Peabody River Asset Management, LLC

  • Private Wealth Management
  • Endowment Management
  • Investment Consulting

Frequently Asked Questions

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ur FAQs should help you decide whether Peabody River Asset Management is the right investment manager for you. For official advice on choosing an investment adviser, see what the Securities and Exchange Commission says.

Our Definitions provide further clarification, and they should be helpful if this is the first time you have considered retaining the services of an investment adviser.

Can I afford your investment management service?

Please request a copy of our Form ADV, Part 2, which includes our fee schedule. As noted there, we do not require a minimum asset size. We do have a minimum annual fee. You must be a resident of Massachusetts or California, or a representative of an organization based in those states. Contact

Are you affiliated with another institution?

No, we are entirely independent. All we offer is disinterested investment advice. We do not receive sales commissions, and we have no financial interest in selling you any particular investment product.

Who is the source of your investment advice?

We provide our own advice, based on our knowledge of investing. That knowledge comes from more than twenty years of diverse professional analytical experience in investment management and from wide reading in the literature of finance and economics. We do not buy and resell canned investment advice from anyone else.

Do you pool accounts?

No. We manage each client's account separately in order to customize the portfolio to his or her objectives and constraints. The term that the investment management profession applies to this approach is separately managed accounts.

Do you offer financial planning without investment management?

Yes, we offer financial planning services for an hourly fee or an annual retainer.

Would you describe your investment process as “disciplined”?

Of course. Every investment manager describes his process as "disciplined."

May I try you out by giving you just a portion of my money to manage?

If by this you mean, "May I test you on, say, $100,000 to see if I'm happy with your performance?", then our answer is, "No." Our expertise lies in the structuring of portfolios to fit individual objectives, constraints, and risk tolerance, not in picking stocks to beat the S&P 500. We would, however, consider managing a distinct account, like your IRA, if we can fit this into your overall financial context. We would also be happy to structure and manage your portfolio around a portion that you have managed by someone else.

What other services do you offer?

Peabody River focuses on what we know and do best. We specialize in investment management. This takes two forms: discretionary asset management and consulting. We also offer financial planning services. We can refer you to other experts who specialize in estate planning, tax advice, and tax preparation.

Who will service my account?

Either Mr. Apt or Mr. Budding will personally service your account.

You’re a small company. What will happen to my money if something happens to you?

Nothing will happen to your money. Peabody River Asset Management does not have custody of your financial assets. Your assets will be custodied at either, as we very strongly recommend, our preferred broker and custodian, Shareholders Service Group, or another brokerage of your choice. If something happens to us, you will still have access to your assets. Customers' assets held at Shareholders Service Group are insured up to $500,000 per account by SIPC® (the Securities Investor Protection Corporation), and beyond that amount to the full net equity in each account by Customer Asset Protection Company (CAPCO), a licensed Vermont insurer. This is insurance in the event of the failure of Shareholders Service Group. It is not insurance against a decline in market value.

Why do you recommend Shareholders Service Group?

Our work is much easier if all the assets we manage are custodied in one place. This leaves us more time to devote to our clients instead of to our operations. Furthermore, Shareholders Service Group has a software platform that simplifies our work, and they are a discount brokerage, which keeps the costs of buying and selling securities low.

What can I expect at our first meeting?

In preparation for our first meeting, Peabody River will ask you to provide us with basic financial information that helps us to evaluate your net worth and cashflows. We will go over this with you and ask you about your needs and special circumstances. We will also discuss the nature of investment risk, so that we have a common understanding of what your risk tolerance is. After this meeting, Peabody River will draft an Investment Policy Statement, which is a guide for managing your portfolio. We will send it to you for review and comment. Subsequently, we will meet with you at least semi-annually and preferably quarterly to review your portfolio and to see if your situation and your needs have changed.

What is the difference between you and my broker?

We are not a stockbroker. Please refer to our section of definitions for an explanation of the different players offering services to individual investors.

What is an investment policy statement?

This is written document, agreed upon by the investment adviser and the client, that guides the investment management process. It is not designed to be a contract, and it is not required for investment management. All the same, it is a good idea to have one. It can take whatever form the client and adviser agree. It can be of almost any length. Usually, it defines the responsibilities of both, states the purpose of the investment portfolio, and provides the guidelines according to which the investment adviser manages the client's assets. It seldom states specifically what investments should or should not be included in the portfolio. Sometimes, it defines performance standards for the adviser.

Where is the Peabody River?

The Peabody River flows through Pinkham Notch in the White Mountains of New Hampshire.

Photo of Charles River, Cambridge MA


We present our definitions only as a beginning aid to clients and prospective clients. These are not quotations from the law or legal interpretations. If you require legal advice concerning investing, you should consult an attorney who specializes in securities law.

Account Executive

See Stockbroker

CFA or Chartered Financial Analyst

The CFA® or Chartered Financial Analyst® designation is awarded by the CFA Institute and is an optional credential for specialists in investment analysis and management. To qualify for it, the holder must have a minimum of four years of related experience and have passed three six-hour examinations covering nearly all aspects of investment analysis and investment management. Mr. Apt, the manager of Peabody River, holds the CFA designation.

CFP or Certified Financial Planner

The CFP® or Certified Financial Planner® designation is awarded by the Certified Financial Planner Board of Standards and is an optional credential for financial advisers or planners. To qualify for it, the holder must have a minimum of three years of related experience and have passed a ten-hour examination. Investment management is part of the study curriculum for the CFP examination, which includes many other topics as well, including various kinds of insurance, estate planning, retirement planning, and tax planning. There exist other unrelated designations for financial planners. Neither Mr. Apt, the manager of Peabody River, nor Mr. Budding holds the CFP designation.


In financial services, a commission is distinguished from a fee. It is an amount paid by the buyer (and sometimes the seller) of a security or financial product to compensate the agent who carries out the transaction. It is paid for a particular transaction, and is often but not always a percentage of the value of the transaction. For example, insurance products are usually but not always sold on commission by an insurance agent. Also, both the sale and the purchase of a stock entail the payment of a commission to the brokerage firm that executes the trades, and the commission may be a percentage of the trade or a fixed amount. Many but not all mutual funds carry loads, which are commissions. Peabody River Asset Management does not sell financial products or services to our clients for commissions.


A financial planner, stockbroker, or investment adviser who earns his living primarily through earning commissions on the sale of financial products is said to be commission-based. For the consumer or client, the choice between commission-based service and fee-based or fee-only financial advisers or planners is not clear cut and depends on individual circumstances and the advisers being considered. Peabody River Asset Management is not commission-based.

Discretionary Management

The power of an investment manager or stockbroker to trade securities for a client's portfolio without the client's knowledge or prior approval for each trade is discretionary management. A client may grant the registered investment adviser or stockbroker permission to undertake discretionary management. Registered investment managers commonly offer discretionary management. Peabody River Asset Management offers discretionary investment management.


Fees are payments for service. In financial services, a fee is distinguished from a commission. Fees can be fixed charges per unit of time (so many dollars an hour, or so many dollars per year), which are common for financial planning services other than investment management; a one-time fixed amount; or a percentage of assets under management per year. The usual fee structure for discretionary investment management and for mutual funds is a percentage of assets under management per year.


A financial planner or investment adviser who earns his living primarily through a fee for service, but also earns commissions from the sale of financial products, is said to be fee-based. For the consumer or client, the choice between commission-based service and fee-based or fee-only financial advisers is not clear cut and depends on individual circumstances and the advisers being considered. Peabody River Asset Management is not fee-based.


A financial planner or investment adviser who earns his living solely through a fee for service is said to be fee-only. For the consumer or client, the choice between commission-based service and fee-based or fee-only financial advisers is not clear cut and depends on individual circumstances and the advisers being considered. Peabody River Asset Management, in both its investment management and its financial planning services, is fee-only.

Financial Adviser or Financial Planner

Anyone may describe himself as a financial planner or adviser. These are generic terms and do not by themselves require a professional license. But most financial planners offer investment advice as more than an incidental part of their practice, which makes them legally investment advisers and therefore subject to the laws and regulations governing investment advisers. There are numerous optional credentials for financial planners, including the CFP®, ChFC®, and, for those who are Certified Public Accountants, the CPA/PFS.

Form ADV

Every registered investment adviser is required to file a Form ADV, which has two parts. Part I contains basic information, such as address and hours of business, the name of the manager, an outline of the services offered, the size of the firm, an indication of the places where the firm is registered, and a disclosure of any regulatory complaints and infractions. Part II is more informative for those who want to delve into the management process. It very broadly gives an account of the investment vehicles used, the sources of information, methods of analysis, and strategies employed, the educational and recent employment histories of those who oversee or provide the investment advice, the structure of fees and/or commissions charged to clients, and much more. Schedule F of Part II is discursive and may give deeper insight into the firm. Part I is available online through the Securities and Exchange Commission and its Investment Adviser Public Disclosure database (IAPD). Part II has always available from the investment adviser, but only starting in 2007 is being made available through the IAPD. The investment adviser is required to offer Part II to each client and prospective client. You can request Peabody River Asset Management's Form ADV Part II directly from us. Contact.

Hedge Fund

A hedge fund is, like a mutual fund, and unlike a registered investment adviser, a pool of assets, not a separate account. Although a hedge fund has a particular legal status, there is no precise definition from the investment standpoint. One thoughtful analysis published by an expert several years ago concluded that hedge funds could not usefully be defined by how they invest, because nearly every conceivable investment strategy and investment instrument or asset is used by one hedge fund or another. Still, hedge funds share several characteristics that make them different from registered investment advisers and mutual funds. They are more lightly regulated and have greater flexibility than registered investment advisers and mutual funds, although, of course, they cannot commit fraud. Unlike mutual funds, their shares are issued in private offerings, and they are not required to register with the SEC, although some, in order to provide reassurance to investors, choose to do so anyway. Those that do not must satisfy particular criteria in order to avoid having to register. Unregistered hedge funds have less stringent reporting and disclosure requirements than registered ones. Some lock up investors' money for long periods in order to give the managers greater leeway to make their investment decisions. Many hedge funds (and, for that matter, some mutual funds and many registered investment advisers) require a very large minimum investment, but registered hedge funds may have much smaller minima, for example, around $25,000. With few exceptions, they charge higher fees than registered investment advisers and than most mutual funds, and these fees usually include incentive payments to reward superior performance (but seldom any penalty for poor performance). There also exist funds of funds and funds of funds of funds, which are pools of hedge funds, and which layer their fees on top of the fees of the underlying funds. Peabody River Asset Management is not a hedge fund manager.

Investment Adviser

See Registered Investment Adviser.

Investment Consultant

Consultant is a generic term, and there is no special license required for its use. Nearly all investment consultants, however, fit the description of an investment adviser, namely, they give advice to clients about investments in return for a fee. They or their employers must therefore be registered as investment advisers.

Registered Investment Adviser or RIA

An investment adviser is a person or firm that is in the business of providing advice about investment securities to clients in return for compensation. An RIA is subject to the U.S. Investment Advisers Act of 1940. There are, however, exceptions, among them stockbrokers and banks. Individuals or firms that fit the definition of investment adviser must register with the SEC or the regulatory authorities in the individual states where they do business. (The difference depends upon the amount of assets being advised; RIAs that advise assets greater than $25 million must register with the SEC.) The federal government does not require that a registered investment adviser have any credentials. Individual states, including Massachusetts, generally require that the supervisor of advice at the investment advisery firm have passed a licensing examination but waive that requirement if the supervisor holds any of several recognized certifications, of which the CFA® is usually one. RIAs often offer discretionary management. "RIA" is not a credential and should not appear after the name of an individual. The registered investment adviser must file a Form ADV, which contains much information about the adviser and the firm's practice. Some investment advisers offer financial planning or advice, and others do not. Peabody River Asset Management is a registered investment adviser.

Registered Representative

See Stockbroker.


The United States Securities and Exchange Commission. The SEC's mission is "to protect investors, maintain fair, orderly, and efficient markets, and facilitate capital formation."


A stockbroker, more commonly called a registered representative or account executive in business parlance, is an employee of a brokerage company that is registered with the Financial Industry Regulatory Authority (FINRA, formerly the National Association of Securities Dealers). Stockbrokers give recommendations on which securities to buy and sell and are usually compensated in large measure through a percentage of the commissions they generate for their companies, which charge these commissions to execute transactions. The stockbroker must be licensed by FINRA to provide advice on securities (like stocks, bonds, and mutual funds). Stockbrokers are subject to the U.S. Securities Exchange Act of 1934 and are also subject to the laws of the states in which they conduct their business. In some instances, stockbrokers may also register as investment advisers, but they are not considered to be investment advisers if their financial advice is only incidental to their role as brokers, and they are not compensated separately for their advice. Stockbrokers may sometimes refer a client to an investment adviser to manage a portion of the portfolio. The legal distinctions between stockbrokers and investment advisers in some of the services that they offer are sometimes not clear cut and have been the subject of some contention in recent years. Peabody River Asset Management is not a brokerage company; neither Mr. Apt nor Mr. Budding is a stockbroker.