals, and objectives with us and to inform us of
any changes.
Reporting
At least quarterly, the custodian provides clients with an account statement for each client
account, which may include individual holdings, cost basis information, deposits and
withdrawals, accrued income, dividends, and performance. We may also provide clients with
periodic reports regarding their holdings, allocations, and performance.
21
Item 14: Client Referrals and Other Compensation
Compensation – Client Referrals
We have been fortunate to receive many client referrals over the years. The referrals came
from current clients, estate planning attorneys, accountants, employees, personal friends of
employees, and other similar sources. We do not compensate referring parties for these
referrals.
22
Item 15: Custody
Custody – Fee Debiting
Clients may authorize us (in the client agreement) to debit fees directly from their account at
the broker dealer, bank or other qualified custodian (“custodian”). The custodian is advised in
writing of the limitation of our access to the account. The custodian sends a statement to the
client, at least quarterly, indicating all amounts disbursed from the account including the
amount of advisory fees paid directly to the Firm.
Custody – Account Statements
Clients receive at least quarterly statements from the custodian that holds and maintains
client’s investment assets. Clients are urged to carefully review such statements and compare
such official custodial records to the reports that we provide. Our reports may vary from
custodial statements based on accounting procedures, reporting dates, or valuation
methodologies of certain securities.
23
Item 16: Investment Discretion
We may accept limited power of attorney to act on a discretionary basis on behalf of clients. A
limited power of attorney allows us to execute trades on behalf of clients. When such limited
powers exist between the Firm and the client, we have the authority to determine, without
obtaining specific client consent, both the amount and type of securities to be bought to satisfy
client account objectives.
If we have not been given discretionary authority, we consult with the client prior to each
trade.
24
Item 17: Voting Client Securities
Proxy Voting
We do not have any authority to and do not vote proxies on behalf of clients, nor do we make
any express or implied recommendation with respect to voting proxies. Clients retain the sole
responsibility for receiving and voting proxies that they receive directly from either their
custodian or transfer agents. Clients may contact us for information about proxy voting.
25
Item 18: Financial Information
We have no financial commitments that impair our ability to meet contractual and fiduciary
commitments to clients and we have not been the subject of a bankruptcy proceeding.
We do not require prepayment of fees of both more than $1,200 per client, and more than six
months in advance; and therefore, we not required to provide a balance sheet to clients.
We have not ever filed a bankruptcy petition.
26
Form ADV Part 2B: Investment Advisor Brochure Supplement
Perennial Advisors Group, LLC
Form ADV Part 2B
Investment Advisor Brochure Supplement
270 Littleton Road, Suite 19
Westford, MA 01886
(978) 577-6025
www.perennialadvisorsgroup.com
David A. Carpenter
January 2026
This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact please contact Kelsey L. Brennan, Chief Compliance Officer, Principal and Financial
Advisor at (978) 577-6025 or kelsey@perennialadvisorsgroup.com if you did not receive our
Brochure or if you have any questions about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
27
Item 2: Educational Background and Business Experience
We require that employees that provide investment advice have a bachelor's degree and
further coursework demonstrating knowledge of financial planning and tax planning. Examples
of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA.
Additionally, advisors must have work experience that demonstrates their aptitude for financial
planning and investment management.
Born 1955
David A Carpenter
CRD #: 4719038
Perennial Advisors Group, LLC
Managing Member and Principal
Principal and Chief Compliance Officer
2024 to Present
1998 to 2024
Formal Education after High School:
Bentley University
Master of Science in Taxation & Personal Financial Planning
Ohio University
Bachelor of Science in Accounting and Finance
Item 3: Disciplinary Information
David A. Carpenter has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Disclosure on Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other
Financial Industry Activities and Affiliations above.
David A. Carpenter does not have any outside business activities.
Item 5: Additional Compensation
David A. Carpenter does not receive any economic benefit outside of regular salaries or
bonuses.
28
Item 6: Supervision
Kelsey L. Brennan, Chief Compliance Officer, Principal and Financial Advisor, supervises the
person named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Kelsey L.
Brennan supervises this person by holding regular staff, investment, and other ad hoc meetings.
In addition, Kelsey L. Brennan regularly reviews client reports, emails, and trading, as well as
employees’ personal securities transaction and holdings reports. Kelsey L. Brennan may be
reached at (978) 577-6025.
29
Form ADV Part 2B: Investment Advisor Brochure Supplement
Perennial Advisors Group, LLC
Form ADV Part 2B
Investment Advisor Brochure Supplement
270 Littleton Road, Suite 19
Westford, MA 01886
(978) 577-6025
www.perennialadvisorsgroup.com
Kelsey L. Brennan
January 2026
This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact please contact Kelsey L. Brennan, Chief Compliance Officer, Principal and Financial Advisor
at (978) 577-6025 or kelsey@perennialadvisorsgroup.com if you did not receive our Brochure
or if you have any questions about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
30
Item 2: Educational Background and Business Experience
We require that employees that provide investment advice have a bachelor's degree and
further coursework demonstrating knowledge of financial planning and tax planning. Examples
of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA.
Additionally, advisors must have work experience that demonstrates their aptitude for financial
planning and investment management.
Born 1992
Kelsey L. Brennan
CRD #: 6266957
Perennial Advisors Group, LLC
Chief Compliance Officer, Principal and Financial Advisor
Financial Advisor
Financial Planning Analyst
2024 to Present
2019 to 2024
2015 to 2019
Formal Education after High School:
Bentley University
Bachelor of Science in Managerial Economics
Professional Designations:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Enrolled Agent (EA)
Professional Certifications
Kelsey L. Brennan maintains professional designations, which requires the following minimum
requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC®
Chartered Life Underwriter® (CLU®)
CFA®
Ph.D. in business or economics
Doctor of Business Administration
Attorney's License
•
•
•
•
•
•
•
31
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Enrolled Agent (EA)
Issued By
Internal Revenue Service
Candidate must meet the following requirements:
Prerequisites
• Obtain a Preparer Tax Identification Number (PTIN)
• Achieve passing scores on all three parts of the Special
Enrollment Examination (SEE) within three years
• Apply for enrollment and pay enrollment fee
• Pass a suitability check
None
Education
Requirements
Exam Type
Three-part comprehensive IRS test or experience as a former IRS
employee
• Completion of 72 hours of continuing professional
education courses every three years
• Obtain a minimum of 16 hours per year (2 of which must be
Continuing Education
Requirements
on ethics)
• Use an IRS approved continuing education provider
Item 3: Disciplinary Information
Kelsey L. Brennan has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Disclosure on Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other
Financial Industry Activities and Affiliations above.
Kelsey L. Brennan does not have any outside business activities.
Item 5: Additional Compensation
Kelsey L. Brennan does not receive any economic benefit outside of regular salaries or bonuses.
Item 6: Supervision
Kelsey L. Brennan, Chief Compliance Officer, Principal and Financial Advisor, supervises the
people named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Kelsey L.
32
Brennan supervises these people by holding regular staff, investment, and other ad hoc
meetings. In addition, Kelsey L. Brennan regularly reviews client reports, emails, and trading, as
well as employees’ personal securities transaction and holdings reports. Kelsey L. Brennan may
be reached at (978) 577-6025.
33
Form ADV Part 2B: Investment Advisor Brochure Supplement
Perennial Advisors Group, LLC
Form ADV Part 2B
Investment Advisor Brochure Supplement
270 Littleton Road, Suite 19
Westford, MA 01886
(978) 577-6025
www.perennialadvisorsgroup.com
Tyler B. Dostie
January 2026
This Brochure Supplement provides information about the Firm’s (“we”, “us”, “our”) employees
that supplements our Brochure. You should have received a copy of that Brochure. Please
contact please contact Kelsey L. Brennan, Chief Compliance Officer, Principal and Financial Advisor
at (978) 577-6025 or kelsey@perennialadvisorsgroup.com if you did not receive our Brochure
or if you have any questions about the contents of this Supplement.
Additional information about our employee(s) referenced above is also available on the SEC’s
website at www.adviserinfo.sec.gov. You may search this site using a unique identifying
number, known as a CRD number for each employee.
34
Item 2: Educational Background and Business Experience
We require that employees that provide investment advice have a bachelor's degree and
further coursework demonstrating knowledge of financial planning and tax planning. Examples
of acceptable coursework include: an MBA, a CFP®, a CFA®, a ChFC®, JD, CTFA, EA or CPA.
Additionally, advisors must have work experience that demonstrates their aptitude for financial
planning and investment management.
Born 2000
Tyler B. Dostie
CRD #: 7596311
Perennial Advisors Group, LLC
Principal and Financial Advisor
Paraplanner
2024 to Present
2022 to 2024
2021 to 2022
McCurdy Investments LLC
Financial Planning Analyst
Formal Education after High School:
Nichols College
Bachelor of Science in Business Administration
Professional Designations:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Professional Certifications
Tyler B. Dostie maintains a professional designation, which requires the following minimum
requirements:
CERTIFIED FINANCIAL PLANNER™ (CFP®)
Issued By
Certified Financial Planner Board of Standards, Inc.
Candidate must meet the following requirements:
• A bachelor’s degree (or higher) from an accredited college or
Prerequisites
university, and
• 3 years of full-time personal financial planning experience
Candidate must complete a CFP®-board registered program, or hold
one of the following:
Education
Requirements
CPA
ChFC®
Chartered Life Underwriter® (CLU®)
CFA®
Ph.D. in business or economics
Doctor of Business Administration
•
•
•
•
•
•
35
Attorney's License
•
CFP® Certification Examination
30 hours every 2 years
Exam Type
Continuing Education
Requirements
Item 3: Disciplinary Information
Tyler B. Dostie has not been involved in any activities resulting in a disciplinary disclosure.
Item 4: Other Business Activities
Disclosure on Outside Business Activities is provided in Form ADV Part 2A Item 10 – Other
Financial Industry Activities and Affiliations above.
Tyler B. Dostie does not have any outside business activities.
Item 5: Additional Compensation
Tyler B. Dostie does not receive any economic benefit outside of regular salaries or bonuses.
Item 6: Supervision
Kelsey L. Brennan, Chief Compliance Officer, Principal and Financial Advisor, supervises the
person named in this Form ADV Part 2B Investment Advisor Brochure Supplement. Ms. Brennan
supervises this person by holding regular staff, investment, and other ad hoc meetings. In
addition, Ms. Brennan regularly reviews client reports, emails, and trading, as well as
employees’ personal securities transaction and holdings reports. Ms. Brennan may be reached
at (978) 577-6025.
36