Overview

Assets Under Management: $690 million
Headquarters: AMHERST, MA
High-Net-Worth Clients: 171
Average Client Assets: $3.5 million

Frequently Asked Questions

WEST BRANCH CAPITAL LLC charges 1.50% on the first $0 million, 1.10% on the next $1 million, 0.75% on the next $3 million, 0.65% on the next $5 million according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #133813), WEST BRANCH CAPITAL LLC is subject to fiduciary duty under federal law.

WEST BRANCH CAPITAL LLC is headquartered in AMHERST, MA.

WEST BRANCH CAPITAL LLC serves 171 high-net-worth clients according to their SEC filing dated February 13, 2026. View client details ↓

According to their SEC Form ADV, WEST BRANCH CAPITAL LLC offers financial planning and portfolio management for individuals. View all service details ↓

WEST BRANCH CAPITAL LLC manages $690 million in client assets according to their SEC filing dated February 13, 2026.

According to their SEC Form ADV, WEST BRANCH CAPITAL LLC serves high-net-worth individuals. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (WEST BRANCH BROCHURE (FORM ADV2A))

MinMaxMarginal Fee Rate
$0 $500,000 1.50%
$500,001 $1,000,000 1.10%
$1,000,001 $3,000,000 0.75%
$3,000,001 $5,000,000 0.65%
$5,000,001 $10,000,000 0.50%
$10,000,001 $15,000,000 0.40%
$15,000,001 $20,000,000 0.30%
$20,000,001 and above 0.25%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $13,000 1.30%
$5 million $41,000 0.82%
$10 million $66,000 0.66%
$50 million $176,000 0.35%
$100 million $301,000 0.30%

Clients

Number of High-Net-Worth Clients: 171
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 86.01%
Average Client Assets: $3.5 million
Total Client Accounts: 1,255
Discretionary Accounts: 1,252
Non-Discretionary Accounts: 3
Minimum Account Size: $1,000,000
Note on Minimum Client Size: $1,000,000

Regulatory Filings

CRD Number: 133813
Filing ID: 2047608
Last Filing Date: 2026-02-13 11:10:34

Form ADV Documents

Primary Brochure: WEST BRANCH BROCHURE (FORM ADV2A) (2026-02-13)

View Document Text
West Branch Capital LLC Form ADV Part 2A Disclosure Brochure Effective: February 2026 This Disclosure Brochure provides information about the qualifications and business practices of West Branch Capital LLC (“West Branch Capital”). If you have any questions about the contents of this Disclosure Brochure, please contact us at (413) 256-1225 or in writing at 9 Research Drive, Suite 1 Amherst, MA 01002. West Branch Capital is a Registered Investment Adviser with the U.S. Securities and Exchange Commission (SEC). The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration of an investment Adviser does not imply any specific level of skill or training. This Disclosure Brochure provides information about West Branch Capital to assist you in determining whether to retain the Adviser. Additional information about West Branch Capital and its Advisory persons are available on the SEC’s website at www.Adviserinfo.sec.gov. West Branch Capital LLC CRD No: 133813 * SEC File No: 801-78332 www.westbranchcapital.com West Branch Capital LLC 100 Independence Drive, Suite 7-123 Hyannis, MA 02601 Phone: 833-888-0534 508-255-9800 Main Office Location 9 Research Drive, Suite 1 Amherst, MA 01002 Phone: 833-888-0534 413 256-1225 Fax: 413-253-5838 West Branch Capital LLC West Branch Capital LLC 300 International Drive, S 99 Derby Street, Suite 200 Williamsville, NY 14221 Hingham, MA 02043 Phone: 833-888-0534 Phone: 833-888-0534 716-636-0169 781-556-1035 1 Item 2 – Material Changes Form ADV 2 is divided into two parts: Part 2A and Part 2B. Part 2A (the “Disclosure Brochure”) provides information about a variety of topics relating to an Adviser’s business practices and conflicts of interest. Part 2B (the “Brochure Supplement”) provides information about Advisory personnel of West Branch Capital. West Branch Capital believes that communication and transparency are the foundation of our relationship and the firm continually strives to provide our Clients with the complete and accurate information at all times. We encourage all current and prospective Clients to read this Disclosure Brochure and discuss any questions you may have with us. And of course, we always welcome your feedback. Material Changes Since the last annual amendment to this brochure was prepared in February 2025, no material changes have been made. Future Changes From time to time, we may amend this Disclosure Brochure to reflect changes in our business practices, changes in regulations and routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to each Client annually if a material change occurs in the business practices of West Branch Capital. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure website at http://Adviserinfo.sec.gov. To review the firm information for West Branch Capital: • Click Investment Adviser Search in the left navigation menu. • Select the option for Investment Adviser Firm and enter 133813 (our firm’s CRD number) in the field labeled “Firm IARD/CRD Number”. • This will provide access to Form ADV (Part 1), ADV Part 2, and ADV Part 3. • Item 11 of the ADV (Part 1) lists legal and disciplinary questions regarding the Adviser. You may also request a copy of this Disclosure Brochure by contacting us at (413) 256-1225 or by writing to us at 9 Research Drive, Suite 1 Amherst, MA 01002. 2 Item 3 – Table of Contents Item 1 – Cover Page ................................................................................................................................................... 1 Item 2 – Material Changes ........................................................................................................................................ 2 Item 3 – Table of Contents ....................................................................................................................................... 3 Item 4 – Advisory Services ....................................................................................................................................... 4 A. Firm Information .................................................................................................................................... 4 B. Advisory Services Offered ..................................................................................................................... 4 C. Client Account Management ................................................................................................................ 5 D. Wrap Fee Programs ................................................................................................................................ 5 E. Assets Under Management.................................................................................................................... 5 Item 5 – Fees and Compensation ............................................................................................................................ 5 A. Fees for Advisory Services ................................................................................................................. 5 B. Fee Billing ................................................................................................................................................. 6 C. Other Fees and Expenses ....................................................................................................................... 7 D. Termination ............................................................................................................................................ 7 E. Compensation for Sales and Purchases of Securities ......................................................................... 8 Item 6 – Performance-Based Fees ............................................................................................................................ 8 Item 7 – Types of Clients .......................................................................................................................................... 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss .......................................................... 9 A. Methods of Analysis .............................................................................................................................. 9 B. Risk of Loss .............................................................................................................................................. 9 Item 9 – Disciplinary Information ........................................................................................................................ 10 Item 10 – Other Financial Activities and Affiliations ....................................................................................... 11 Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading ............................... 11 A. Code of Ethics ....................................................................................................................................... 11 B. Personal Trading and Conflicts of Interest ........................................................................................ 11 Item 12 – Brokerage Practices ................................................................................................................................ 11 A. Recommendation of Custodian[s] ...................................................................................................... 11 B. Aggregating and Allocating Trades ................................................................................................... 14 Item 13 – Review of Accounts................................................................................................................................ 15 A. Frequency of Reviews .......................................................................................................................... 15 B. Causes for Reviews ............................................................................................................................... 15 C. Reports Review ...................................................................................................................................... 15 Item 14 - Client Referrals and Other Compensation ......................................................................................... 15 A. Compensation Received by West Branch Capital ............................................................................ 15 B. Client Referrals from Solicitors ........................................................................................................... 16 Item 15 – Custody .................................................................................................................................................... 16 Item 16 – Investment Discretion ........................................................................................................................... 16 Item 17 – Voting Client Securities ........................................................................................................................ 17 Item 18 – Financial Information ............................................................................................................................ 17 3 Item 4 – Advisory Services A. Firm Information West Branch Capital LLC (“West Branch Capital” or the “Adviser”) is a Registered Investment Adviser with the Securities and Exchange Commission (SEC), which is organized as a Limited Liability Company (“LLC”) under the laws of Massachusetts. West Branch Capital was founded in 2004 by Ayaz Mahmud, CEO and sole owner. This Disclosure Brochure provides information regarding the qualifications, business practices, and the Advisory services provided by West Branch Capital. B. Advisory Services Offered West Branch Capital offers investment Advisory services to individuals, high net worth individuals, trusts, estates, corporations and other businesses (each referred to as a “Client”). Portfolio Management West Branch Capital provides investment Advisory solutions through continuous personal Client contact and interaction while providing discretionary Investment Advisory services. West Branch Capital works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. West Branch Capital will construct a portfolio consisting of individual equity and fixed income securities, mutual funds, Exchange Traded Funds, United States government securities, options and other investments to achieve the Client’s investment goals. West Branch Capital’s investment strategy is primarily long-term focused, but the Adviser may buy, sell, or re-allocate positions frequently. Some positions may be held for less than 30 days. The Adviser will construct, implement, and monitor the portfolio to assist the clients in meeting their goals, objectives, circumstances, and risk tolerance agreed to by the Client. The Adviser may recommend specific positions to increase sector or asset class weightings of both US and non-US securities or exposure to hard assets such as commodities. The Adviser may recommend employing cash positions as a possible hedge against adverse market movements. Further, West Branch Capital may use leverage and other hedging strategies, if appropriate for certain Clients. Prior to rendering investment Advisory services, the Adviser will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objective[s]. West Branch Capital will provide investment Advisory services and portfolio management services but will not provide custodial services for securities, cash or other assets. At no time will West Branch Capital accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client Investment Advisory Agreement. Financial Planning West Branch Capital will provide financial planning services to individuals and families who are existing or new portfolio management clients. Services are offered in several areas of a Clients financial situation, depending on the Client’s goals and objectives. Generally, such financial planning services will involve preparing a financial plan based on the Client’s objectives. This planning or consulting can encompass one or more areas of need, such as investment management, retirement planning, personal savings, 4 education savings, charitable giving, estate planning, insurance needs and other areas personal and financial relevance. C. Client Account Management Prior to engaging West Branch Capital to provide Investment Advisory services, each Client is required to enter into an Investment Advisory Agreement with the Adviser that defines the terms, conditions, authority, and responsibilities of the Adviser and the Client. These services may include: Establishing an Investment Objective: West Branch Capital, in conjunction with the Client, will assist the Client in determining investment goals and objectives along with the broad strategy or strategies to be employed to meet those objectives. Asset Allocation: West Branch Capital may 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: West Branch Capital will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. Investment Advisory and Supervision: West Branch Capital will provide Investment Advisory and ongoing oversight of the Client’s portfolio and overall account. D. Wrap Fee Programs West Branch Capital does not manage or place Client assets into wrap fee programs. E. Assets Under Management As of December 31, 2025, the most recent date for which such calculations are provided pursuant to securities regulations, West Branch Capital managed the following assets: Assets Under Management Discretionary Assets Non-Discretionary Assets Total Assets $679,518,411 $10,572,199 $690,090,610 Clients can request more current information at any time by contacting the Adviser. Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for our Investment Advisory services. Each Client shall sign an Investment Advisory Agreement that details the responsibilities of West Branch Capital and the Client. A. Fees for Advisory Services Portfolio Management For services provided by West Branch Capital, Investment Advisory Fees are paid quarterly in arrears or in advance pursuant to the terms of the Investment Advisory Agreement we have in writing with each client. 5 For services provided by West Branch Capital, the fees fall within the range of the schedules below. Fees are based on the value of the account on the last business day of the preceding quarter. The following is our standard fee schedule. Because our fees are negotiable, fee rates can vary from client to client. Annual Rate Assets Under Management 1.50% 1.10% .75% .65% .50% .40% .30% .25% First $500,000 Next $500,000 Next $1,000,000-$3,000,000 Next $3,000,000-$5,000,000 Next $5,000,000-$10,000,000 Next $10,000,000-$15,000,000 Next $15,000,000-$20,000,000 Above $20,000,000 This is a blended fee schedule. This means that the assets in a client’s account will be billed at different levels according to the fee schedule above. For example, if a client had an account value of $9,000,000 then the first $500,000 is billed at 1.50%, the next $500,000 is billed at 1.10%, the portion from $1,000,000 to $3,000,000 is billed at .75%, the portion from $3,000,000 to $5,000,000 is billed at .65% and the final portion from $5,000,000 to $9,000,000 is billed at 0.50% for an effective blended (or average) fee rate of 0.68%. Fees are prorated when deposits and withdrawals are made. Investment Advisory Fees in the first quarter of service are prorated from the inception date of the account to the end of the first quarter. Financial Planning Services West Branch Capital‘s financial planning services are provided in connection with or as part of our Portfolio Management services. For clients receiving Portfolio Management services, all financial planning services are covered by the Porfolio Management fees described above. We do not charge a separate or stand-alone hourly or fixed fee to our Portfolio Management clients for financial planning services. B. Fee Billing Portfolio Management Investment Advisory Fees can be paid by check or automatically deducted from the Client Account by the Custodian. The Adviser shall send a billing statement to the Custodian indicating the amount of the fees deducted from the Client Account for the respective quarter-end date. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the total assets under management with West Branch Capital at the end of the prior quarter. Clients will be provided with a monthly statement from the Custodian reflecting amount of deduction of the Investment Advisory Fee when deducted at the beginning of each quarter. In addition, the Adviser will provide the Client a quarterly billing statement itemizing the fee, including the calculation period covered by the fee, the account value, and the methodology used to calculate the fee. It is the responsibility of the Client to verify the accuracy of these fees deducted from their accounts and as listed on the Custodian’s brokerage statement, as the Custodian does not assume this responsibility. The Client should notify the Adviser immediately if there is any discrepancy in the 6 billing statement. Clients will provide written authorization permitting West Branch Capital to be paid directly from their accounts held by the Custodian as part of the Investment Advisory Agreement. C. Other Fees and Expenses Clients can incur certain commissions or charges imposed by third parties, other than West Branch Capital, in connection with investments made on behalf of the Client’s account(s). The Client is responsible for all custodial and security commissions and other fees, if any, charged by the custodian or executing broker/dealer. The Investment Advisory Fee charged by West Branch Capital is separate and distinct from these custodial and execution fees. In addition, all fees paid to West Branch Capital for Investment Advisory services are separate and distinct from the expenses charged by mutual funds and exchange-traded funds 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 could invest in these products directly, without the services of West Branch Capital, but would not receive the services provided by West Branch Capital which are designed, among other things, to assist the Client in determining which products or services are most appropriate to each Client’s financial condition and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by West Branch Capital to fully understand the total fees to be paid. At West Branch Capital’s discretion, for certain clients, West Branch Capital will assume the responsibility of the payment of legal fees charged by an unaffiliated third-party law firm that provides estate planning services to the client. In this situation, the client is not required to reimburse West Branch Capital for legal- fee payments. These clients will execute a legal engagement with the unaffiliated, third-party law firm but the law firm will send its invoice for estate-planning services to West Branch Capital for payment. West Branch Capital’s payment of such legal fees will not result in an increase of investment advisory fees charged to the client by West Branch Capital. West Branch Capital is not a law firm and does not provide legal services. West Branch Capital is not compensated for referring clients to a law firm nor does it pay referral fees to any law firm that refers clients to West Branch Capital. The decision to work with a law firm is important and should not be based solely on West Branch Capital’s recommendation. Moreover, the clients are never obligated nor required to use a law firm recommended by West Branch Capital. D. Termination Portfolio Management Clients may terminate their Investment Advisory Agreement with West Branch Capital, by providing advance written notice. The Client shall be responsible for Investment Advisory Fees up to and including the effective date of termination. Upon termination, the Adviser will refund any unearned, prepaid Investment Advisory Fees from the effective date of termination to the end of the quarter or if the Client is paying Advisory Fees in arrears, the Client shall be responsible for fees not yet paid to the date of termination. The Client’s Investment Advisory Agreement with the Adviser is not assignable without Client’s written approval. 7 E. Compensation for Sales and Purchases of Securities West Branch Capital does not receive any compensation for securities transactions in any Client account, other than the Investment Advisory Fees as noted above, nor does West Branch Capital receive any portion of commissions, distribution fees, sales fees or management fees from Mutual Fund companies or other investment vehicles. Item 6 – Performance-Based Fees West Branch Capital charges a Performance Fee to three current clients meeting the definition of “Qualified Client”. As a matter of firm policy, West Branch Capital no longer offers performance-fee arrangements to new and existing clients not already under a performance based fee agreement. Our current performance-fee arrangements are legacy arrangements. For the legacy clients under a performance-fee arrangement, West Branch Capital’s compensation is a percentage of the amount of the applicable year’s realized or unrealized capital gains or capital appreciation if any, as of the last business day of the calendar year. Qualified Client The Investment Advisers Act of 1940 (the “Advisers Act”), Rule 205-3(d)(1) defines a “Qualified Client” who is financially sophisticated and meets one or more of the following conditions: i. ii. Client is a natural person who or a company that immediately after entering into the contract has at least $1,100,000 under the management of the Adviser; Client is a natural person who or a company that has a net worth (together, in the case of a natural person, with assets held jointly with a spouse and excluding any primary residence) of more than $2,200,000 at the time the contract is entered into. Item 7 – Types of Clients West Branch Capital provides Investment Advisory services to individuals, high net worth individuals, trusts, estates, corporations and other businesses. The relative percentage of each type of Client is available on West Branch Capital’s Form ADV Part 1. These percentages will change over time. West Branch Capital generally requires a minimum account size of $1,000,000 to implement its Investment Advisory process. The minimum account value may be waived at the discretion of the Adviser. 8 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis West Branch Capital primarily employs fundamental and technical analysis in developing investment strategies for its Clients. West Branch Capital’s research and analysis 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. West Branch Capital generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. West Branch Capital will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio, potential and actual adverse conditions impacting the holding, or meeting the cash needs of Clients. At times, West Branch Capital may also buy and sell positions that are short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class, or if dictated by market conditions. 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. West Branch Capital 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. 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 portfolio and other investments. The Adviser shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy of the information provided. It is the responsibility of the Client to inform the Adviser of any changes in financial condition, goals or other factors that may affect this analysis. West Branch Capital may employ investment strategies that at times may involve significant or unusual risk including domestic and international market risks. The Adviser will work with each Client to determine their tolerance for risk as part of the portfolio construction process. West Branch Capital may use margin in Client accounts to manage the timing of purchases and sales, as appropriate. The use of margin will require specific authorization given by the Client and execution of appropriate documentation required by the Custodian. West Branch Capital may employ options strategies to hedge or gain additional exposure to a particular asset class or sector or use covered call writing with the goal to enhance income stream from a portfolio. West Branch Capital’s investment strategy encompasses active trading in concentrated portfolios. Following are some of the risks associated with Options, Margin and Short-Sale transactions: 9 Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can exacerbate gains or losses. Margin The use of margin may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which the Client must either deposit additional funds with the broker or be subject to the mandatory liquidation of the pledged securities to compensate for the decline in value, such liquidation/sales could be at a great loss. Frequent Trading Frequent trading in securities can result in higher transaction costs in the Client’s account[s]. For taxable accounts, frequent trading can also result in taxable transactions each year that would not be present in a buy-and-hold strategy. There are no guarantees that a frequent trading strategy will be profitable. 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 Adviser. For more information on our Investment Advisory services, please contact us at 413-256-1225/toll Free Number 833-888-0534 or via email at info@westbranchcapital.com. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving West Branch Capital or any of its employees. West Branch Capital and its Advisory personnel value the trust you place in us. As we advise all Clients, we encourage you to perform the requisite due diligence on any Adviser or service provider with whom you partner. Our backgrounds are on the Investment Adviser Public Disclosure website at www.Adviserinfo.sec.gov. To review the firm information contained in ADV Part 1, select the option for Investment Adviser Firm and enter 133813 in the field labeled “Firm IARD/CRD Number”. This will provide access to Form ADV Parts 1 and 2. Item 11 of the ADV Part 1 lists legal and disciplinary questions. You may also research the background of Ayaz Mahmud by selecting the Investment Adviser Representative and entering Mr. Mahmud’s Individual CRD# 1094095 in the field labeled “Individual CRD Number”. In addition, you may also obtain information relating to the disciplinary history of any investment Adviser representative conducting business in Massachusetts by contacting the Commonwealth of Massachusetts Securities Division at (617) 727-3548, www.sec.state.ma.us/divisions/securities/securities.htm. 10 Item 10 – Other Financial Activities and Affiliations The firm and its Advisory personnel are dedicated to the Investment Advisory activities of West Branch Capital’s Clients and do not have any other business activities. Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading A. Code of Ethics West Branch Capital has implemented a Code of Ethics that defines our fiduciary commitment to each Client. This Code of Ethics applies to all persons associated with West Branch Capital. The Code of Ethics was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. West Branch Capital and its personnel owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of West Branch Capital personnel to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code of Ethics covers a range of topics including general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings and private placements, reporting ethical violations, distribution of the Code of Ethics, review and enforcement processes, amendments to Form ADV and supervisory procedures. West Branch Capital has a written Code of Ethics. To request a copy of our Code of Ethics, please contact us at 413-256-1225/Toll Free 833-833-888- 0534 or request a copy by mail at 9 Research Drive, Suite 1 Amherst, MA 01002 or 100 Independence Drive, Suite 7-123 Hyannis, MA 02601. B. Personal Trading and Conflicts of Interest West Branch Capital allows its employees to purchase or sell the same securities that are also recommended to and purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, we must mitigate through policies and procedures. As noted above, we have adopted, consistent with Section 204A of the Investment Advisers Act of 1940, a Code of Ethics, which addresses insider trading (material non-public information controls) and personal securities reporting procedures. We have also adopted written policies and procedures to detect the misuse of material, non-public information. We can have an interest or position in certain securities, which are recommended to Clients. At no time, will West Branch Capital or any associated person of West Branch Capital, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian[s] West Branch Capital typically does not have discretionary authority to select the broker-dealer/Custodian for custodial services or the administrator for defined contribution accounts. The Clients will select the broker-dealer or Custodian (herein the "Custodian") to maintain custody of their assets and authorize West Branch Capital to direct trades to this Custodian as agreed in the Investment Advisory Agreement. Further, West Branch Capital does not have the discretionary authority to negotiate commissions on 11 behalf of our Clients on a trade-by-trade basis. At times, Clients may authorize West Branch Capital to trade away from the designated Custodian for trade execution. In such instances, the Client will authorize West Branch Capital through the designated Custodian’s required forms. West Branch Capital will have brokerage discretion in this limited circumstance. Where West Branch Capital does not exercise discretion over the selection of the Custodian, it may recommend the Custodian[s] to Clients for execution and/or custodial services. Clients are not obligated to use the recommended Custodian and will not incur any extra fee associated with using a broker not recommended by West Branch Capital. West Branch Capital typically recommends to Clients that they establish their brokerage account[s] at Charles Schwab & Co., (“Schwab”) or Fidelity Institutional Wealth Services (“Recommended Custodians”). The Recommended Custodians are independent and unaffiliated SEC-registered broker- dealers and FINRA members. The Recommended Custodians offer independent investment Advisers through their institutional platform, services such as custody of Client securities, trade execution, clearance and settlement of transactions. West Branch Capital receives some benefits from the Recommended Custodians through its utilization of the platform. West Branch Capital considers a number of factors in selecting and/or recommending brokers and Custodians for its Clients’ accounts, including, but not limited to, execution capability, experience and financial stability, reputation and the quality of services provided. However, there may be other custodians and/or broker/dealers that provide similar services at lower costs and may be able to provide better execution. West Branch Capital is not affiliated with, or related to, any Recommended Custodians. In selecting the Custodian, West Branch Capital will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. Transaction costs are determined by the Custodian/broker-dealer. Charles Schwab Adviser Services: The decision to use Charles Schwab is largely based on the firm’s participation in Schwab Adviser Services and not solely based on our Clients’ interest in receiving most favorable execution. However, we certainly consider the overall execution services of Charles Schwab when recommending them over other brokerage platforms. Through the Schwab Adviser Services platform, West Branch Capital is provided with access to Charles Schwab’s institutional trading and custody services, which are typically not available to Charles Schwab retail investors. By receiving benefits and services from Charles Schwab, we do not have to produce or pay for them directly. These services generally are available to independent investment Advisers and is not otherwise contingent upon West Branch Capital committing to Charles Schwab any specific amount of business (assets in custody or trading). Charles Schwab's services include brokerage, custody, research and access to mutual funds and possibly other investment vehicles that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For West Branch Capital’s Clients’ accounts maintained in its custody, Charles Schwab does not charge separately for custody but is compensated by account holders through commissions, management fees of money market funds, administrative costs or other transaction-related fees for securities trades that are executed through Charles Schwab or that settle into Charles Schwab accounts. The commission and/or transaction fees charged by Charles Schwab may be higher than those charged by other broker/dealers. 12 Charles Schwab also makes available to West Branch Capital other products and services that benefit West Branch Capital but may not benefit each Clients' account directly. Some of these other products and services assist West Branch Capital in managing and administering Clients’ accounts as a whole. These include software and other technology that provide access to Client account data (such as trade confirmation and account statements); facilitate trade execution (and allocation of aggregated trade orders for multiple Client accounts); provide research, pricing information and other market data; facilitate payment of Advisory fees from its Clients’ accounts; and assist with back-office functions; recordkeeping and Client reporting. Many of these services generally may be used to service all or a substantial number of West Branch Capital accounts. Schwab Adviser Services also makes available to West Branch Capital other services intended to help West Branch Capital manage and further develop its business enterprise. These services can include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance and marketing. In addition, Charles Schwab can make available, arrange and/or pay for these types of services rendered to West Branch Capital by an independent third party providing these services to West Branch Capital. While as a fiduciary, West Branch Capital endeavors to act in its Clients’ best interests, the recommendation that Clients maintain their assets in accounts at Charles Schwab can be based in part on the benefit to West Branch Capital, given the products and services provided as part of the custody of Client assets. Nevertheless, these products and services facilitate the Firm’s workload and helps West Branch Capital to service its Clients. Fidelity Institutional Wealth Services: As with the case with Charles Schwab, the decision to use Fidelity is largely based on the firm’s participation in Fidelity Institutional Wealth Services and not solely based on our Clients’ interest in receiving most favorable execution. However, we consider the overall execution services of Fidelity when recommending them over other brokerage platforms. Fidelity provides West Branch Capital with Fidelity's platform services through its affiliated companies National Financial Services LLC, and Fidelity Brokerage Services LLC. The platform services are similar in many ways to those provided by Schwab as described above include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support firms like West Branch Capital in conducting their business and in serving the best interests of their Clients but that may also benefit West Branch Capital. Fidelity charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). Fidelity, like Schwab, enables West Branch Capital to obtain investment vehicles and security transactions at a low transaction cost. Fidelity’s commission rates are similar to Schwab’s, are generally considered discounted from customary retail commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As a result of receiving services from Fidelity, West Branch Capital has an incentive to continue to use or expand the use of Fidelity or Schwab’s services. West Branch Capital examined this conflict of interest when it chose to enter into the relationship with Fidelity and Schwab and determined that the relationship is in the best interests of West Branch Capital's Clients and satisfies its Client obligations, including its duty to seek best execution. Possibly, a Client may pay a commission that is higher than another qualified broker-dealer might charge to affect the same transaction, West Branch Capital has determined in good faith that Fidelity and Schwab commission rates are reasonable in relation to the 13 value of the brokerage, custodial, research and other services provided to West Branch Capital to facilitate the management of its Clients’ assets. Best Execution In seeking best execution, the determining factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a custodian/broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although West Branch Capital will seek competitive rates, to the benefit of all Clients, it may not necessarily obtain the lowest possible commission rates for specific Client account transactions. Although the investment research products and services that may be obtained by West Branch Capital will generally be used to service all of West Branch Capital’s clients, a brokerage commission paid by a specific Client may be used to pay for research that is not used in managing that specific Client’s account. West Branch Capital is not affiliated with Schwab, Fidelity or any other broker-dealer. Following are additional details regarding the brokerage practices of the Adviser: Soft Dollars: Soft dollars are revenue programs offered by broker-dealers whereby an Adviser enters into an agreement to place security trades with the broker in exchange for research and other services. West Branch Capital does not participate in formal soft dollar programs sponsored or offered by any broker- dealer beyond its participation in the normal and customary Schwab and Fidelity platforms described above. Brokerage Referrals: West Branch Capital does not receive any compensation from any third party in connection with the recommendation for establishing a brokerage account. Directed Brokerage: all Clients are serviced on a “directed brokerage basis”, where West Branch Capital will place trades within the established account[s] at the Custodian designated by the Client, unless trade-away authorization is provided (See Item 12.A. above). The Adviser will not engage in any principal transactions (i.e., trading a security from or to the Adviser’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client’s account from another Client’s account[s]). B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality 5) responsiveness of the broker and 6) skill required of the broker. West Branch Capital will execute its transactions through an unaffiliated broker-dealer selected by the Client or, if authorized, as prime broker trades, based on Adviser’s judgment. West Branch Capital may aggregate orders in a block trade or trades when securities are purchased or sold through the same broker-dealer for multiple (discretionary) accounts. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that does not consistently advantage or disadvantage a particular Client. 14 Item 13 – Review of Accounts A. Frequency of Reviews Accounts are monitored on a regular and continuous basis by the Client’s portfolio manager. Formal reviews are generally conducted based on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A. each Client account is generally reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts are typically 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. The Client should notify West Branch Capital if any changes occur in his/her personal financial situation that might adversely affect his/her investment plan as this may call for a change in the investment strategy being employed by West Branch Capital on behalf of the Client. Additional reviews can be triggered by material market, economic or political events. C. Reports Review The Client will receive brokerage statements, at least quarterly, from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. Clients may also establish electronic access to the Custodian’s website so that the Clients may view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The Adviser provides Clients with periodic reports regarding their holdings, allocations, and performance, including the billing statement. Clients’ portfolio reports, including invoices for fees, this disclosure document, and other important documents are available to view via West Branch Capital’s website (https://www.westbranchcapital.com). These reports are an important tool for Clients to monitor their accounts and investments. West Branch Capital strongly recommends that all Clients access these reports periodically. Clients must always employ at least a two-factor authentication with a strong password when logging into their accounts at the Custodian or the Client Portal provided by West Branch Capital via its website. Item 14 - Client Referrals and Other Compensation A. Compensation Received by West Branch Capital Participation in Institutional Adviser Platform West Branch Capital has established an institutional relationship with Recommended Custodians to assist the Adviser in managing Client account[s]. West Branch Capital does not receive any monetary compensation from custodians. Access to the Recommended Custodians Institutional platform is provided at no charge to the Adviser. The Adviser receives access to software and related support without cost because the Adviser renders Investment Advisory services to Clients that maintain assets at Recommended Custodians. The software and related systems support may benefit the Adviser, but not its Clients directly. In fulfilling its duties to its Clients, the Adviser endeavors at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of services from a Custodian creates a conflict of interest since these benefits influence the Adviser's recommendation of one Custodian over another that does not 15 furnish similar software, systems support, or services. The Client may designate a Custodian other than the Recommended Custodian, subject to the approval of West Branch Capital. Additionally, the Adviser can receive the following benefits from Recommended Custodians: 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. Client Referrals from Solicitors West Branch Capital does not have arrangements with unaffiliated financial professionals and other outside solicitors (Referring Parties) to refer clients to West Branch Capital. Item 15 – Custody Custody, as it applies to investment Advisers, has been defined by regulators as having access or control over Client funds and/or securities. Custody is not limited to physically holding Client funds and securities. If an investment Adviser has the ability to access or control Client funds or securities, the investment Adviser is deemed to have custody and must ensure that proper procedures are implemented. West Branch Capital is deemed to have custody of Client funds and securities whenever West Branch Capital is given the authority to have fees deducted directly from Client accounts. However, this is the only form of custody West Branch Capital maintains. It should be noted that authorization to trade in Client accounts is not deemed by regulators to be custody. For accounts in which West Branch Capital is deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified Custodian in a separate account for each client under that Client’s name. Clients or an independent representative of the Client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified Custodian to each Client, or the Client’s independent representative, generally on a monthly or quarterly basis. Clients should carefully review those statements and are urged to compare the statements against reports received from West Branch Capital or posted to the Client’s portal via West Branch Capital’s website. When Clients have questions about their account statements, they should contact West Branch Capital or the qualified Custodian that has the custody of the Client’s account(s). Item 16 – Investment Discretion West Branch Capital 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 are subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by West Branch Capital. The granting of such authority will be evidenced by the Client's execution of an Investment Advisory Agreement in writing containing applicable limitations, if any, to such authority. All discretionary trades made by West Branch Capital 16 will be in accordance with each Client's investment objectives and goals. If Client’s Investment objectives change, the Client must provide such changes in writing to the Adviser. Item 17 – Voting Client Securities West Branch Capital does not vote proxies on behalf of Clients. We have determined that taking on the responsibilities for proxy voting does not add enough value to the services provided to Clients to justify the additional compliance and regulatory costs associated with proxy voting. Therefore, it is the Client’s responsibility to vote all proxies for securities held in Client account(s). Clients will receive proxies directly from the qualified Custodian or transfer agent; West Branch Capital does not provide Clients with the proxies. If you have questions about a specific proxy vote, you may contact your Portfolio Manager for assistance. However, Clients are encouraged to read through the information provided with the proxy voting documents and make a determination based on the information provided. Item 18 – Financial Information Neither West Branch Capital nor its management is experiencing adverse financial conditions, which would reasonably impair the ability of West Branch Capital to meet its obligations to its Clients. Neither West Branch Capital, nor any of its Advisory persons, has been subject to a bankruptcy. West Branch Capital is not required to deliver a balance sheet along with this Brochure, as the firm does not collect advance fees for services to be performed six months or more in advance. 17