Disclosure Brochure
Last Updated on March 6, 2023
Beaulieu & Associates, LLC
This brochure provides information about the qualifications and business practices of Beaulieu & Associates, LLC. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at: (860)749-4138. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority.

Additional information about Beaulieu & Associates, LLC (CRD #168829) is available on the SEC’s website at www.adviserinfo.sec.gov

Office Address:

48 South Road, Unit 15
Somers, CT 06071

Tel: 860-749-4138
Fax: 860-749-4167

Email:jim@jimbeaulieu.com

Item 2: Material Changes

Annual Update
The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure.
Material Changes since the Last Update
This update is in accordance with the required annual update for Registered Investment Advisors. Since the last update on February 23, 2022, the following changes have occurred:
• Item 4 has been updated to disclose the assets under management for the firm as of year-end.
Full Brochure Available
Whenever you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at (860)749-4138 or by email at jim@jimbeaulieu.com.

Item 3: Table of Contents

FORM ADV – PART 2A – FIRM BROCHURE
ITEM 1: COVER PAGE
ITEM 2: MATERIAL CHANGES
           ANNUAL UPDATE
           MATERIAL CHANGES SINCE THE LAST UPDATE
           FULL BROCHURE AVAILABLE
ITEM 3: TABLE OF CONTENTS
ITEM 4: ADVISORY BUSINESS
           FIRM DESCRIPTION
           TYPES OF ADVISORY SERVICES
           CLIENT TAILORED SERVICES AND CLIENT IMPOSED RESTRICTIONS
           WRAP FEE PROGRAMS
           CLIENT ASSETS UNDER MANAGEMENT
ITEM 5: FEES AND COMPENSATION
           METHOD OF COMPENSATION AND FEE SCHEDULE
           CLIENT PAYMENT OF FEES
           ADDITIONAL CLIENT FEES CHARGED
           PREPAYMENT OF CLIENT FEES
           EXTERNAL COMPENSATION FOR THE SALE OF SECURITIES TO CLIENTS
ITEM 6: PERFORMANCE-BASED FEED AND SIDE-BY-SIDE MANAGEMENT
           SHARING OF CAPITAL GAINS
ITEM 7: TYPES OF CLIENTS
           DESCRIPTION
           ACCOUNT MINIMUMS
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AMD RISK OF LOSS
           METHODS OF ANALYSIS
           INVESTMENT STRATEGY
           SECURITY SPECIFIC MATERIAL RISKS
ITEM 9: DISCIPLINARY INFORMATION
           CRIMINAL OR CIVIL ACTIONS
           ADMINISTRATIVE ENFORCEMENT PROCEEDINGS
           SELF-REGULATORY ORGANIZATION ENFORCEMENT PROCEEDINGS
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
           BROKER-DEALER OR REPRESENTATIVE REGISTRATION
           FUTURES OR COMMODITY REGISTRATION
           MATERIAL RELATIONSHIPS MAINTAINED BY THIS ADVISORY BUSINESS AND CONFLICTS OF INTEREST
           RECOMMENDATIONS OR SELECTIONS OF OTHER INVESTMENT ADVISORS AND CONFLICTS OF INTEREST
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING
           CODE OF ETHICS DESCRIPTION
           INVESTMENT RECOMMENDATIONS INVOLVING A MATERIAL FINANCIAL INTEREST AND CONFLICT OF INTEREST
           ADVISORY FIRM PURCHASE OF SAME SECURITIES RECOMMENDED TO CLIENTS AND CONFLICTS OF INTEREST
           WRAP FEE PROGRAMS
           CLIENT SECURITIES RECOMMENDATIONS OR TRADES AND CONCURRENT ADVISORY FIR, SECURITIES TRANSACTIONS AND     
           CONFLICTS OF INTEREST
ITEM 12: BROKERAGE PRACTICES
           FACTORS USED TO SELECT BROKER-DEALERS FOR CLIENT TRANSACTIONS
           AGGREGATING SECURITIES TRANSACTIONS FOR CLIENT ACCOUNTS
ITEM 13: REVIEW OF ACCOUNTS
           SCHEDULE FOR PERIODIC REVIEW OF CLIENT ACCOUNTS OR FINANCIAL PLANS AND ADVISORY PERSONS INVOLVED
           REVIEW OF CLIENT ACCOUNTS ON NON-PERIODIC BASIS
           CONTENT OF CLIENT PROVIDED REPORTS AND FREQUENCY
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
           ECONOMIC BENEFITS PROVIDED TO THE ADVISORY FIRM FROM EXTERNAL SOURCES AND CONFLICTS OF INTEREST
           ADVISORY FIRM PAYMENTS FOR CLIENT REFERRALS
ITEM 15: CUSTODY
           ACCOUNT STATEMENTS
ITEM 16: INVESTMENT DISCTRETION
           DISCRETIONARY AUTHORITY FOR TRADING
ITEM 17: VOTING CLIENT SECURITIES
           PROXY VOTES
ITEM 18: FINANCIAL INFORMATION
           BALANCE SHEET
           FINANCIAL CONDITIONS REASONABLY LIKELY TO IMPAIR ADVISORY FIRM'S ABILITY TO MEET COMMITMENTS TO CLIENTS
           BANKRUPTCY PETITIONS DURING THE PAST TEN YEARS
ITEM 19: REQUIREMENTS FOR STATE REGISTERED ADVISORS
           PRINCIPAL EXECUTIVE OFFICERS AND MANAGEMENT PERSONS
           OUTSIDE BUSINESS ACTIVITIES
           PERFORMANCE BASED FEE DESCRIPTION
           DISCLOSURE OF MATERIAL FACTS RELATED TO ARBITRATION OR DISCIPLINARY ACTIONS INVOLVING MANAGEMENT 
           PERSONS
           MATERIAL RELATIONSHIP MAINTAINED BY THIS ADVISORY BUSINESS OR MANAGEMENT PERSONS WITH ISSUERS OF 
           SECURITIES    
           MATERIAL CONFLICTS OF INTEREST ASSURANCE
BROCHURE SUPPLEMENT (PART 2B OF FORM ADV)
           PRINCIPAL EXECUTIVE OFFICER
           JAMES BEAULIEU
           ITEM 2 EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
           ITEM 3 DISCIPLINARY INFORMATION
           ITEM 4 OTHER BUSINESS ACTIVITIES
           ITEM 5 PERFORMANCE BASED FEE DESCRIPTION    
           ITEM 6 SUPERVISION
           ITEM 7 REQUIREMENTS FOR STATE-REGISTERED ADVISORS

Item 4: Advisory Business

Firm Description
Beaulieu & Associates, LLC (“B&A”) was founded in 2000. James Beaulieu is 100% owner.

B&A is a fee based investment management and financial planning firm. B&A does not act as a custodian of client assets. The client always maintains asset control. B&A also sells annuities and insurance products for separate yet typical commission or fees. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, tax planning, insurance review, investment management, education funding, retirement planning, and estate planning needs.

An evaluation of each client's initial situation is provided to the client, often in the form of a net worth statement, risk analysis or similar document. Periodic reviews are also communicated to provide reminders of the specific courses of action that need to be taken. More frequent reviews occur but are not necessarily communicated to the client unless immediate changes are recommended.

Other professionals (e.g., lawyers, accountants, insurance agents, etc.) are engaged directly by the client on an as-needed basis.
Types of Advisory Services

ASSET MANAGEMENT
B&A offers discretionary direct asset management services to advisory clients. B&A will offer clients ongoing portfolio management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring, and the overall investment program will be based on the above factors. The client will authorize B&A discretionary authority to execute selected investment program transactions without consent prior to each transaction as stated within the Investment Advisory Agreement.
Wrap Fee Programs
B&A does not sponsor a wrap program.
Client Assets under Management
As of December 31, 2022, B&A had approximately $56,000,000 in discretionary assets under management.

Item 5: Fees and Compensation

Method of Compensation and Fee Schedule

ASSET MANAGEMENT
B&A offers discretionary direct asset management services to advisory clients. B&A charges an annual investment advisory fee based on the total assets under management and on a flat fee basis. Both outlined as follows below:
Assets Under Management
Annual Fee
Quarterly Fee
Up to $2,000,000
$2,000,001 to $5,000,000
$5,000,001 to $10,000,000
Over $10,000,000
2.00%
1.70%
0.80%
0.40%
.500%
.425%
.200%
.100%
Tier 1: $12,000 Flat Fee Program (Account Minimum $400,000)
• Asset management and/or Asset Management Oversight
• Financial planning/Goal planning
  • Financial Planning
  • ​Tax Planning
  • ​Money Management
  • ​Legacy/Estate Planning
  • ​Life Insurance Planning
  • ​Long Term Care Insurance Planning
Tier 2: $24,000 Flat Fee Program (Account Minimum $800,000)
• Asset management and/or asset management oversight
• Financial planning/Goal planning
  • Financial Planning
  • ​Tax Planning
  • ​Money Management
  • ​Legacy/Estate Planning
  • ​General Insurance Planning
  • ​Disability Insurance Planning
  • ​Health Insurance Planning
  • ​Life Insurance Planning
  • ​Long Term Care Insurance Planning
• Coordination with your existing relationships
Tier 3: $36,000 The Personal CEO Experience (Account Minimum $1,200,000)
• Asset Management and or Asset management oversight
• Financial planning/Goal planning
• Coordination, oversight, and accountability of your Financial subject matter experts

The annual Fee may be negotiable. Accounts within the same household may be combined for a reduced fee. Fees are billed quarterly in advance based on the amount of assets managed as of the last business day of the previous quarter. Initial fees for partial quarters are pro-rated. Quarterly advisory fees deducted from the clients' account by the custodian will be reflected in a provided fee invoice as fees are withdrawn. Lower fees for comparable services may be available from other sources. Clients will have a period of five (5) business days from the date of signing an advisory agreement to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, either party may terminate the advisory agreement with written notice to the other party. For accounts closed mid-quarter, the client will be entitled to a pro rata refund for the days service was not provided in the final quarter. Client shall be given thirty (30) days prior written notice of any increase in fees, and client will acknowledge, in writing, any agreement of increase in said fees.
Client Payment of Fees
Investment management fees are billed quarterly in advance, meaning we bill you at the beginning of the quarter. If an account is opened after the start of the calendar quarter, a prorated fee will be billed. Fees are usually deducted from a designated client account to facilitate billing. The client must consent in advance to direct debiting of their investment account.
Additional Client Fees Charged
Custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include Mutual Fund transactions fees, postage and handling and miscellaneous fees (fee levied to recover costs associated with fees assessed by self-regulatory organizations).These transaction charges are usually small and incidental to the purchase or sale of a security. The selection of the security is more important than the nominal fee that the custodian charges to buy or sell the security.

B&A, in its sole discretion, may waive its minimum fee and/or charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.).

For more details on the brokerage practices, see Item 12 of this brochure.
Prepayment of Client Fees
B&A does not require any prepayment of fees of more than $500 per Client and six months or more in advance.

Investment management fees are billed quarterly in advance. If the client cancels after five (5) days, any unearned fees will be refunded to the client.
External Compensation for the Sale of Securities to Clients
Mr. Beaulieu receives external compensation for the sale of securities to clients as a registered representative of Purshe Kaplan Sterling Investments, a broker-dealer. Approximately 10% of his time is spent in this practice and less than 15% of his total revenue is generated as a registered representative. He will offer clients products from this activity.

This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. As a registered representative, Mr. Beaulieu does not charge advisory fees for the services offered through Purshe Kaplan Sterling Investments. This conflict is mitigated by disclosures, procedures, and the firm’s fiduciary obligation to place the best interest of the Client first and Clients are not required to purchase any products or services. Clients have the option to purchase these products through another registered representative of their choosing.

Item 6: Performance-Based Fees and Side-by-Side Management

Sharing of Capital Gains
Fees are not based on a share of the capital gains or capital appreciation of managed securities.

B&A does not use a performance-based fee structure because of the conflict of interest. Performance based compensation may create an incentive for the advisor to recommend an investment that may carry a higher degree of risk to the client.

Item 7: Types of Clients

Description
B&A generally provides investment advice to individuals, high net worth individuals, and businesses. Client relationships vary in scope and length of service.
Account Minimums
B&A requires a minimum of $400,000 to open an account. Accounts are subject to a $12,000 fee per year.

Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss

Methods of Analysis
Security analysis methods may include fundamental analysis, technical analysis, charting, and cyclical analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns.

Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value.

Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time.

Charting analysis strategy involves using and comparing various charts to predict long and short-term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case.

Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are twofold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit.

The main sources of information include financial newspapers and magazines, annual reports, prospectuses, and filings with the Securities and Exchange Commission.
Investment Strategy
The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Each client executes an Investment Policy Statement or Risk Tolerance that documents their objectives and their desired investment strategy.

Other strategies may include long-term purchases, short-term purchases, trading, and option writing (including covered options, uncovered options or spreading strategies).
Security Specific Material Risks
Investing in securities involves risk of loss that clients should be prepared to bear. Risk refers to the possibility that you will lose money (both principal and any earnings) or fail to make money on an investment. B&A cannot guarantee that it will achieve a client’s investment objective. Investors face the following investment risks and should discuss these risks with B&A:
  • Market Risk: The prices of securities held by mutual funds in which clients invest may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value.
  • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.
  • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation.
  • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.
  • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.
  • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.
  • Management Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the client’s portfolio may suffer.
  • Equity Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small- and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product 6 lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies.
  • Fixed Income Risk: The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate.
  • Investment Companies Risk: When a client invests in open end mutual funds or ETFs, the client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. B&A has no control over the risks taken by the underlying funds in which client invests.
  • Foreign Securities Risk: Funds in which clients invest may invest in foreign securities. Foreign securities are subject to additional risks not typically associated with investments in domestic securities. These risks may include, among others, currency risk, country risks (political, diplomatic, regional conflicts, terrorism, war, social and economic instability, currency devaluations and policies that have the effect of limiting or restricting foreign investment or the movement of assets), different trading practices, less government supervision, less publicly available information, limited trading markets and greater volatility. To the extent that underlying funds invest in issuers located in emerging markets, the risk may be heightened by political changes, changes in taxation, or currency controls that could adversely affect the values of these investments. Emerging markets have been more volatile than the markets of developed countries with more mature economies.
  • Long-term purchases: Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically, the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value.
  • Short-term purchases: Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles 7 may be subject to purchasing power risk — the risk that your investment’s return will not keep up with inflation.
  • Trading risk: Investing involves risk, including possible loss of principal. There is no assurance that the investment objective of any fund or investment will be achieved.
  • Options Trading: The risks involved with trading options are that they are very time sensitive investments. An options contract is generally a few months. The buyer of an option could lose his or her entire investment even with a correct prediction about the direction and magnitude of a particular price change if the price change does not occur in the relevant time period (i.e., before the option expires). Additionally, options are less tangible than some other investments. An option is a “book-entry” only investment without a paper certificate of ownership.

Item 9: Disciplinary Information

Criminal or Civil Actions
B&A and its management have not been involved in any criminal or civil action required to be reported.
Administrative Enforcement Proceedings
B&A and its management have not been involved in administrative enforcement proceedings required to be reported.
Self-Regulatory Organization Enforcement Proceedings
B&A and its management have not been involved in legal or disciplinary events related to past or present investment clients required to be reported.

Item 10: Other Financial Industry Activities and Affiliations

Broker-Dealer or Representative Registration
B&A is not registered as a broker-dealer; however, Managing Member James Beaulieu is a registered representative of Purshe Kaplan Sterling Investments, a FINRA/SIPC broker-dealer.
Futures or Commodity Registration
Neither B&A nor its employees are registered or has an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading advisor.
Material Relationships Maintained by this Advisory Business and Conflicts of Interest
James Beaulieu is an independent insurance agent that operates under Beaulieu & Associates, LLC. Less than 10% of the affiliate’s time is spent on insurance practices. Clients of Beaulieu & Associates, LLC may be offered insurance products. As an insurance agent, affiliates may receive separate yet typical compensation in the form of commissions for the sale of insurance products.

These practices represent conflicts of interest because it gives the affiliates an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of the clients first and clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent of their choosing.
Recommendations or Selections of Other Investment Advisors and Conflicts of Interest
B&A does not solicit the services of Third-Party Money Managers to manage client accounts.

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

Code of Ethics Description
The employees of B&A have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of B&A employees and addresses conflicts that may arise. The Code defines acceptable behavior for employees of B&A. The Code reflects B&A and its supervised persons’ responsibility to act in the best interest of their client.

One area the Code addresses is when employees buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our clients. We do not allow any employees to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our clients.

B&A’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of B&A may recommend any transaction in a security or its derivative to advisory clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security.

B&A’s Code is based on the guiding principle that the interests of the client are our top priority. B&A’s officers, directors, advisors, and other employees have a fiduciary duty to our clients and must diligently perform that duty to maintain the complete trust and confidence of our clients. When a conflict arises, it is our obligation to put the client’s interests over the interests of either employees or the company.

The Code applies to “access” persons. “Access” persons are employees who have access to non-public information regarding any clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to clients, or who have access to such recommendations that are non-public.

The firm will provide a copy of the Code of Ethics to any client or prospective client upon request.
Investment Recommendations Involving a Material Financial Interest and Conflict of Interest
B&A and its employees do not recommend to clients securities in which we have a material financial interest.
Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest
B&A and its employees may buy or sell securities that are also held by clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide B&A with copies of their brokerage statements.

The Chief Compliance Officer of B&A is James Beaulieu. He reviews all employee trades each quarter. The personal trading reviews helps mitigate that the personal trading of employees does not affect the markets and that clients of the firm have received preferential treatment over employee trades.
Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities Transactions and Conflicts of Interest
B&A does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, employees may buy or sell securities at the same time they buy or sell securities for clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide B&A with copies of their brokerage statements.

The Chief Compliance Officer of B&A is James Beaulieu. He reviews all employee trades each quarter. The personal trading reviews ensure that the personal trading of employees does not affect the markets and that clients of the firm receive preferential treatment over employee transactions.

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

Factors Used to Select Broker-Dealers for Client Transactions
B&A may recommend the use of a particular broker-dealer such as TD Ameritrade Institutional, a Division of TD Ameritrade, Inc., Member FINRA/SIPC or may utilize a broker-dealer of the client's choosing. B&A will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. B&A relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the advisory fee charged by B&A .

B&A participates in the Institutional advisor program offered by TD Ameritrade Institutional. TD Ameritrade Institutional is a division of TD Ameritrade Inc., member FINRA/SIPC (TD Ameritrade) an unaffiliated SEC-registered broker-dealer and FINRA member. TD Ameritrade offers to independent investment advisors services that include custody of securities, trade execution, clearance and settlement of transactions. B&A receives some benefits from TD Ameritrade through its participation in the Program. (Please see the disclosure under Item 14)
  • Directed Brokerage 

In circumstances where a client directs B&A to use a certain broker-dealer, B&A still has a fiduciary duty to its clients. The following may apply with Directed Brokerage: B&A 's inability to negotiate commissions, to obtain volume discounts, there may be a disparity in commission charges among clients, and conflicts of interest arising from brokerage firm referrals. 

  • Best Execution 

Investment advisors who manage or supervise client portfolios on a discretionary basis have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the 10 transaction is effected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. 

  • Soft Dollar Arrangements 

The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by B&A from or through a broker-dealer in exchange for directing client transactions to the broker-dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, B&A receives economic benefits as a result of commissions generated from securities transactions by the broker-dealer from the accounts of B&A. These benefits include both proprietary research from the broker and other research written by third parties. 

A conflict of interest exists when B&A receives soft dollars. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to act in the best interest of its clients and the services received are beneficial to all clients.

Aggregating Securities Transactions for Client Accounts
B&A may aggregate purchases and sales and other transactions made for the account with purchases and sales and transactions in the same securities for other Clients of B&A. All clients participating in the aggregated order shall receive an average share price with all other transaction costs shared on a pro-rated basis.

Item 13: Review of Accounts

Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved
Account reviews are performed quarterly by James Beaulieu, Chief Compliance Officer. Account reviews are performed more frequently when market conditions dictate. Advisor does not provide written statements to client. Financial Plans are considered complete when recommendations are delivered to the client and a review is done only upon request of client.
Review of Client Accounts on Non-Periodic Basis
Other conditions that may trigger a review of clients’ accounts are changes in the tax laws, new investment information, and changes in a client's own situation.
Content of Client Provided Reports and Frequency
Clients receive written account statements no less than quarterly for managed accounts. Account statements are issued by B&A’s custodian. Client receives confirmations of each transaction in account from Custodian and an additional statement during any month in which a transaction occurs.

Item 14: Client Referrals and Other Compensation

Economic benefits provided to the Advisory Firm from External Sources and Conflicts of Interest
As disclosed under Item 12 above, B&A participates in TD Ameritrade’s Institutional advisor program and B&A may recommend TD Ameritrade to Clients for custody and brokerage services. There is no direct link between B&A’s participation in the program and the investment advice it gives to its Clients, although B&A receives economic benefits through its participation in the program that are typically not available to TD Ameritrade retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate Client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving B&A participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from Client accounts; access to an electronic communications network for Client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to B&A by third party vendors.

TD Ameritrade may also have paid for business consulting and professional services received by B&A’s related persons. Some of the products and services made available by TD Ameritrade through the program may benefit B&A but may not benefit its Client accounts. These products or services may assist B&A in managing and administering Client accounts, including accounts not maintained at TD Ameritrade. Other services made available by TD Ameritrade are intended to help B&A manage and further develop its business enterprise. The benefits received by B&A or its personnel through participation in the program do not depend on the amount of brokerage transactions directed to TD Ameritrade. As part of its fiduciary duties to clients, B&A endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by B&A or its related persons in and of itself creates a conflict of interest and may indirectly influence the B&A’s choice of TD Ameritrade for custody and brokerage services.

B&A may receive succession planning, practice valuation, and equity management services from third-party vendors through B&A’s participation in the TD Ameritrade Institutional Equity Management Program. In addition to meeting the minimum eligibility criteria for participation in the TD Ameritrade Institutional Equity Management Program, B&A may have been selected to participate in the TD Ameritrade Institutional Equity Management Program based on the amount and potential profitability to TD Ameritrade of the assets in, and trades placed for, client accounts maintained with TD Ameritrade. TD Ameritrade is a discount broker-dealer independent of and unaffiliated with B&A and there is no employee or agency relationship between TD Ameritrade and B&A. TD Ameritrade has established the TD Ameritrade Institutional Equity Management Program as a means of assisting independent unaffiliated Advisors to grow and maintain their respective investment advisory business. TD Ameritrade does not supervise B&A and has no responsibility for B&A’s management of client portfolios or B&A’s other advice or services to clients.

B&A’s participation in the TD Ameritrade Institutional Equity Management Program raises potential conflicts of interest. B&A may encourage their clients to custody their assets at TD Ameritrade and whose client accounts are profitable to TD Ameritrade. Consequently, in order to participate in the TD Ameritrade Institutional Equity Management Program, B&A may have an incentive to recommend to clients that the assets under management by B&A be held in custody with TD Ameritrade and to place transactions for client accounts with TD Ameritrade. B&A’s participation in the TD Ameritrade Institutional Equity Management Program does not relieve B&A of the duty to seek best execution of trades for client accounts.

Additionally, B&A may receive succession planning, practice valuation, and equity management services from third-party vendors through B&A’s participation in the TD Ameritrade Institutional Equity Management Program. In addition to meeting the minimum eligibility criteria for participation in the TD Ameritrade Institutional Equity Management Program, B&A may have been selected to participate in the TD Ameritrade Institutional Equity Management Program based on the amount and potential profitability to TD Ameritrade of the assets in, and trades placed for, client accounts maintained with TD Ameritrade. TD Ameritrade is a discount broker-dealer independent of and unaffiliated with B&A and there is no employee or agency relationship between TD Ameritrade and B&A. TD Ameritrade has established the TD Ameritrade Institutional Equity Management Program as a means of assisting independent unaffiliated Advisors to grow and maintain their respective investment advisory business. TD Ameritrade does not supervise B&A and has no responsibility for B&A’s management of client portfolios or B&A’s other advice or services to clients.

B&A’s participation in the TD Ameritrade Institutional Equity Management Program raises potential conflicts of interest. B&A may encourage their clients to custody their assets at TD Ameritrade and whose client accounts are profitable to TD Ameritrade. Consequently, in order to participate in the TD Ameritrade Institutional Equity Management Program, B&A may have an incentive to recommend to clients that the assets under management by B&A be held in custody with TD Ameritrade and to place transactions for client accounts with TD Ameritrade. B&A’s participation in the TD Ameritrade Institutional Equity Management Program does not relieve B&A of the duty to seek best execution of trades for client accounts.
Advisory Firm Payments for Client Referrals
B&A does not compensate for client referrals nor does it receive compensation for referrals.

Item 15: Custody

Account Statements
All assets are held at qualified custodians, which means the custodians provide account statements directly to clients at their address of record or make available electronically at least quarterly. Clients are urged to compare the account statements received directly from their custodians to the performance report information made available to clients by B&A’s portfolio software

B&A is deemed to have constructive custody solely because advisory fees are directly deducted from client’s account by the custodian on behalf of B&A. B&A will adhere to the following safeguards:
  • Provide the client an invoice electronically (or physically if requested) stating the amount of the fee prior to being deducted;
  • Obtain written authorization signed by the client allowing such fees to be deducted; and 
  • The client will receive or be made available electronically quarterly statements directly from the custodian which disclose the fees deducted.

Item 16: Investment Discretion

Discretionary Authority for Trading
B&A requires discretionary authority to manage securities accounts on behalf of clients. B&A has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold.

B&A allows Client’s to place certain restrictions, as outlined in the Client’s Investment Policy Statement or similar document. Such restrictions could include only allowing purchases of socially conscious investments.

The client approves the custodian to be used and the commission rates paid to the custodian. B&A does not receive any portion of the transaction fees or commissions paid by the client to the custodian on certain trades.

Item 17: Voting Client Securities

Proxy Votes
B&A does not vote proxies on securities. Clients are expected to vote their own proxies. The client will receive their proxies directly from the custodian of their account or from a transfer agent.

When assistance on voting proxies is requested, B&A will provide recommendations to the client. If a conflict of interest exists, it will be disclosed to the client.

Item 18: Financial Information

Balance Sheet
A balance sheet is not required to be provided because B&A does not serve as a custodian for client funds or securities and B&A does not require prepayment of fees of more than $500 per client and six months or more in advance.
Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients
B&A has no condition that is reasonably likely to impair our ability to meet contractual commitments to our clients.
Bankruptcy Petitions during the Past Ten Years
No bankruptcy petitions to report.

Item 19: Requirements for State Registered Advisors

Principal Executive Officers and Management Persons
The education and business background for all management and supervised persons can be found in the Part 2B of this Brochure.
Outside Business Activities
The outside business activities for all management and supervised persons can be found in the Part 2B of this Brochure.
Performance Based Fee Description
B&A does not receive any performance-based fees.
Disclosure of Material Facts Related to Arbitration or Disciplinary Actions Involving Management Persons
No management persons of B&A have any disclosures to report.
Material Relationship Maintained by this Advisory Business or Management persons with Issuers of Securities
There are no material relationships with issuers of securities to disclose.
Material Conflicts of Interest Assurance
All material conflicts of interest regarding the B&A, its representatives or any of its employees which could be reasonably expected to impair the rendering the rendering of unbiased and objective advice are disclosed.


Supervised Person Brochure
Form ADV Part 2B
Last Updated on March 6, 2023
Beaulieu & Associates, LLC
This brochure supplement provides information about James Beaulieu and supplements the Beaulieu & Associates, LLC’s brochure. You should have received a copy of that brochure. Please contact James Beaulieu if you did not receive the brochure or if you have any questions about the contents of this supplement.
Additional information about James Beaulieu (CRD #1914268) is available on the SEC’s website at www.adviserinfo.sec.gov.
Office Address:
48 South Road, Unit 15
Somers, CT 06071

Tel: 860-749-4138
Fax: 860-749-4167
Email:jim@jimbeaulieu.com

Brochure Supplement (Part 2B of Form ADV)
Supervised Person Brochure

Principal Executive Officer - James Beaulieu
• Year of birth: 1966
Item 2 Educational Background and Business Experience
Educational Background:
• University of Connecticut; Bachelor of Science; Real Estate and Urban Economics; 1988
Business Experience:
• Beaulieu & Associates, LLC; Managing Member/Investment Advisor Representative; 08/2013 – Present
• Beaulieu & Associates, LLC; Managing Member/Insurance Agent; 09/2000 – Present
• Purshe Kaplan Sterling Investments; Registered Representative; 09/2013 – Present
• Southfield Corners Condominium Association; Member of Board of Directors; 05/2013 – Present
• GLJ Enterprises, LLC; President; 12/2012 – Present
• M-1 Properties; Partner; 09/2006 – Present
• LPL Financial; Registered Representative; 08/1997 – 09/2013
• LPL Financial; Investment Advisor Representative; 10/1997 – 09/2013
Item 3 Disciplinary Information
Criminal or Civil Action: None to report.
Administrative Proceeding: None to report.
Self-Regulatory Proceeding: None to report.
Item 4 Other Business Activities
Mr. Beaulieu is an independent insurance agent that operates under Beaulieu & Associates, LLC. Less than 10% of the affiliate’s time is spent on insurance practices. Clients of Beaulieu & Associates, LLC may be offered insurance products. As an insurance agent, affiliates may receive separate yet typical compensation in the form of commissions for the sale of insurance products.

Mr. Beaulieu also receives external compensation for the sale of securities to clients as a registered representative of Purshe Kaplan Sterling Investments, a broker-dealer. Approximately 10% of his time is spent in this practice and less than 15% of his total revenue is generated as a registered representative. He will offer clients products from this activity.

This represents a conflict of interest because it gives an incentive to recommend products based on the commission received. As a registered representative, Mr. Beaulieu does not charge advisory fees for the services offered through Purshe Kaplan Sterling Investments.

These practices represent conflicts of interest because it gives the affiliates an incentive to recommend products based on the commission amount received. This conflict is mitigated by disclosures, procedures, and the firm’s Fiduciary obligation to place the best interest of the clients first and clients are not required to purchase any products. Clients have the option to purchase these products through another insurance agent or registered representative of their choosing.

Finally, Mr. Beaulieu conducts business as the owner of a real estate property. Less than 5% of his time is spent on this activity. This does not represent a conflict of interest as the activity is not investment related.
Item 5 Performance Based Fee Description
Mr. Beaulieu is compensated for rental of real estate and receives commission from the sale of insurance and security products, but he does not receive performance-based fees.
Item 6 Supervision
Since Mr. Beaulieu is the sole owner of Beaulieu & Associates, he is solely responsible for all supervision and formulation and monitoring of investment advice offered to clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual.
Item 7 Requirements for State-Registered Advisors
Arbitration Claims: None to report.
Self-Regulatory Organization or Administrative Proceeding: None to report.
Bankruptcy Petition: None to report.
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