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Form ADV Part 2A: Firm Disclosure Brochure
Amendment – March 12, 2025
O’Brien Wealth Partners LLC
Jill A. Fopiano, CEO, CIO
51 Sawyer Road, Suite 600
Waltham, MA 02453
(617) 547-6717
www.obrienwp.com
Disclaimer
O’Brien Wealth Partners LLC is a registered investment adviser with the Securities and Exchange Commission
as well as with the Massachusetts Securities Division. This in no way implies a certain level of skill or training.
The ADV Part 2A brochure provides information about the qualifications and business practices of O’Brien
Wealth Partners LLC. If you have any questions about the contents of the brochure, please contact us at (617)
547-6717 or info@obrienwp.com. The information in the brochure has not been approved or verified by the
United States Securities and Exchange Commission or by any state securities authority.
Additional information about O’Brien Wealth Partners LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov.
O’Brien Wealth Partners LLC Form ADV Part 2A
Date: 3/12/2025
Item 2
Summary of Material Changes
Since the last annual filing of our Form ADV Part 2A dated February 26, 2024, we have the following material
changes to report:
• Our supervised persons have entered into arrangements which resulted in our firm being deemed to have
constructive custody over certain client assets. Please refer to Item 15 of our Form ADV Part 2A for
additional information.
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Page: 2
Item 3
Table of Contents
ITEM 2
SUMMARY OF MATERIAL CHANGES ......................................................................................................................... 2
ITEM 3 TABLE OF CONTENTS ..................................................................................................................................................... 3
ITEM 4 ADVISORY BUSINESS ....................................................................................................................................................... 4
ITEM 5 FEES AND COMPENSATION ........................................................................................................................................... 5
ITEM 6 PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ................................................................... 6
ITEM 7 TYPES OF CLIENTS .......................................................................................................................................................... 7
ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................................................... 7
ITEM 9 DISCIPLINARY INFORMATION ..................................................................................................................................... 9
ITEM 10
OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................................ 9
ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS & PERSONAL TRADING
................................................................................................................................................................................................................. 10
ITEM 12
BROKERAGE PRACTICES ........................................................................................................................................ 12
ITEM 13
REVIEW OF ACCOUNTS ........................................................................................................................................... 13
ITEM 14
CLIENT REFERRALS AND OTHER COMPENSATION ...................................................................................... 14
ITEM 15
CUSTODY ...................................................................................................................................................................... 14
ITEM 16
INVESTMENT DISCRETION ..................................................................................................................................... 14
ITEM 17
VOTING CLIENT SECURITIES ................................................................................................................................ 15
ITEM 18
FINANCIAL INFORMATION .................................................................................................................................... 17
O’Brien Wealth Partners, LLC Form ADV Part 2A
Date: 3/12/2025
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Item 4
Advisory Business
Introduction
Established in 1986 and located in Boston, MA, O’Brien Wealth Partners LLC is a fee-only registered
investment adviser (or RIA). Our principal owner is Jill A. Fopiano, who is also our President, Chief Executive
Officer and Chief Investment Officer.
Our services
O’Brien Wealth Partners provides the following advisory services:
- Investment Strategy Development
- Investment Management
- Pension Consulting
- Portfolio Accounting and Reporting
- Financial Planning, including retirement, tax, education and lifestyle planning
- Client Education
O’Brien Wealth Partners offers advisory services to individuals, businesses and nonprofits. O’Brien Wealth
Partners primarily invests in mutual funds and exchange-traded funds. Thus, to achieve equity exposure, we
invest in funds with investment objectives to invest entirely or predominantly in equities, and to achieve fixed
income exposure, we invest in funds with investment objectives to invest entirely or predominantly in fixed
income (in each case, subject to defensive strategies, e.g., increasing cash). We seek to invest in no-load, load-
waived or institutional mutual fund share classes.
Our investment philosophy is organized around two primary investment objectives. The first is to preserve
clients’ capital and purchasing power. The second is to earn an attractive rate of return on clients’ assets.
O’Brien Wealth Partners tailors its advisory services to the individual needs of clients. We begin with a
discussion of an individual’s goals, risk tolerance, liquidity needs, current lifestyle and time horizon. This
discussion becomes the foundation for creating a long-term strategy and financial plan. The investment strategy
created for each client is based on that client’s objectives and tolerance for risk.
O’Brien Wealth Partners will follow investment restrictions imposed by clients or will seek to invest only in
socially responsible funds on request.
We may also, when appropriate, sub-advise certain portions of a client portfolio to independent third-party
managers or recommend direct investment with independent third-party managers, typically when those
managers demonstrate knowledge and expertise in a particular investment strategy.
As part of this service, we perform management searches of various unaffiliated registered investment advisers.
Based on a client's individual circumstances and needs we will determine which selected registered investment
adviser's portfolio management style is appropriate for that client. Factors considered in making this
determination include account size, risk tolerance, the opinion of each client and the investment philosophy of
the selected registered investment adviser. We encourage clients to review each third-party manager’s
disclosure document regarding the particular characteristics of any program and managers selected by us.
O’Brien Wealth Partners will regularly and continuously monitor the performance of the selected registered
investment adviser(s). If we determine that a particular selected registered investment adviser(s) are not
providing sufficient management services to the client, or are not managing the client's portfolio in a manner
consistent with the client's IPS, we will remove the client's assets from that selected registered investment
O’Brien Wealth Partners, LLC Form ADV Part 2A
Date: 3/12/2025
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adviser(s) and place the client's assets with another registered investment adviser(s) at our discretion, if so
granted by the client, and without prior consent from the client.
Our firm will conduct appropriate due diligence on all independent third-party managers, where appropriate and
applicable, making reasonable inquiries into their performance calculations, policies and procedures, Code of
Ethics, and other operational and compliance matters deemed important to account performance and risk
management.
ESG Investments: Our ESG security selection is typically limited to select Exchange Traded Funds (“ETFs”),
mutual funds and third-party investment accounts that are managed by unaffiliated third parties. As such, our
firm has no control over the selection of investments within those instruments or accounts. Our firm relies on
internal screening and/or the representations and screening processes of the third-party advisers responsible for
managing each instrument and account. While our firm will conduct due diligence on each manager’s overall
investment mandate and philosophy, we cannot guarantee that each security held within the instrument or
account structure will align with the ESG objectives and restrictions expressed by its clients.
The amount of client assets O’Brien Wealth Partners currently manages is approximately $1,109,353,637, as
last calculated on 12/31/2024. O’Brien Wealth Partners manages its clients’ assets on a discretionary basis, that
is, each client gives O’Brien Wealth Partners the authority to make investment decisions without notifying
them.
Item 5
Fees and Compensation
Management Fees
O’Brien Wealth Partners LLC is a fee-only investment adviser.
O’Brien Wealth Partners’ general fee schedule is below. Fees are paid in advance based on the total value
of the client’s investments that are advised by O’Brien Wealth Partners at the end of the preceding quarter.
The value of the client’s investments is equal to the market value of the portfolios. We have a tiered fee
structure, which means the first $1 million will be charged a fee of 1% and amounts over $1 million up to $3
million will be charged a fee of 0.75% and amounts over $3 million will be charged a fee of 0.50%.
Assets under management
Management fee rate
(on total amount invested)
Amounts up to $1 million
1.0%
Amounts over $1 million up to $3 million
0.75%
Amounts over $3 million
0.5%
Client assets will be reduced by the asset-based advisory fee charged by O’Brien Wealth Partners, the
expense ratios of the mutual funds and exchange-traded funds in which we invest, and any fees charged by
broker-dealers or custodians to process transactions. See Item 8 for fees that may be incurred with separate
account managers.
On occasion, O’Brien Wealth Partners consults on investment and financial planning issues at an hourly fee
ranging from $300.00 - $500.00.
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Most fees are deducted from the appropriate client account(s) by the custodian. If a client wishes, he or she
may select to be billed directly and pay by check for their fees incurred. O’Brien Wealth Partners bills
clients in advance on a quarterly basis.
O’Brien Wealth Partners’ fees may be negotiated. O’Brien Wealth Partners may negotiate or reduce fees
based upon a number of factors, including the overall client relationship, the type of account, the size of the
account, the number and range of supplemental advisory and client-related services to be provided to the
client, and other business considerations. The fee schedule may be modified by O’Brien Wealth Partners
upon notice to its client(s). Discounts, not generally available to our advisory clients, may be offered to
family members and friends. O’Brien Wealth Partners may group certain related client accounts for the
purposes of determining the account size and/or annualized fee. Certain legacy client agreements may be
governed by fee schedules different from those listed above.
If either the client or O’Brien Wealth Partners terminates the investment advisory contract at any time, any
management fees paid in advance for services provided shall be refunded on a pro-rata basis based on days
remaining in the quarter.
Unless agreed otherwise, any and all account asset classes, including cash positions, are included in the
firm’s advisory fee calculation. At certain times our advisory fee may exceed the money market yield for
cash assets.
Selected sub-advisers and third-party managers may elect to directly debit client accounts for their
management fees upon receiving permission from each client. These managers may charge their fees in
advance or in arrears, monthly or quarterly, depending on the terms of each investment program and each
selected manager’s billing practices.
Mutual Fund and ETF Fees and Expenses: All fees paid to O’Brien Wealth Partners for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their
shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally
include a management fee, other fund expenses, and a possible distribution fee. A client could invest in a
mutual fund or and ETF directly, without the services of O’Brien Wealth Partners. In that case, the client
would not receive the services provided by O’Brien Wealth Partners which are designed, among other
things, to assist the client in determining which mutual fund or funds or ETFs are most appropriate to each
client's financial condition and objectives. Accordingly, the client should review both the fees charged by
the funds and ETFs and the fees charged by O’Brien Wealth Partners to fully understand the total amount of
fees to be paid by the client and to thereby evaluate the advisory services being provided.
Brokerage and Custodial Fees
In addition to advisory fees paid to O’Brien Wealth Partners, clients will also be responsible for all
transaction, brokerage, and custodial fees incurred as part of their account management. Please see Item
12 of this Brochure for important disclosures regarding our brokerage practices.
Item 6
Performance-Based Fees and Side-By-Side Management
O’Brien Wealth Partners does not charge performance-based fees, which are fees based on earning a particular
share of capital gains on, or capital appreciation of, the assets of a client.
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Item 7
Types of Clients
O’Brien Wealth Partners provides investment advice to individuals, families, businesses, nonprofit
organizations, pensions and endowments. O’Brien Wealth Partners generally requires a minimum account size
of $1,000,000. Exceptions may be made to the minimum account size based on individual circumstances.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
The methods of analysis and investment strategies O’Brien Wealth Partners employs in formulating investment
advice or managing assets are described below in our Investment Objective, Strategy and Process Statement:
O’Brien Wealth Partners’ Investment Objective, Strategy and Process Statement
Investment Objective
Our investment philosophy is to manage assets for their purpose. This can include preserving capital and
purchasing power and earning an attractive rate of return on assets.
By adhering to a disciplined and proven investment process, we seek to help our clients reach their financial
goals without exposing their financial assets to undue risk.
Investment Strategy
Our investment strategy revolves around four major tenets:
❑ The asset allocation decision dominates investment return
❑ Effective diversification minimizes volatility and optimizes return
❑ Commitment to being fully invested with limited tactical market timing
❑ Managing to the client’s time horizon, risk tolerance, and financial goals
Financial assets are typically divided into four broad classes – equities (stocks), fixed income (bonds),
alternative assets and cash. The appropriate allocation between these asset classes is dependent on the client’s
financial goals, time horizon and risk tolerance.
Of the four major asset classes, equities are the most volatile and therefore are considered the riskiest. Because
the long-term investor earns a premium for accepting the ups and downs of the stock market, equity exposure
should dominate most investment portfolios. Fixed income securities are an integral part of an investment
portfolio and serve two purposes. They provide income and help to dampen the overall volatility of a portfolio
because of their greater price stability. Alternative assets are securities or other financial assets whose returns
exhibit a low or negative correlation to traditional equity and fixed income securities. The cash portion of a
portfolio should provide for liquidity needs.
Diversification is designed to allow investors to optimize returns and dampen volatility. Effective
diversification is achieved by investing in asset classes with different return patterns, and within asset classes by
mixing funds that have different return patterns. Combining asset classes and funds that have low correlations
improves a portfolio’s overall return for a given amount of risk.
At O’Brien Wealth Partners, the equity portion of a portfolio is structured to include mutual funds and
exchange-traded funds that emphasize large, medium and small companies and to incorporate both value and
growth investing styles, as well as domestic and foreign exposure. Well-diversified portfolios allow our clients
to take advantage of growth in positive markets and help to preserve principal in most down markets.
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The appropriate asset allocation is determined by an investor’s time horizon, risk tolerance and financial goals.
The longer an investor’s time horizon, the greater amount of risk the investor should be able to accept.
However, over shorter periods of time, equities may be too volatile. An investor anticipating the need to
liquidate a significant portion of their portfolio within the short run should allocate a more significant portion
toward fixed income and cash to minimize the risk of having to sell equity securities at a loss. Conversely, an
investor with a longer time horizon may justify a higher exposure to equities.
An individual’s risk tolerance must also be taken into consideration when determining the proper asset
allocation. If an investor cannot tolerate significant losses on his or her whole portfolio in a given year, then
reduced exposure to equities in favor of less volatile bonds may be appropriate.
Interval Funds
When consistent with a client’s investment objectives, O’Brien Wealth Partners may allocate investment assets
to interval funds. Investment companies structured as interval funds are generally designed for long-term
investors who do not require daily liquidity. Shares in interval funds typically do not trade on the secondary
market. Instead, their shares are subject to periodic redemption offers by the fund at a price based on net asset
value. Accordingly, interval funds are subject to liquidity constraints. Interval funds investing in securities of
companies with smaller market capitalizations, derivatives, or securities with substantial market and/or credit
risk tend to have the greatest exposure to liquidity risk. Generally, the interval funds recommended by O’Brien
Wealth Partners offer a one to two week period, on a quarterly basis, during which the client may seek the
redemption of previously purchased interval funds. Given the lack of secondary market, the infrequent nature of
the offers to buy back shares, and the liquidity gates (or re-purchase limits), the investor should consider the
shares of interval funds to be illiquid.
Emerging Market Funds
In general, investment in foreign issuer securities entails additional risks such as limited transparency and
accounting overview, varying frequency, availability and quality of financial information, limited enforcement
opportunities by US regulators, and limited shareholder rights and/or remedies.
Investment Process
We construct client portfolios from funds that invest predominantly in the equity, fixed income or alternative
asset classes, as well as cash (i.e., money market funds). Model portfolios, based on our best thinking at any
point in time, are constructed to match broad investment objectives. Blended or balanced portfolios made up of
a combination of core equity and core fixed income positions are constructed dependent on a client’s financial
goals, time horizon, risk tolerance and tax status. Model portfolios are used as a guideline for constructing
individual client portfolios; a client’s specific objectives and tax situation may dictate variances from the model.
Fund Selection and Due Diligence
The model portfolios are populated from a list of approved mutual funds and exchange-traded funds. The
approval process is carried out at the investment committee level and involves many levels of analysis and
discussions before a consensus decision is reached. Funds selected have a clear and understandable investment
philosophy that has been followed for an extended period of time. There are many criteria included in the
selection process including performance, risk, manager qualifications, tax efficiency, expenses and fees. Fund
expenses are important selection criteria. We look to minimize costs by using funds with relatively low expense
ratios and by buying the institutional share class when available.
Direct contact with fund company representatives and the fund manager serve as a primary source of
information. Before a fund is approved, the prospectus and statement of additional information are reviewed
and analyzed, and we engage in conversations or in-person meetings with fund management. We subscribe to
various database and independent research services and use them for screening purposes and the gathering of
fundamental information. At regular investment committee meetings, fund performance is monitored and
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pertinent newsworthy information on individual funds is shared. The performance of funds against their peers
is reviewed on a regular basis.
A risk of mutual fund and/or exchange-traded fund analysis is that, as in all securities investments, past
performance does not guarantee future results. A manager who has been successful may not be able to replicate
that success in the future. In addition, as we do not control the underlying investments in a fund, managers of
different funds held by the client may purchase the same security, increasing the risk to the client if that security
were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or
strategy of the fund, which could make the fund suitable of the client’s portfolio.
Third-Party Manager Analysis
We examine the experience, expertise, investment philosophies, and past performance of independent third-
party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over
a period of time and in different economic conditions. We monitor the manager’s underlying holdings,
strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of
our due-diligence process, we survey the manager’s compliance and business enterprise risks.
A risk of investing with a third-party manager who has been successful in the past is that it may not be able to
replicate that success in the future. In addition, as we do not control the underlying investments in a third-party
manager’s portfolio, there is also a risk that a manager may deviate from the stated investment mandate or
strategy of the portfolio, making it a less suitable investment for our clients. Moreover, as we do not control the
manager’s daily business and compliance operations, it is possible for us to miss the absence of internal controls
necessary to prevent business, regulatory or reputational deficiencies.
Risks for all forms of analysis: Our securities analysis method relies on the assumption that the companies
whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-
available sources of information about these securities, are providing accurate and unbiased data. While we are
alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by
inaccurate or misleading information.
Clients should understand that investing in any securities, including mutual funds, involves a risk of loss of
both income and principal.
Item 9
Disciplinary Information
O’Brien Wealth Partners has not been the subject of any legal or disciplinary events that are material to a
client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Neither
O’Brien Wealth Partners nor any of its management or staff has:
a) been the subject of a criminal or civil action in a domestic, foreign or military court of competent
jurisdiction;
b) been the subject of any administrative proceedings before the SEC;
c) been the subject of any proceeding by any other federal regulatory agency, any state regulatory
agency, or any foreign financial regulatory authority; or,
d) been subject of a self-regulatory organization proceeding.
Item 10
Other Financial Industry Activities and Affiliations
O’Brien Wealth Partners, LLC Form ADV Part 2A
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Neither O’Brien Wealth Partners nor any of its management persons are registered, or have an application
pending to register, as a broker-dealer or a registered representative of a broker-dealer.
Neither O’Brien Wealth Partners nor any of its management persons are registered, or have an application
pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser,
or an associated person of the foregoing entities.
Neither O’Brien Wealth Partners nor any of its management persons have a relationship or arrangement that is
material to our advisory business or to our clients with any of the following:
1. broker-dealer, municipal securities dealer, or government securities dealer or broker;
2. investment company or other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or “hedge fund,” and
offshore fund);
3. other investment adviser or financial planner;
4. futures commission merchant, commodity pool operator, or commodity trading adviser;
5. banking or thrift institution;
6. accountant or accounting firm;
7. lawyer or law firm;
8. insurance company or agency;
9. pension consultant;
10. real estate broker or dealer; or,
11. sponsor or syndicator of limited partnerships.
O’Brien Wealth Partners does not participate in any other financial industry activities and affiliations that may
create conflicts of interest or impair the objectivity of O’Brien Wealth Partners’ investment advice.
As an institutional adviser doing business with Charles Schwab & Co., we may from time to time participate in
seminars offered by Charles Schwab to advisers. Such complimentary seminars may include management
training, operations workshops or compliance seminars. We may also participate in seminars or conferences
offered by mutual fund companies. Such seminars may include general education on economic and market
trends as well as more specific due diligence information on fund composition, philosophy and management.
See Item 14 for certain benefits we may receive as a result of our relationship with Charles Schwab.
O’Brien Wealth Partners will accept referrals from other associates, (e.g., accountants, estate planners), but does
not pay compensation in any way for such referrals.
Item 11 Code of Ethics, Participation or Interest in Client Transactions & Personal
Trading
O’Brien Wealth Partners is an SEC-registered adviser and has adopted a Code of Ethics pursuant to SEC Rule
204A-1. The Code provides that all employees have a fiduciary responsibility to place the interests of clients
ahead of their own interests and O’Brien Wealth Partners’ interests. A copy of the O’Brien Wealth Partners’
Code of Ethics is available to any existing or prospective client upon request. Requests should be addressed to
Richard A. Davies, O’Brien Wealth Partners LLC, 51 Sawyer Road, Suite 600, Waltham, MA 02453.
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O’Brien Wealth Partners staff members do not recommend securities in which a staff member or related person
has a material financial interest (other than as an investor in the ordinary course), nor do they buy or sell such
securities for client accounts.
O’Brien Wealth Partners staff may invest in the same securities (or related securities, e.g., warrants, options or
futures) that we recommend to clients. Each employee is required to conduct all personal securities transactions
in a manner that is consistent with our Code of Ethics to avoid any actual or potential conflict of interest. No
employee may misuse information about client accounts, abuse his or her position of trust and responsibility or
take inappropriate advantage of his or her position. O’Brien Wealth Partners has a personnel security trading
policy which it believes is reasonably designed to minimize potential conflicts of interest between O’Brien
Wealth Partners staff and its clients.
The interests of clients of O’Brien Wealth Partners always come first. O’Brien Wealth Partners employees are
required to conduct all personal securities transactions in a manner that is consistent with our Code of Ethics
and Code of Ethics Relating to Inside Information. It is written in our Code of Ethics that,
All Access Persons must scrupulously avoid serving their own personal interests ahead of the interests of the
Company's Advisory Clients. Access Persons may not induce or cause an Advisory Client to take action, or not
to take action, for personal benefit, rather than for the benefit of the Advisory Client. For example, a
supervisor or employee would violate the policy by causing an Advisory Client to purchase a security he or she
owned for the purpose of increasing the price of that security. Doubtful situations always should be resolved in
favor of Advisory Clients. Technically, compliance with the Code's provisions shall not automatically insulate
from scrutiny any securities transactions or actions that indicate a violation of O’Brien Wealth Partners’
fiduciary duties.
Pursuant to recent Department of Labor regulations, O’Brien Wealth Partners is required to acknowledge in
writing its fiduciary status under Section 3(21) of the Employee Retirement Income Security Act of 1974, as
amended (“ERISA”) and Section 4975 of the Internal Revenue Code of 1986, as amended (the “Code”), as
applicable.
When O’Brien Wealth Partners provides investment advice to you regarding your retirement plan account or
individual retirement account, it is a fiduciary within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts.
The way O’Brien Wealth Partners makes money creates some conflicts with your interests, so our firm operates
under a special rule that requires it to act in your best interest and not put its interests ahead of yours.
Asset Roll-Over Disclosure:
Consistent with this fiduciary duty, O’Brien Wealth Partners is required to disclose applicable conflicts of interest
associated with its rollover recommendations. Our rollover recommendations create a conflict of interest if
O’Brien Wealth Partners will earn a new (or increase its current) advisory fee on the rolled over assets. Please
see Item 5 of Form ADV Part 2A for further information regarding our services, fees, and other conflicts of
interest.
Clients and prospective clients considering a rollover from a qualified employer sponsored workplace retirement
plan (“Employer Retirement Plan”) to an Individual Retirement Account (“IRA”), or from an IRA to another
IRA, are encouraged to consider and to investigate the advantages and disadvantages of an IRA rollover from
their existing plan or IRA, including, but not limited to, factors such as management expenses, transaction
expenses, custodial expenses and available investment options.
Potential alternatives to a rollover may include:
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• Leaving the money in your former Employer Retirement Plan, if permitted;
• Rolling over the assets to your employer’s plan, if one is available and if rollovers are permitted;
• Rolling over Employer Retirement Plan assets into an IRA; or
• Cashing out (or distribute) the Employer Retirement Plan assets and paying the taxes due.
Item 12
Brokerage Practices
O’Brien Wealth Partners does not request or accept the discretionary authority to determine the broker
dealer to be used for client accounts. This means that we will not survey or shop the brokerage market place
for best execution on a transaction-by-transaction basis. As such, clients must direct O’Brien Wealth
Partners as to the broker dealer to be used. Generally, this direction is given via the client selection of a
particular custodian and/or their specific platform and is memorialized in the advisory agreement. In
directing the use of a particular broker or dealer, it should be understood that O’Brien Wealth Partners will
not have authority to negotiate commissions among various brokers or obtain volume discounts, and best
execution may not be achieved. In addition, a disparity in commission charges may exist between the
commissions charged to the client and those charged to other clients. Not all advisers require their clients to
direct brokerage.
For clients in need of brokerage or custodial services, and depending on client circumstances and needs, we
will recommend the use of one of several broker dealers, provided that such recommendation is consistent
with our fiduciary duty to the client. Generally, we will recommend the brokerage services offered by the
client’s custodian and/or their respective platforms. Our clients must evaluate these brokers before opening
an account. The factors considered by our firm when making this recommendation are the broker's ability to
provide professional services, our experience with the broker, the broker's reputation, and the broker's quality
of execution services and costs of such services, and the custodial platform provided to clients, among other
factors.
If a client, when undertaking an advisory relationship with our firm, already has a pre-established
relationship with a broker and instructs us to execute all transactions through that broker, it should be
understood that under those circumstances, we will not have the authority to negotiate commissions, obtain
volume discounts and best execution may not be achieved. In addition, under these circumstances a disparity
in commission charges may exist between the commissions charged to other clients since our firm may not
be able to aggregate orders to reduce transaction costs or the client may receive less favorable prices.
O’Brien Wealth Partners reserves the right to decline acceptance of any client account for which the client
directs the use of a broker if we believe that this choice would hinder its fiduciary duty to the client and/or its
ability to service the account.
O’Brien Wealth Partners primarily sets up new accounts using Charles Schwab & Co. (“Charles Schwab”), a
discount broker with an extensive mutual fund clearing service. O’Brien Wealth Partners believes that Charles
Schwab provides for efficient transfers among more than 5000 mutual funds and exchange-traded funds under
the umbrella of a single client account. On certain transactions, Charles Schwab applies a transaction charge on
the purchase and sale of mutual fund and exchange-traded fund shares. O’Brien Wealth Partners has negotiated
preferential rates with Charles Schwab for its clients. Charles Schwab provides monthly statements (quarterly if
no activity) directly to the client and duplicate confirmations and statements electronically to O’Brien Wealth
Partners. O’Brien Wealth Partners’ clients sign a Charles Schwab "Limited Power of Attorney" that authorizes
O’Brien Wealth Partners to execute transactions on a client’s behalf as well as to request fund transfers between
a client’s Charles Schwab account and their bank account registered in the same name. Finally, clients sign a
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Charles Schwab "Authorization to Pay Fees to Agent" form that allows Charles Schwab to pay the management
fees from the clients’ accounts on O’Brien Wealth Partners’ submission of a bill to both Charles Schwab and
the client. The client receives notification from Charles Schwab of any such payments to O’Brien Wealth
Partners.
Research and Other Soft Dollar Benefits
O’Brien Wealth Partners does not have any formal or informal soft-dollar arrangements with any broker
dealer. However, O’Brien Wealth Partners participates in the Schwab Advisor Services (SAS) program
offered to independent investment advisers by Schwab. As part of the SAS program, our firm receives
benefits that it would not receive if it did not recommend or use Schwab as a custodian. These benefits
include: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk
serving SAS participants exclusively; access to block trading which provides the ability to aggregate
securities transactions and then allocate the appropriate shares to client accounts; ability to have investment
advisory fees deducted directly from client account; access, for a fee, to an electronic communication
network for client order entry and account information; receipt of compliance publications; and access to
mutual funds which generally require significantly higher minimum initial investments or are generally
available only to institutional investors. The benefits received through participation in the SAS program may
or may not depend upon the amount of transactions directed to, or amount of assets custodied by, Charles
Schwab.
Participation in the SAS platform may result in a potential conflict of interest for O’Brien Wealth
Partners, as the receipt of the above benefits creates an incentive for us to recommend Charles Schwab to
clients.
While, based on our business model, we will not seek to exercise discretion to negotiate trades among various
brokers on behalf of clients, we will, however, periodically attempt to negotiate lower commission rates for our
clients with Schwab and/or Fidelity.
Brokerage for Client Referrals
O’Brien Wealth Partners does not normally select or recommend broker-dealers in order to receive client
referrals from broker-dealers or third parties; however, because O’Brien Wealth Partners is enrolled in Charles
Schwab’s advisor program, Charles Schwab may refer clients to it. O’Brien Wealth Partners notes that this
feature is not a material reason why it primarily sets up new accounts at Charles Schwab. Please see Item 14 of
this Brochure for additional information.
O’Brien Wealth Partners does occasionally aggregate the purchase or sale of ETF securities for various client
accounts. If we do have the opportunity to do so, we will allocate the trade among clients, giving each client a
proportionate share of the total trade.
Item 13
Review of Accounts
O’Brien Wealth Partners client accounts are monitored and reviewed on a regular basis by advisers to assure
that they are meeting the standards set forth in each client's Investment Policy Statement. Client inquiries,
changes in general market outlook, and changes in opinion on specific issues determined at the investment
committee level may prompt particular reviews.
Factors that trigger a review of client accounts include, but are not limited to, the following:
If a client’s financial situation changes;
If a client has questions;
O’Brien Wealth Partners, LLC Form ADV Part 2A
Date: 3/12/2025
Page: 13
If there are changes in general market outlook;
If O’Brien Wealth Partners’ opinions on specific issues determined at the Investment Committee level
require changes to a client’s account structure; and,
Any other situation that O’Brien Wealth Partners or its clients deem important to discuss.
Clients are furnished quarterly summary reports of their investment advisory portfolios.
Item 14
Client Referrals and Other Compensation
Other than the arrangements disclosed in Item 12 this Form ADV Part 2A, O’Brien Wealth Partners does not
presently have arrangements whereby a third-party provides an economic benefit to the firm in exchange for
us providing investment advice to clients.
O’Brien Wealth Partners does not presently compensate anyone for client referrals or other promotional
activities although we have had such arrangements in the past and may again in the future.
Item 15
Custody
O’Brien Wealth Partners has constructive custody of client assets as a result of its ability to debit fees from the
custodial account. We satisfy our “due inquiry” obligation that the qualified custodian(s) are sending our clients
statements at least quarterly by conducting random spot checks.
O’Brien Wealth Partners is also deemed to have constructive custody of client assets due to designation of certain
supervised persons of O’Brien Wealth Partners as trustees or co-trustees for certain client accounts. O’Brien
Wealth Partners has adopted controls as required under applicable SEC rules to ensure the safeguarding of client
assets under such circumstances.
In addition, we are also deemed to have custody as a result of our ability to transfer funds from client accounts
to third parties (a “third-party” transfer) pursuant to third party standing letters of authorization (“SLOAs”). The
SEC has published guidance regarding third-party transfers, which if properly adhered to, means that an adviser
has custody but does not need to engage a surprise custody exam. We adhere to this guidance. We maintain
procedures to prevent client assets from conversion or inappropriate use by advisory personnel. We keep a log
of all accounts which have SLOAs in our portfolio management software. In this log we confirm that we have
reviewed the third party and that he, she or it is not related to us.
O’Brien Wealth Partners also includes the following message to clients on all of their quarterly statements:
This statement is provided by O’Brien Wealth Partners LLC to supplement the statement(s) you receive from
your qualified custodian (i.e., Charles Schwab, Fidelity Investments and TIAA). We urge you to compare the
information we provide with the information reflected in your custodian’s account statement(s) for verification.
If you have any questions, please call us at (617) 547-6717.
Item 16
Investment Discretion
O’Brien Wealth Partners has discretionary authority to manage securities accounts on behalf of our clients. A
client may from time to time request that we do not sell a particular security or place any trades in a particular
account. If this occurs, O’Brien Wealth Partners categorizes the security and/or account as “Unmanaged” in our
O’Brien Wealth Partners, LLC Form ADV Part 2A
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Page: 14
portfolio accounting system. O’Brien Wealth Partners only manages accounts in which we have discretionary
trading authority.
By signing the O’Brien Wealth Partners Investment Advisory Contract, clients give O’Brien Wealth Partners
full discretion to make investment decisions with respect to clients’ portfolios advised by O’Brien Wealth
Partners. In addition, O’Brien Wealth Partners has limited power of attorney over the accounts that we manage.
When opening or moving an account to O’Brien Wealth Partners, for each account, the client is required to sign
an application with their account custodian (Charles Schwab, Fidelity, etc.) containing authorizations for trading
and disbursement and fee payment. The client authorizes their custodian to execute trades at the direction of
O’Brien Wealth Partners. The client also authorizes O’Brien Wealth Partners to inquire and receive specific
information about their account(s), such as account balance, beneficiary designations, requesting of forms, etc.
With respect to the use of third party investment advisers, our firm does not manage these client portfolios, or
this portion of these client portfolios, in the traditional sense of the definition, rather, we manage the managers.
As such, the client may grant us the authority to hire and fire the selected registered investment adviser(s)
directly. Discretionary investment authority granted to us may be delegated by us to selected third-party
managers and/or sub-advisers without prior client consent.
Item 17
Voting Client Securities
For any new clients, O’Brien Wealth Partners does not assume the responsibility to vote proxies or sign written
consents with respect to any securities owned by our clients, including securities held in client accounts over
which we have been granted discretionary authority. In addition, O’Brien Wealth Partners will not take any action
with respect to shareholder class action lawsuits related to any investment held at any time in client accounts
(“class actions”). It is the responsibility of O’Brien Wealth Partners’ clients to vote proxies for the securities held
in their accounts and to protect their interests in any class action proceeding. Generally, clients will receive proxy
voting materials directly from their custodian(s). O’Brien Wealth Partners will take reasonable steps to forward
any proxy voting or class action materials directly to our clients. While O’Brien Wealth Partners is available
discuss such proxy voting or class action materials with the client, the obligation to vote client proxies and
exercise class action rights at all time rests with the client.
For certain legacy clients, O’Brien Wealth Partners has assumed proxy voting responsibility and has a written
Proxy Voting Policy and requires clients to sign an acknowledgement of the policy. With respect to these client
accounts, records will be maintained indicating receipt of proxies and how votes were cast. Proxy voting
guidelines and voting records will be available to clients on request.
O’Brien Wealth Partners’ proxy voting policy is as follows:
Proxy Voting Procedures
Proxy voting materials will be monitored by a member of the investment committee. In conjunction with our
advisers, all proxies will be voted in a timely manner.
Proxy Voting Guidelines
A. Corporate Governance:
On the following issues, we would vote as recommended by a board if the proposal is reasonable and
not for the purpose of management entrenchment. Industry standards are to be considered; however, the
over-riding standard is that of common sense and fairness.
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Increasing or decreasing amounts of authorized stock
• Election of directors in a non-contested election
• Selection of auditors
•
• Changing terms of authorized stock
• Company name changes
• Stock splits
• Changing size of board
• Opting into or out of optional provisions of state corporation laws
• Changing annual meeting date or location
• Changing state of incorporation
B. Voting, Board Composition and Control Issues:
Proposals considered to be reasonable by industry standards that improve shareholder democracy,
reduce the likelihood of management entrenchment or conflict of interest and are likely to make
management more responsive to the concerns of shareholders.
Independent audit committees
Independent nominating committees
Independent compensation committees
Then vote For:
• Confidential voting
•
•
•
• Requiring information on proponents of shareholder resolutions
• Cumulative voting
Then vote Against:
• Greenmail
• Poison pills
• Preemptive rights
• Supermajority voting requirements
• Targeted share placements (placing blocks of securities with friendly third parties)
• Limiting shareholders’ right to act by written consent
• Limiting shareholders’ right to call meetings
C. Compensation Issues:
Proposals that relate management compensation to long-term performance are generally favored.
Then vote For:
• Stock option plans
• Restricted stock bonus plans
• Director compensation proposals
• Director stock ownership proposals
• Executive compensation proposals
Then vote Against:
• Re-pricing of “underwater” options
D. Social Issues:
All forms of discrimination are opposed.
Then vote For:
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• Equal Employment Opportunity
E. Conflicts of Interest:
Due to the nature of O’Brien Wealth Partners’ business, it is unlikely that conflicts of interest will arise
in voting the proxies of public companies because O’Brien Wealth Partners does not perform investment
banking or advise public companies. If there is a material conflict, O’Brien Wealth Partners will
document it in writing, disclose the conflict of interest to the client, give the client the option of voting
the proxy themselves and/or vote in the clients’ best interest.
Item 18
Financial Information
O’Brien Wealth Partners does not require or solicit prepayment of any dollar amount, in fees per client, six
months or more in advance.
O’Brien Wealth Partners has not been the subject of a bankruptcy petition at any time during the past ten years.
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