ABTW LLC d/b/a AssetAlign

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Form ADV Part 2A – Disclosure Brochure

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Effective: March 4, 2024

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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.

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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.

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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.

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ABTW LLC

50 Broadway, Stoneham, MA, 02180

Phone: 617-279-6190

www.assetalign.net

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Item 2 – Material Changes

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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 Page1

Item 2 – Material Changes2

Item 3 – Table of Contents3

Item 4 – Advisory Services4

A. Firm Information4

B. Advisory Services Offered4

C. Client Account Management4

D. Wrap Fee Programs4

E. Assets Under Management4

Item 5 – Fees and Compensation4

Item 6 – Performance-Based Fees and Side-By-Side Management4

Item 7 – Types of Clients4

Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss5

A. Methods of Analysis5

Item 9 – Disciplinary Information5

Item 10 – Other Financial Industry Activities and Affiliations5

Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading5

A. Code of Ethics5

Item 12 – Brokerage Practices5

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.5

Item 13 – Review of Accounts5

Item 14 – Client Referrals and Other Compensation6

A. Compensation Received by AssetAlign6

B. Compensation for Client Referrals6

Item 15 – Custody6

Item 16 – Investment Discretion6

Item 17 – Voting Client Securities6

Item 18 – Financial Information6

Item 19 – Requirements for State Registered Advisors6

A. Educational Background and Business Experience of Principal Officer6

B. Other Business Activities of Principal Officer6

C. Performance Fee Calculations6

D. Disciplinary Information6

E. Material Relationships with Issuers of Securities7

Form ADV Part 2B – Brochure Supplement8

Privacy Policy11

 

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 other business endeavors. AssetAlign does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts.

Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

A. Code of Ethics

AssetAlign has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with AssetAlign (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. AssetAlign and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of AssetAlign ’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at 617-279-6190 or via email at john@assetalign.net.

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 any Client assets, and therefore does not conduct reviews on Client accounts. AssetAlign recommends Third-Party RIAs for investment advisory services. The Third-Party RIA will be responsible for all account and performance reviews. Please see the Third-Party RIA’s respective Form ADV Part 2A – Disclosure Brochure for additional details regarding review of accounts.

Item 14 – Client Referrals and Other Compensation

A. Compensation Received by AssetAlign

As noted in Item 4, AssetAlign recommends that Clients utilize the investment advisory services of Third-Party RIA. AssetAlign will receive referral compensation from the Third-Party RIA for which the Client engages for investment advisory services.

B. Compensation for Client Referrals

Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party and receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the respective party a fee in accordance with the applicable state securities requirements. Any such compensation shall be paid solely from the fees earned by the Advisor, and shall not result in any additional charge to the Client.

Item 15 – Custody

AssetAlign does not accept or maintain custody of any Client assets.

Item 16 – Investment Discretion

AssetAlign does not have investment discretion over Client assets.

Item 17 – Voting Client Securities

AssetAlign does not accept proxy-voting responsibility for any Client or Third-Party RIA.

Item 18 – Financial Information

Neither AssetAlign, nor its management, have any adverse financial situations that would reasonably impair the ability of AssetAlign to meet all obligations to its Clients and Third-Party RIA. Neither AssetAlign, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. AssetAlign is not required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect advance fees of $500 or more for services to be performed six months or more in the future.

Item 19 – Requirements for State Registered Advisors

A. Educational Background and Business Experience of Principal Officer

The Principal Officer of AssetAlign is Mr. John Gavin. Information regarding the formal education and background of Mr. Gavin is included the Form ADV 2B – Brochure Supplement below.

B. Other Business Activities of Principal Officer

The sole business of AssetAlign and Mr. Gavin is to provide services to its Clients. Neither AssetAlign nor Mr. Gavin are involved in other business endeavors. AssetAlign does not maintain any affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts.

C. Performance Fee Calculations

AssetAlign does not charge performance-based fees. The fees charged by AssetAlign are as described in Item 5 – Fees and Compensation and Item 14 – Client Referrals and Other Compensation above and are not based upon the capital appreciation of the funds or securities held by any Client.

D. Disciplinary Information

There are no legal, civil or disciplinary events to disclose regarding AssetAlign or Mr. Gavin. Neither AssetAlign nor Mr. Gavin have ever been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims or administrative proceedings against 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

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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.

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Employment History:

President and Chief Compliance Officer, ABTW LLC

03/2024 to Present

Managing Regional Director, Natixis Advisors, LLC

11/2010 to 07/2023

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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.

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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.