(a) Description of Birch Hill
Birch Hill is an investment management firm founded in June of 2007 and wholly owned by its
principals, all of whom are actively engaged in the business. We have broad experience in investment
research, portfolio management, taxation and trust administration and have a long history of working
with clients and coordinating financial solutions with their attorneys, accountants, and other
professionals. Clients have direct access to the portfolio manager primarily responsible for the
management of their portfolio. The assets of the accounts managed by Birch Hill are held by
independent custodians, as further described in Item 15 below.
The Managing Members of Birch Hill are Gary Mikula and Robert O’Neil.
(b) Services Offered
Birch Hill provides investment advisory services to individuals, trusts, IRA’s and other employee benefit
plans, endowment, and foundations accounts. Birch Hill works with each client to establish their goals,
objectives, risk tolerance and investment time horizon and devises a plan to structure a portfolio to
meet their goals within the appropriate risk profile. Investment solutions primarily employ individual
stocks and bonds but may include mutual funds and exchange traded funds for certain asset classes.
The advice provided by Birch Hill often goes beyond the portfolio and will include coordination with
other professionals, including attorneys and accountants, in areas such as income and estate tax
planning, giving strategies and other matters.
(c) Services tailored to meet the needs of our clients
Birch Hill believes in building portfolios customized to reflect the individual circumstances and needs of
each client. Central to the approach is knowing each client well, understanding their needs, and
investing to meet objectives for growth, income, and risk tolerance. Establishing the investment
strategy begins with a discussion with each client about their goals, objectives, and risk parameters.
We work with each client to define their investment horizon, to understand how much they will spend
and when, and to assess an acceptable level of volatility. The investment strategy incorporates
portfolio growth objectives and expected financial needs.
What is an acceptable level of volatility? The answer is different for each client and not easily
determined. We invest in securities that can go up or down in value, so our clients can lose money.
Our goal is to structure portfolios for our clients that reflect the right amount of risk for them. For
example, a client with a low risk level would generally have a higher percentage of their account in
bonds. In a year when the stock market is down significantly, the bonds would generally reduce the
amount of the decline. A client more able and inclined to have a higher risk level might have a larger
percentage in stocks. This client would generally lose more in the years when stocks are down but
perform better in the years when stock prices rise significantly. The key conversation is to determine
the right mix for each client for the long term. We try to ensure that clients are comfortable
with their
asset allocation and are not urging us to change their asset allocation at times of market extremes.
Birch Hill manages some client portfolios with significant investment restrictions. For example, with
some clients we may construct and manage a portfolio that addresses their social responsibility
concerns. Some clients have very restrictive requirements concerning levels of annual realized capital
gains. Other clients may be actively engaged in a business or venture, and Birch Hill will tailor their
investment portfolio to reduce exposure to other companies in the same industry, or construct a
portfolio focused on low risk, low volatility to offset some of the risk in the client’s business. Each
client’s investment strategy is periodically reviewed and updated with the client to ensure it remains
appropriate for their situation.
The communication plan devised for each individual client may include periodic meetings to review the
portfolio objectives, investment performance results, recent activity, and other pertinent information.
The plan may also include periodic written reports, such as quarterly letters, sent electronically or by
mail and supplemented by email and telephone conversations.
Retirement Funds Rollover Recommendations: When we provide investment advice to you regarding
your retirement plan account or individual retirement account, we are fiduciaries within the meaning of
Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as
applicable, which are laws governing retirement accounts. The way we make money creates some
conflicts with your interests, so we operate under a special rule that requires us to act in your best
interest and not put our interest ahead of yours. Under this special rule’s provision, we must:
• Meet a professional standard of care when making investment recommendations (give prudent
advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
• Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interests. Our clients may decide to rollover retirement assets independently and without a
recommendation from Birch Hill. However, if Birch Hill offers advice regarding the rollover, in any way,
even small, then we are deemed to be giving Fiduciary Advice.
(d) Birch Hill does not participate in any wrap fee programs.
(e) Amount of client assets managed by Birch Hill as of December 31, 2021.
Amount Number of Accounts
Discretionary: $2,064,583,618 1,204
Non-Discretionary: $0 0
Total: $2,064,583,618 1,204