Ccm Investment Management is a investment adviser based in New Bedford, MA, that holds a 87.9/100 Fidelon TransparencyScore (41st percentile among state-registered advisers), with 2 registered advisors. Score based on public SEC and FINRA filings.
Ccm Investment Management
Ccm Investment Management, LLC · CRD #290483
A registered investment adviser with a clean regulatory record.
Fidelon Fact Sheet
Ccm Investment Management, LLC is a state-registered investment adviser in New Bedford, MA. It has 2 registered advisors. It manages $20.5 million across 130 client accounts. It charges a yearly percentage of your account that gets smaller as the account grows, and it can also earn commissions when it sells you a product. Its services include financial planning and portfolio management. Its record shows no customer complaints, regulatory actions or fines.
Peer Context
9,372nd of 15,825
state-registered advisers
Bottom 41%
347th of 546
state-registered advisers in MA
Bottom 36%
2nd of 2
state-registered advisers in New bedford, MA
Bottom 1%
How This Firm Works
Registration & Standard of Care
Investment Adviser — this firm is a registered investment adviser, held to a fiduciary standard — legally required to act in clients' best interests.
How This Firm Gets Paid
- Charges a percentage of assets under management
- Representatives can earn commissions on product sales
What you’d pay
Blended across 1 tiers, from $500,000 - $1,000,000.
This fee is negotiable
“Fees are generally negotiable and the final Schedule of Fees is included in the Investment Advisory Contract and any appendixes or related documents.”
From their Form ADV Part 2A. Most investors never ask.
Not included above
- • Clients are responsible for transaction and trading fees, custody fees, annual IRA fees, transition fees, margin costs, charges imposed by mutual funds or ETFs, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.
Estimated from the firm’s Form ADV Part 2A brochure — not a quote. Actual fees are set in your agreement and may differ. Costs charged by others (custodians, fund managers) are not included.
What This Firm Charges
| Account Size | Annual Fee |
|---|---|
| $0 - $50,000 | 1.45% |
| $50,000 - $250,000 | 1.30% |
| $250,000 - $500,000 | 1.15% |
| $500,000 - $1,000,000 | 0.95% |
| $1,000,000 - $2,000,000 | 0.75% |
| $2,000,000 - $5,000,000 | 0.60% |
| $5,000,000 and above | 0.45% |
Billed monthly in advance
Extracted from Form ADV Part 2A brochure
Specializations
Extracted from Form ADV Part 2A brochure
Key Findings
Strengths
- Registered as investment adviser with fiduciary obligation
- Clean regulatory record — no disclosures, arbitrations, or fines
- TransparencyScore in the top 59% of state-registered advisers
Things You Should Know
- Earns commissions when you buy certain products — may influence what gets recommended
Conflict Audit
Our analysis identified 2 potential conflicts of interest in regulatory filings.
Source: Form ADV Part 1, Items 6-8; Part 2A, Items 10-14
Regulatory Track Record
0
Disclosures
Clean record — no disclosures found
$0
Total Fines
Clean record — no fines found
Regulatory Events
TransparencyScore Dimensions
Disclosure Record
Customer complaints, arbitrations, and fines. Frequency and recency matter.
100/100
Strong
Avg for investment adviser firms: 82.6 | Top 10%: 99.5
Filing Quality
How clearly the firm describes services, fees, and investment approach in regulatory filings.
94/100
Strong
Avg for investment adviser firms: 84.1 | Top 10%: 100
Conflict Disclosure
How openly the firm explains who pays it and what it's paid to sell. The conflict isn't the problem — hiding it is.
85/100
Strong
Avg for investment adviser firms: 54 | Top 10%: 67
Enforcement History
Self-reported legal and disciplinary history from Form ADV Item 11.
100/100
Strong
Avg for investment adviser firms: 99.7 | Top 10%: 100
Their two-page relationship summary
The SEC requires every SEC-registered investment adviser to hand you this summary, called a Form CRS, and says what it must cover. We checked this firm's against that list. What is a Form CRS?
Not required
This firm is not required to file a Form CRS.
Without a Form CRS, the score above cannot go over 90. A firm that gives us one is scored on the same yardstick and can earn up to 10 more points.
What their brochure tells you
The firm must give you this brochure, Form ADV Part 2A, before you sign. We read it against the SEC's own instructions, item by item. Quotes are the firm's own words; page numbers refer to the filed brochure. What is in a brochure?
Can you tell what you'd pay and when?Brochure Fee Clarity100/100
The SEC asks every brochure to spell out the fee schedule, whether fees can be negotiated, how and when you are billed, the other costs you pay, and refunds.
The brochure answers every one of these.
- Can you tell what you'd pay?CoveredItem 5.A
Without a fee schedule you cannot compare this firm with any other.
Maximum annual fees are listed in the Schedule of Fees below.p. 7
- Does it say whether the fee can be negotiated?CoveredItem 5.A
If fees are negotiable, other clients may be paying less than you for the same service.
Fees are generally negotiable and the final Schedule of Fees is included in the Investment Advisory Contract and any appendixes or related documents.p. 7
- Does it say whether the fee comes out of your account or gets billed?CoveredItem 5.B
A fee taken straight from your account is easy to stop noticing.
Depending on the custodian and/or investment vehicle chosen, clients may have the ability to have CCMIM calculate and deduct asset-based portfolio management fees directly from the client account or have the fees calculated, deducted and remitted to CCMIM from the account by the custodian or other third-party.p. 7
- Does it say how often you're charged?CoveredItem 5.B
Monthly, quarterly, in advance or in arrears changes what you owe when you leave.
Asset-based portfolio management fees calculated by CCMIM are withdrawn directly from the clients’ accounts on a monthly basis.p. 8
- Does it list the other costs you pay, like fund and custodian fees?CoveredItem 5.C
The advisory fee is rarely the whole bill; fund, trading and custody costs come on top.
The fees include, but are not limited to, transaction and trading fees, custody fees, annual IRA fees paid to the custodian, transition fees when moving an account, margin costs, charges imposed directly by a mutual funds or exchange traded funds, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions.p. 9
- Does it say how you get money back if you leave mid-period?CoveredItem 5.D
If you pay in advance and leave early, the refund rule decides what you get back.
Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client’s account.p. 9
Does it explain each conflict of interest and what it could cost you?Brochure Conflict SpecificityNot applicable
Not applicable: the brochure names no material conflict of interest
Do they earn commissions on products, and do they say so?Brochure Sales Compensation85/100
When a firm or its people sell products for a commission, the SEC asks the brochure to say so, name the pull, and tell you whether you could buy elsewhere.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it say that earning commissions is a conflict of interest?CoveredItem 5.E.1
A firm paid to sell a product has a reason to recommend it that has nothing to do with you.
Conflicts of interest may arise when receiving commissions for the recommendation of insurance products.p. 9
- Does it say commissions can shape what they recommend?CoveredItem 5.E.1
Naming the pull is the first step to controlling it; silence leaves it working on you.
This practice potentially gives CCMIM and its supervised persons an incentive to recommend products based on the compensation received, rather than on a client’s needs.p. 9
- Does it say you can buy the same products elsewhere?CoveredItem 5.E.2
You may be able to buy the same product for less somewhere else.
Insurance products recommended by CCMIM are non-exclusive and are available for purchase through insurance brokers not affiliated with CCMIM.p. 10
- Does it say whether commissions lower your advisory fee?Not found in the brochureItem 5.E.4
If the firm earns a commission and the full advisory fee, you pay twice for one recommendation.
What to askAsk whether any commission the firm earns is credited against your advisory fee.
Do they get free research or services from brokers, and does it affect you?Brochure Soft Dollars85/100
When brokers give the firm research or services in return for your trades, the SEC asks the brochure to say what the firm gets and what it may cost you.
Each point is marked Covered or Not found. When a point is not found, we say what to ask.
- Does it list what the firm gets from brokers for free?Not found in the brochureItem 12.A.1.e
Research, software and data paid for by your trades are a cost you never see.
What to askAsk what research, tools or services the firm receives from brokers or custodians at no charge.
- Does it say the firm benefits by not paying for those things?CoveredItem 12.A.1.a
A perk the firm would otherwise buy is money in the firm's pocket, paid with your trades.
CCMIM benefits by not having to produce or pay for the research, products or servicesp. 16
- Does it say those perks can shape which broker it picks for you?CoveredItem 12.A.1.b
Your trades should go where you get the best deal, not where the firm gets the best perks.
CCMIM will have an incentive to recommend a broker-dealer based on receiving research or services.p. 16
- Does it say whether those perks stay within what the law allows?CoveredItem 12.A.1.e note
The law allows research paid for with client trades only within limits; outside them, it is your money.
CCMIM may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended.p. 16
- Does it say whether you pay more in trading costs because of those perks?CoveredItem 12.A.1.c
Paying up for trades to earn the firm a perk comes straight out of your returns.
Clients should be aware that CCMIM’s acceptance of soft dollar benefits may result in higher commissions charged to the client.p. 16
- Does it say whether every client benefits or only some?CoveredItem 12.A.1.d
Your trades may be paying for research that helps other clients' accounts, not yours.
CCMIM does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts.p. 16
A point not found is not a finding against the firm; many points apply only when the firm has that arrangement, and state-registered firms file the same brochure form.
Next Steps
Advisor Roster
2 advisors
| Advisor | CRD | Score | Grade |
|---|---|---|---|
| Andrew Richard Sylvia | 6700794 | — | — |
| Chad Clayton Mello | 5355726 | — | — |
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Frequently Asked Questions
What does the TransparencyScore measure?
The TransparencyScore measures how clearly and completely an advisor or firm discloses important information in their regulatory filings — things like fees, conflicts of interest, disciplinary history, and business practices. A higher score means better disclosure quality, not better investment performance.
Where does this data come from?
All data comes from public regulatory filings: SEC Form ADV (Parts 1, 2, and 3), FINRA BrokerCheck, and the SEC's Investment Adviser Public Disclosure (IAPD) database. These are official filings that firms and advisors are legally required to submit.
Does a low score mean they're a bad advisor?
Not necessarily. A low score means the firm's public filings are less transparent — they may use vague language about fees, skip details about conflicts, or have a more complex regulatory history. Some excellent advisors work at firms with poor disclosure practices. The score measures the filing, not the person.
How often is this data updated?
Fidelon refreshes data from SEC and FINRA sources on a regular schedule. Form ADV filings are updated annually by firms (with amendments throughout the year), and BrokerCheck data is updated as events are reported. Scores are recalculated after each data refresh.
Can an advisor or firm improve their score?
Yes. Scores are based on what's in public filings. A firm that rewrites its ADV brochure in clearer language, discloses conflicts more specifically, or resolves outstanding regulatory issues will see its score improve at the next refresh. The incentive structure is intentional.
Data Sources
Scores are generated using Fidelon's published scoring methodology and reflect the quality of public disclosures, not the quality of investment advice. A firm that improves its disclosures will see its score improve. Fidelon does not provide investment advice.
Verify on SEC IAPD
Last scored: · Score version: 3.15 · CRD #290483