9AT: NORTON CAPITAL MANAGEMENT, INC.

NORTON CAPITAL MANAGEMENT, INC.

NORTON CAPITAL MANAGEMENT, INC.

NORTON CAPITAL MANAGEMENT INC

Adviser Profile

As of Date	09/19/2025
Registration	SEC, Approved, 10/13/2017
Other registrations (3)	North Carolina, Terminated, 12/11/2017 Texas, Terminated, 12/11/2017 Virginia, Terminated, 12/11/2017
ADV Location	HENRICO, VA, United States
Contact Info	(75 xxxxxxx
Websites

AUM^*	136,565,435 3%
of that, discretionary	123,677,066 2%
Number of Employees	6 200%
of those in investment advisory functions	2
Private Fund GAV^*	0
Avg Account Size	517,293 14%
% High Net Worth	29.27% 23%
SMA’s	Yes
Private Funds	0

Adviser Type

- Large advisory firm

Client Types

- Individuals (other than high net worth individuals)
- High net worth individuals
- Charitable organizations

Advisory Activities

- Financial planning services
- Portfolio management for individuals and/or small businesses
- Portfolio management for businesses

Compensation Arrangments

- A percentage of assets under your management

Reported AUM

124M 106M 88M 71M 53M 35M 18M

2017 2018 2019 2020 2021 2022 2023 2024 2025

Discretionary

Non-discretionary

Private Funds

No private funds

Employees

Form ADV-E Surprise Examination Reports

Accounting Firm Name	Filing Date	Form ADV-E
Accounting Firm Name CAVANAUGH NELSON PLC	Filing Date05/05/2025	Form ADV-E View Report
Accounting Firm Name CAVANAUGH NELSON PLC	Filing Date09/09/2024	Form ADV-E View Report
Accounting Firm Name CAVANAUGH NELSON PLC	Filing Date09/06/2023	Form ADV-E View Report
Accounting Firm Name CAVANAUGH NELSON PLC	Filing Date01/13/2023	Form ADV-E View Report

Brochure Summary

Overview

Norton Capital Management, Inc. (“NCM”) is a Delaware corporation that provides fee-based asset management services. The firm registered as an investment adviser and began conducting business in June of 1993. NCM is owned by Raymond J. Norton and Kimberly M. Norton. NCM is not engaged in any other business other than providing investment advice. NCM provides asset management services to a wide variety of clients wishing to have their assets managed continuously on a discretionary or non-discretionary basis. The service begins with NCM assisting clients in determining their investment objectives and investment restrictions and establishing a brokerage account. NCM typically recommends that clients establish a brokerage account with Pershing Advisor Solutions, LLC (“PAS”) and most clients typically do so (PAS is an indirect subsidiary of The Bank of New York Mellon Corporation). After the brokerage account is established, NCM will invest and reinvest the client’s funds and securities held in the account on a discretionary or non-discretionary basis in a manner consistent with their individual objectives and restrictions. Managing on a discretionary basis means that NCM has the authority to execute securities transactions in client accounts, including determining the amount purchased and timing of the transactions, without obtaining prior permission from the client (i.e., investment decisions are made at NCM’s discretion). Besides

managing various types of securities for clients, such as preferred stocks, warrants, rights, common stocks, bonds, municipal securities, and government bonds, a portion of the securities in clients’ accounts may be held in cash or cash equivalents, including, but not limited to, money market mutual funds and bank deposits insured by the Federal Deposit Insurance Corporation. Each of these involves risk in varying degrees. NCM utilizes the information provided by clients to provide investment recommendations. NCM may implement various short and long-term investment strategies and may give advice and take action in the performance of its duties to clients which may differ from advice given, or the timing and nature of the action taken, with respect to other client accounts. NCM will make a reasonable effort to follow all investment management restrictions and instructions expressed by clients. Clients may request consultations about the performance of their accounts as often as they wish. Clients are asked to inform NCM promptly upon the occurrence of any changes to their financial status or investment objectives. Providing this information allows NCM to determine if a change in investment strategy is necessary or appropriate. As of June 30, 2023, NCM had total assets under management of $124,074,957, consisting of $113,132,814 under discretionary management and $10,942,143 under non-discretionary management.

NORTON CAPITAL MANAGEMENT, INC.

NORTON CAPITAL MANAGEMENT, INC.

NORTON CAPITAL MANAGEMENT INC

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Form ADV-E Surprise Examination Reports

Brochure Summary

Overview

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NORTON CAPITAL MANAGEMENT, INC. NORTON CAPITAL MANAGEMENT, INC. NORTON CAPITAL MANAGEMENT INC

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Form ADV-E Surprise Examination Reports

Brochure Summary

Overview

NORTON CAPITAL MANAGEMENT, INC.

NORTON CAPITAL MANAGEMENT, INC.

NORTON CAPITAL MANAGEMENT INC