Prospect Hill Management LLC

Fees and Compensation
Our annual fees for Investment Supervisory Services are based upon a percentage of gross assets under
management (excluding debit balanced owed) and generally range from 1.00% to 1.25%.
  Our fees for Investment Supervisory Services are charged at the following rates:
  ● 1.25% per year on accounts with market value of gross assets up to $2,000,000
  ● 1.00% per year on accounts with market value of gross assets above $2,000,000
Our fees are billed in arrears at the end of each calendar quarter based upon the value (market value or fair
market value in the absence of market value), of the client's account at the end of the previous quarter. Fees will
be debited from the account in accordance with the client authorization in the Client Services Agreement.
A minimum of $1,000,000 of assets under management is required for this service. This account size may be
negotiable under certain circumstances. Prospect Hill Management, LLC may group certain related client
accounts for the purposes of achieving the minimum account size and determining the annualized fee.
Limited Negotiability of Advisory Fees: Although Prospect Hill Management, LLC has established the
aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis.
Client facts, circumstances and needs will be considered in determining the fee schedule. These include the
complexity of the client, assets to be placed under management, anticipated future additional assets; related
accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule
will be identified in the contract between the adviser and each client.

We may group certain related client accounts for the purposes of achieving the minimum account size
requirements and determining the annualized fee.
Discounts, not generally available to our advisory clients, may be offered to family members and friends of
associated persons of our firm.

General Information
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either
party, for any reason upon receipt of 90 days written notice. Upon termination of any account, a client will be
billed a pro-rated portion of the advisory fee based upon the number of days the account was managed during
the final billing period.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and
expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction
charges imposed by a broker dealer with which an independent investment manager effects transactions for the
client's account(s). All fees paid to Prospect Hill Management, LLC for investment advisory services are separate
and distinct from the fees and expenses charged by mutual funds and/or EFTs to their shareholders. These fees
and expenses are described in each fund's prospectus.
Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information.
To the extent requested specifically by a client, Prospect Hill Management, LLC may provide limited consultation
services with regard to retirement, estate planning, cash flow analysis, taxes, and bill payment services. As
related to these consultation services and to the extent with which they are rendered, no portion of these services
should be interpreted by the client as legal, tax, or accounting advice. Any such services are rendered only on an
unsolicited basis for which Prospect Hill Management, LLC may charge a fee in excess of normal investment
supervisory services fees at a rate of $250 per hour. These additional services would be rendered to a client and
a fee levied upon a separate oral or written agreement with the client.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to
Prospect Hill Management, LLC's minimum account requirements and advisory fees in effect at the time the
client entered into the advisory relationship. Therefore, our firm's minimum account requirements will differ
among clients.
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available
from other registered (or unregistered) investment advisers for similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of
$500 more than six months in advance of services rendered.

Performance-Based Fees and Side-By-Side Management
Prospect Hill Management, LLC does not charge performance-based fees.

Types of Clients
Prospect Hill Management, LLC provides advisory services to predominantly high net worth individuals but does
provide advisory services to a select group of related individuals as well as a Family Limited Partnership (other
pooled investment vehicle).
As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based
on the nature of the service(s) being provided. For a more detailed understanding of those requirements, please
review the disclosures provided in each applicable service.

Methods of Analysis, Investment Strategies and Risk of Loss
We use the following methods of analysis in formulating our investment advice and/or managing client assets:
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and
financial factors (including the overall economy, industry conditions, and the financial condition and
management of the company itself) to determine if the company is underpriced (indicating it may be a good time
to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the
price of a security can move up or down along with the overall market regardless of the economic and financial
factors considered in evaluating the stock.
Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt
to recognize recurring patterns of investor behavior and potentially predict future price movement.
Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that
a poorly-managed or financially unsound company may underperform regardless of market movement.
Qualitative Analysis. We subjectively evaluate non-quantifiable factors such as quality of management,
labor relations, and strength of research and development factors not readily subject to measurement, and
predict changes to share price based on that data.
A risk in using qualitative analysis is that our subjective judgment may prove incorrect.
Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate
ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance.
A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry
or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to
stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals.
While we generally do not invest in mutual funds and ETFs, we will consider allocating assets to these types of
investments at the request of a client. In those instances, we look at the experience and track record of the
manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to
invest over a period of time and in different economic conditions. We also look at the underlying assets in a
mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held
in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they
are continuing to follow their stated investment strategy.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies
whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-
available sources of information about these securities, are providing accurate and unbiased data. While we are
alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by
inaccurate or misleading information.
INVESTMENT STRATEGIES
We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are appropriate
to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons,
among other considerations:
Long-term purchases. We purchase securities with the idea of holding them in the client's account for a year
or longer. Typically, we employ this strategy when:

● we believe the securities to be currently undervalued, and/or
● we want exposure to a particular asset class over time, regardless of the current projection for this class.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take
advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a
security may decline sharply in value before we make the decision to sell.
Short-term purchases. When utilizing this strategy, we purchase securities with the idea of selling them
within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions
that we believe will soon result in a price swing in the securities we purchase.

Trading. We purchase securities with the idea of selling them very quickly (typically within 30 days or less).
We do this in an attempt to take advantage of our predictions of brief price swings.
Short sales. We borrow shares of a stock for your portfolio from someone who owns the stock on a promise to
replace the shares on a future date at a certain price. Those borrowed shares are then sold. On the agreed-upon
future date, we buy the same stock and return the shares to the original owner. We engage in short selling based
on our determination that the stock will go down in price after we have borrowed the shares. If we are correct
and the stock price has gone down since the shares were purchased from the original owner, the client account
realizes the profit.
Margin transactions. We will purchase stocks for your portfolio with money borrowed from your brokerage
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