06/26/2020

Reynders, McVeigh Capital Management, LLC, which includes our division Fresh Pond Capital, is registered with the Securities and Exchange Commission (“SEC”) as an investment adviser. Brokerage and investment advisory services and fees differ. It is important for you to understand the differences. Free and simple tools to research firms and financial professionals, and educational materials about broker-dealers, investment advisers and investing are available at www.investor.gov/CRS.

We offer investment advisory services to retail investors mainly via separately managed accounts (“SMAs”).

Scope of Our Services and Investment Authority

Most clients’ SMAs are “discretionary,” meaning that we are allowed to buy and sell investments in your SMA without obtaining your consent for the specific transaction in advance, subject to any reasonable restrictions you may impose in your agreement with us.

Monitoring

As part of our standard SMA services, your SMA investments are reviewed at least quarterly. Material changes in the market or your circumstances can trigger more frequent reviews.

Investment Offerings and Limitations

Our investment philosophy is growth at a reasonable price, guided by “ESG” (Environmental, Social and Governance) principles. Our investment advice focuses primarily on equity securities (stocks) and fixed income investments (bonds). We also research and recommend “Impact Investments” (some are not traded publicly) to those clients who express interest in such types of investments. You must sign a separate agreement before buying certain Impact Investments.

Minimum Requirements

We do not require a specified minimum investment, and generally require SMAs to have sufficient assets to diversify their portfolio holdings.

• We occasionally make available, as an accommodation to a small number of retail clients, and subject to additional internal approval, SMAs which are “non-discretionary,” meaning that we recommend specific transactions for your SMA, subject to any reasonable restrictions you may impose in your agreement with us, but the ultimate investment decisions for the purchase or sale of securities in the SMA will be yours.
• In addition, we offer financial planning and retirement planning, on a non-discretionary basis only. We do not monitor investments with respect to which we provide such planning services only (i.e., investments that are held outside of your SMA), and do not impose any minimum requirements to obtain a plan.

Please refer to Items 4 and 7 in our Form ADV Part 2A (“Brochure”) for more information.

We charge SMAs an “SMA Management Fee,” quarterly and in advance, unless other arrangements are agreed upon. The fee is negotiable depending on the scope of our services and other factors, and is outlined in your agreement with us.

• The standard SMA Management Fee is an asset-based fee, at an annual rate of 1% of the first $3 million and 0.75% of assets in excess of $3 million.
• Flat fee arrangements apply in some legacy relationships.
• We have an incentive to encourage adding assets to your SMA, which would increase our asset-based fee.
• We do not currently charge separate fees for financial planning or retirement planning services.

You will also pay other fees and expenses, including fees charged by brokerage firms for purchasing or selling investments, exchange fees on the sale of investments, and any fees paid to the custodian you choose to hold your assets.

• If you hold shares of any mutual fund, exchange traded fund, or private equity fund in your SMA, you pay the SMA’s share of that fund’s internal fees and expenses.
• We manage a mutual fund (“our Fund”), which we often recommend as an SMA investment for accounts not large enough to hold a diversified portfolio. Our Fund’s annual rate for internal fees and expenses is set forth in its prospectus, available at https://www.reyndersmcveighfunds.com. We do not charge the asset-based SMA Management Fee on assets invested in our Fund.

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investments over time. Please make sure you understand what fees and costs you are paying.

Most of our financial professionals are paid a salary, plus discretionary bonuses based on the firm’s profitability and the individual’s overall employee performance rating. Those financial professionals who introduce clients to the firm are paid a direct percentage of the fees we receive from those clients.

• Both arrangements incentivize our financial professionals to maximize the revenue they generate for us.

No. Free and simple tools are available to research us and our financial professionals at www.investor.gov/CRS.

Please visit reyndersmcveigh.com or call (617) 226-9999 for more information about our firm and our services, or to request a printed copy of our Client Relationship Summary. Our Form ADV Part 1A and Brochure are also available on the Investment Adviser Public Disclosure website at https://www.adviserinfo.sec.gov/IAPD/default.aspx.