ABTW LLC Common Communication Disclosures
Important Disclaimers
ABTW LLC ("ABTW") is a Registered Investment Advisor ("RIA"), located in the Commonwealth of Massachusetts. ABTW provides investment advisory and related services for clients nationally. ABTW will maintain all applicable registration and licenses as required by the various states in which ABTW conducts business, as applicable. ABTW renders individualized responses to persons in a particular state only after complying with all regulatory requirements, or pursuant to an applicable state exemption or exclusion.
Terms of Use
Please read these terms and conditions of use (“Terms”) carefully before using the website located at www.assetalign.net or any of the information or services provided by ABTW LLC (collectively “ABTW”, “we”, “our”, “us”) in connection with the Website. By using the Website, you acknowledge that you have read and understood these Terms and accept to be legally bound by them. If you do not accept and agree to these Terms, you are not an authorized user of the Website or any of the information or services provided by ABTW in connection with the Website and should promptly terminate all use thereof. The terms “you” and “your” mean you and any entity you may represent in connection with the use of the Website. You may use your browser to download or print a copy of these Terms for your records. ABTW reserves the right to change, modify, add or remove portions of these Terms at any time for any reason. We suggest that you review these Terms periodically for changes. Such changes shall be effective immediately upon posting. You acknowledge that by accessing our Website after we have posted changes to these Terms, you are agreeing to these Terms as modified. These Terms were last updated on March 28, 2024.
Risk Disclosure
Different types of investments involve varying degrees of risk. Therefore, it should not be assumed that future performance of any specific investment or investment strategy will be profitable.
Asset allocation may be used in an effort to manage risk and enhance returns. It does not, however, guarantee a profit or protect against loss. Performance of the asset allocation strategies depends on the underlying investments. This website is intended to provide general information about ABTW and its services. It is not intended to offer or deliver investment advice in any way. Information regarding investment services are provided solely to gain an understanding of our investment philosophy, our strategies and to be able to contact us for further information.
Market data, articles and other content on this website are based on generally available information and are believed to be reliable. ABTW does not guarantee the accuracy of the information contained in this website. The information is of a general nature and should not be construed as investment advice.
Please remember that it remains your responsibility to advise ABTW, in writing, if there are any changes in your personal/financial situation or investment objectives for the purpose of reviewing/evaluating/revising our previous recommendations and/or services, if you would like to impose, add, or to modify any reasonable restrictions to our investment advisory services.
ABTW will provide all prospective clients with a copy of our current Form ADV, Part 2A ("Disclosure Brochure"), Form ADV Part 2B, which is the Brochure Supplement for each advisory person supporting a particular client. You may obtain a copy of these disclosures on the SEC website at http://adviserinfo.sec.gov or you may Contact Us to request a free copy via .pdf or hardcopy.
Privacy Disclosures
ABTW is committed to safeguarding the use of personal information of our Clients (also referred to as "you" and "your") that we obtain as your Investment Advisor, as described in our Privacy Policy.
ABTW does not collect personal non-public information through this website; however, the Advisor may collect information from you on application forms, agreements, profile or investment policy statements, and other documents received or processed in relation to services we provide. We also may collect information from other sources.
We do not respond to "do not track" requests because we do not track you over time or across third party websites to provide targeted advertising. We may track you across our website to help us improve our content.
We may use "cookies" and similar online technologies to keep, and sometimes track, information about you regarding your usage of our website. Cookies are small data files that are sent to your browser or related software from a Web server and stored on your device. Cookies help us to collect information about your usage of our website, including date and time of visits, pages viewed, amount of time spent on our sites, or general information about the device used to access the site, such as the browser used. You can refuse to store or delete cookies by configuring your web browser settings. Most browsers and mobile devices have their own settings to manage cookies. If you refuse a cookie when on our website, or if you delete cookies, you may experience some inconvenience in your use of our website, such as having to re-configure preferences.
When you are on this website you may have the opportunity to click-through to other websites, including websites operated by unaffiliated third parties. These sites may collect nonpublic personal Information about you. We do not control sites operated by these entities and are not responsible for the information practices of these sites. This Privacy Policy does not address the information practices of other websites. The privacy policies of websites operated third parties are located on those sites.
For a copy of the ABTW Privacy Policy, please click here.
Email Disclosures
ABTW often communicates with its clients and prospective clients through electronic mail ("email") and other electronic means. Your privacy and security are very important to us. ABTW makes every effort to ensure that email communications do not contain sensitive information. We remind our clients and others not to send ABTW private information over email. If you have sensitive data to deliver, we can provide secure means for such delivery.
Please note: ABTW does not accept trading or money movement instructions via email.
As a registered investment advisor, ABTW emails may be subject to inspection by the Chief Compliance Officer ("CCO") of ABTW or the securities regulators.
If you have received an email from ABTW in error, we ask that you contact the sender and destroy the email and its contents.
If you have any questions regarding our email policies, please Contact Us.
Social Websites
ABTW may utilize third-party websites, including social media websites, blogs and other interactive content. ABTW considers all interactions with clients, prospective clients and the general public on these sites to be advertisements under the securities regulations. As such, ABTW generally retains copies of information that ABTW or third-parties may contribute to such sites. This information is subject to review and inspection by the CCO of ABTW or the securities regulators.
Information provided on these sites is for informational and/or educational purposes only and is not, in any way, to be considered investment advice nor a recommendation of any investment product. Advice may only be provided by ABTW's advisory persons after entering into an advisory agreement and provided ABTW with all requested background and account information.
If you have any questions regarding our policies, please Contact Us.
Disclosure:
ABTW LLC ("ABTW") is a Registered Investment Adviser.
This content is intended to provide general information about ABTW. It is not intended to offer or deliver investment advice in any way. Information regarding investment services are provided solely to gain an understanding of our investment philosophy, our strategies and to be able to contact us for further information.
All information has been obtained from sources believed to be reliable, but its accuracy is not guaranteed. There is no representation or warranty as to the current accuracy, reliability or completeness of, nor liability for, decisions based on such information and it should not be relied on as such.
The views expressed in this commentary are subject to change based on market and other conditions. These documents may contain certain statements that may be deemed forward‐looking statements. Please note that any such statements are not guarantees of any future performance and actual results or developments may differ materially from those projected. Any projections, market outlooks, or estimates are based upon certain assumptions and should not be construed as indicative of actual events that will occur.
Past performance is no guarantee of future returns.
Different types of investments involve varying degrees of risk. Therefore, it should not be assumed that future performance of any specific investment or investment strategy will be profitable.
Additional Important Disclosures may be found in the ABTW Form ADV Part 2A. For a copy, please Click here.
Form ADV Part 2A – Disclosure Brochure
Effective: March 4, 2024
This Form ADV Part 2A ("Disclosure Brochure") provides information about the qualifications and business practices of ABTW LLC ("AssetAlign" or the "Advisor"). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at 617-279-6190 or by email at john@assetalign.net.
AssetAlign is a registered investment advisor located in the Commonwealth of Massachusetts. 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 advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about AssetAlign to assist you in determining whether to retain the Advisor.
Additional information about AssetAlign and its Advisory Persons is available on the SEC's website at www.adviserinfo.sec.gov by searching with the Advisor's firm name or CRD# 329950.
ABTW LLC
50 Broadway, Stoneham, MA, 02180
Phone: 617-279-6190
www.assetalign.net
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor's business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory Persons of AssetAlign. For convenience, the Advisor has combined these documents into a single disclosure document.
AssetAlign believes that communication and transparency are the foundation of its relationship with clients and will continually strive to provide you with complete and accurate information at all times. AssetAlign encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
Material Changes
AssetAlign is a newly formed registered investment advisor. This is the initial filing of the Disclosure Brochure.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor's firm name or CRD# 329950. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at 617-279-6190 or by email at john@assetalign.net.
Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Services
Item 5 – Fees and Compensation
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 – Brokerage Practices
Item 13 – Review of Accounts
Item 14 – Client Referrals and Other Compensation
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Item 19 – Requirements for State Registered Advisors
Form ADV Part 2B – Brochure Supplement
Privacy Policy
Item 4 – Advisory Services
A. Firm Information
ABTW LLC ("AssetAlign" or the "Advisor") is a registered investment advisor located in the Commonwealth of Massachusetts. The Advisor is organized as a Limited Liability Company under the laws of Massachusetts. AssetAlign was founded in December 2023. The Advisor is owned and operated by John Gavin (President and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by AssetAlign.
B. Advisory Services Offered
AssetAlign supports individuals and high net worth individuals (each referred to as a "Client") access investment advisory services from third-party registered investment advisory firms (each referred to as a "Third-Party RIA"). AssetAlign will work with the Client to understand their investment needs and then recommend the appropriate Third-Party RIA.
AssetAlign does not manage Client assets or accounts. Instead, AssetAlign will recommend a Third-Party RIA and assist the Client with establishing an advisory relationship with the Third-Party RIA. AssetAlign will receive compensation from the Third-Party RIA to which Clients are referred for investment advisory services. When making a referral recommendation, AssetAlign will provide the Client with a written solicitor disclosure statement describing the relationship between AssetAlign and the Third-Party RIA, including information regarding the compensation received by AssetAlign for the referral (the "Disclosure Statement"). In addition, AssetAlign will provide the Form ADV2A – Disclosure Brochure for the Third-Party RIA.
C. Client Account Management
AssetAlign does not manage Client assets and therefore has no disclosure for this Item.
D. Wrap Fee Programs
AssetAlign does not manage or place Client assets into a wrap fee program and therefore has no disclosure for this Item.
E. Assets Under Management
AssetAlign does not manage Client assets and therefore has no disclosure for this Item.
Item 5 – Fees and Compensation
AssetAlign is compensated through referral fee arrangements with a Third-Party RIA pursuant to a solicitor agreement, which is paid to AssetAlign at a quarterly rate. AssetAlign is only compensated when a Client engages with a Third-Party RIA that has a solicitor agreement with AssetAlign to share in the revenue generated by the Client's relationship with the Third-Party RIA. The referral fee is fully disclosed to each Client in the Disclosure Statement provided by AssetAlign.
Third-Party RIAs may terminate the referral fee relationship pursuant to the terms of their solicitor agreement with AssetAlign. The agreement between the Client and a Third-Party RIA are governed by the terms of the investment advisory agreement between those parties.
Item 6 – Performance-Based Fees and Side-By-Side Management
AssetAlign does not manage Client assets nor charges performance-based fees and therefore has no disclosure for this item.
Item 7 – Types of Clients
AssetAlign supports individuals and high net worth individuals with their investment needs. AssetAlign does not manage any Client accounts and solely refers Clients to a Third-Party RIA.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
AssetAlign does not manage Client assets. AssetAlign recommends Third-Party RIAs to provide investment advisory services to Clients.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving AssetAlign or Mr. John Gavin. AssetAlign values the trust Clients and Third-Party RIAs place in the Advisor. The Advisor encourages Clients and Third-Party RIAs to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor's firm name or CRD# 329950.
In addition, Clients may also obtain information relating to the disciplinary history of any investment advisor representative conducting business in Massachusetts by contacting the Commonwealth of Massachusetts Securities Division at (617) 727-3548.
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of AssetAlign and Mr. Gavin is to provide services to its Clients. Neither AssetAlign nor Mr. Gavin are involved in any other financial industry activities or affiliations.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
AssetAlign has adopted a Code of Ethics that applies to all Supervised Persons of the Advisor. The Code of Ethics requires Supervised Persons to act in the best interests of Clients and to avoid conflicts of interest. The Code of Ethics also requires Supervised Persons to report personal securities transactions and to comply with all applicable securities laws and regulations.
Item 12 – Brokerage Practices
AssetAlign does not select or recommend broker-dealers/custodians. AssetAlign refers Clients to Third-Party RIAs, which may recommend these providers to complement and support their services. Please see the Third-Party RIA's Form ADV Part 2A – Disclosure Brochure for information regarding Brokerage Practices.
Item 13 – Review of Accounts
AssetAlign does not manage Client accounts and therefore has no disclosure for this Item.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by AssetAlign
AssetAlign receives compensation from Third-Party RIAs pursuant to solicitor agreements. This compensation is fully disclosed to Clients in the Disclosure Statement provided by AssetAlign.
B. Compensation for Client Referrals
AssetAlign does not pay any compensation to third parties for client referrals.
Item 15 – Custody
AssetAlign does not have custody of Client assets and therefore has no disclosure for this Item.
Item 16 – Investment Discretion
AssetAlign does not have investment discretion over Client accounts and therefore has no disclosure for this Item.
Item 17 – Voting Client Securities
AssetAlign does not vote Client securities and therefore has no disclosure for this Item.
Item 18 – Financial Information
AssetAlign is not required to provide financial information disclosures.
Item 19 – Requirements for State Registered Advisors
A. Educational Background and Business Experience of Principal Officer
John P. Gavin, born in 1982, is the President and Chief Compliance Officer of AssetAlign. Mr. Gavin earned a Bachelors degree from University of Massachusetts - Amherst in 2005. Mr. Gavin served as Managing Regional Director at Natixis Advisors, LLC from November 2010 to July 2023.
B. Other Business Activities of Principal Officer
Mr. Gavin is dedicated to the investment advisory activities of AssetAlign's Clients. Mr. Gavin does not have any other business activities.
C. Performance Fee Calculations
AssetAlign does not charge performance-based fees and therefore has no disclosure for this Item.
D. Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding AssetAlign or Mr. Gavin. Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding AssetAlign or Mr. Gavin.
E. Material Relationships with Issuers of Securities
Neither AssetAlign nor Mr. Gavin has any relationships or arrangements with issuers of securities.
Form ADV Part 2B – Brochure Supplement
for
John P. Gavin
President and Chief Compliance Officer
Effective: March 4, 2024
This Form ADV 2B ("Brochure Supplement") provides information about the background and qualifications of John P. Gavin (CRD# 5524005) in addition to the information contained in the ABTW LLC ("AssetAlign" or the "Advisor", CRD# 329950) Disclosure Brochure. If you have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the AssetAlign Disclosure Brochure or this Brochure Supplement, please contact us at 617-279-6190 or by email at john@assetalign.net.
Additional information about Mr. Gavin is available on the SEC's Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5524005.
Item 2 – Educational Background and Business Experience
John P. Gavin, born in 1982, is dedicated to advising Clients of AssetAlign as the President and Chief Compliance Officer. Mr. Gavin earned a Bachelors degree from University of Massachusetts - Amherst in 2005. Additional information regarding Mr. Gavin's employment history is included below.
Employment History:
President and Chief Compliance Officer, ABTW LLC
03/2024 to Present
Managing Regional Director, Natixis Advisors, LLC
11/2010 to 07/2023
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Gavin. Mr. Gavin has never been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against Mr. Gavin.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no legal, civil or disciplinary events to disclose regarding Mr. Gavin.
However, we do encourage you to independently view the background of Mr. Gavin on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5524005.
Item 4 – Other Business Activities
Mr. Gavin is dedicated to the investment advisory activities of AssetAlign's Clients. Mr. Gavin does not have any other business activities.
Item 5 – Additional Compensation
Mr. Gavin is dedicated to the investment advisory activities of AssetAlign's Clients. Mr. Gavin does not receive any additional forms of compensation.
Item 6 – Supervision
Mr. Gavin serves as the President and Chief Compliance Officer of AssetAlign. Mr. Gavin can be reached at 617-279-6190.
AssetAlign has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in meeting their fiduciary obligations to Clients of AssetAlign. Further, AssetAlign is subject to regulatory oversight by various agencies. These agencies require registration by AssetAlign and its Supervised Persons. As a registered entity, AssetAlign is subject to examinations by regulators, which may be announced or unannounced. AssetAlign is required to periodically update the information provided to these agencies and to provide various reports regarding the business activities and assets of the Advisor.
Item 7 – Requirements for State Registered Advisors
A. Arbitrations and Regulatory Proceedings
State regulations require disclosure if any Supervised Person of the Advisor is subject to:
1. An award or otherwise being found liable in an arbitration claim alleging damages in excess of $2,500, involving any of the following:
1. an investment or an investment-related business or activity;
2. fraud, false statement(s), or omissions;
3. theft, embezzlement, or other wrongful taking of property;
4. bribery, forgery, counterfeiting, or extortion; or
5. dishonest, unfair, or unethical practices.
2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following:
1. an investment or an investment-related business or activity;
2. fraud, false statement(s), or omissions;
3. theft, embezzlement, or other wrongful taking of property;
4. bribery, forgery, counterfeiting, or extortion; or
5. dishonest, unfair, or unethical practices.
Mr. Gavin does not have any disclosures to make regarding this Item.
B. Bankruptcy
If a Supervised Person has been the subject of a bankruptcy petition, that fact and the details must be disclosed.
Mr. Gavin does not have any disclosures to make regarding this Item.
Privacy Policy
Effective: March 4, 2024
Our Commitment to You
ABTW LLC ("AssetAlign" or the "Advisor") is committed to safeguarding the use of personal information of our Clients (also referred to as "you" and "your") that we obtain as your Investment Advisor, as described here in our Privacy Policy ("Policy").
Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. AssetAlign (also referred to as "we", "our" and "us") protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you.
AssetAlign does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy.
Why you need to know?
Registered Investment Advisors ("RIAs") must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information.
What information do we collect from you?
Driver's license number
Date of birth
Social security or taxpayer identification number
Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Account applications and forms
Other advisory agreements and legal documents
Investment questionnaires and suitability documents
Transactional information with us or others
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client's personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive from us.
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information.
State Specific Regulations
Changes to our Privacy Policy: We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at 617-279-6190 or via email at john@assetalign.net.
MA Fee Table
