Appleton is an SEC-registered investment adviser with its principal place of business located at One Post Office
Square, 5th Floor, Boston, Massachusetts 02109. Appleton began conducting business as a firm in 1987 when it
filed its first registration with the Commission.
Appleton’s principal shareholder is the Appleton Partners Business Trust.
PRIVATE CLIENT SERVICES
Appleton manages separately managed accounts under a variety of arrangements. One such arrangement is
through direct relationships with the investor. These direct relationships are managed by Appleton’s Private
Client Services (“PCS”) team. PCS clients sign investment management agreements directly with Appleton. PCS,
with the support of its various industry partners and relationships, offers its diverse client base a menu of wealth
management solutions. Primary among Appleton’s PCS services are discretionary investment management and
general financial planning services. Through a relationship-driven and customized approach, Appleton works to
identify and address each client’s individual needs and provides services based on those unique sets of
circumstances. During the information-gathering process at the outset of the client relationship, Appleton will
discuss a wide range of issues with the client, including the client’s individual investment objectives, time
horizons, risk tolerances, tax sensitivities and liquidity needs. Periodically thereafter, the Firm will, in
consultation with the client when possible, review and revise investment objectives, strategies, and financial
plans (if applicable), where deemed necessary and appropriate.
Appleton specializes in municipal bond, taxable bond, and equity strategies, with domestic fixed income
securities, large cap equities, and exchange-traded funds (“ETFs”) generally comprising the major asset classes
held by PCS clients. Some client advisory accounts also include small cap equities, mid cap equities, mutual
funds, and various other security types, including but not limited to investments in private funds and other
alternatives. Appleton manages client advisory accounts on a discretionary basis. As such, clients authorize
Appleton to buy, sell, or otherwise trade securities or other investments in their accounts without first
discussing the transactions with the clients. Account supervision is guided by the individual client’s stated
objectives (e.g., growth, income, or growth and income), as well as risk tolerance, tax considerations and other
factors. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or
industry sectors. Appleton’s advisory recommendations are not limited to any specific product or service
offered by a broker-dealer, investment company or insurance company.
As an accommodation to clients who wish to gain exposure to bitcoin (and/or other types of cryptocurrencies),
Appleton’s Equity Investment Committee has approved the use of certain spot bitcoin ETFs. These bitcoin spot
ETFs are only included in a client’s account if explicitly requested by the client and are not utilized in any
standard Appleton strategy. Cryptocurrency is historically volatile, and investors should speak with their
Portfolio Manager to assess whether an investment in such an asset is consistent with their long term objectives
and risk tolerance. Further risks associated with investing in cryptocurrency and bitcoin spot ETFs may be found
in Item 8 – “Methods of Analysis, Investment Strategies and Risk of Loss.”
THIRD-PARTY ADVISORY PROGRAMS
Appleton also manages separately managed accounts (some of which are “wrap fee accounts”) for individual
and institutional clients pursuant to individual agreements with certain brokerage firms, investment banks, and
investment advisers (commonly referred to as “Sponsors”). Under these arrangements, separately managed
account holders typically enter into an agreement directly with the Sponsor, who in turn enters into an
agreement with Appleton in order to offer Appleton’s investment services to their clients. Appleton typically
manages these separately managed accounts in a manner consistent with other accounts not
under such a
portfolio management arrangement. Appleton receives a portion of the fee paid to the Sponsor for the
management of the separately managed account. Under these arrangements, Appleton receives the suitability
determination, investment objective, and any restrictions directly from the Sponsors with which the client has
a primary relationship. Often, separately managed accounts are funded prior to Appleton’s management of
them. In such circumstances, the account may hold securities inconsistent with the ultimate strategy objective.
In such instances, Appleton will realign the portfolio positions in a manner consistent with the determined and
agreed upon objective. Further details of Appleton’s advisory services with respect to separately managed
accounts may be found in Item 5 – “Fees and Expenses.”
SUB-ADVISORY & DUAL CONTRACT RELATIONSHIPS
Appleton has executed sub-advisory agreements with various investment advisers and financial services firms,
including banks and trust companies (each, an “Advising Firm” and together, the “Advising Firms”), for the
management of certain client accounts. The fees Appleton receives for these sub-advisory services are
established in the relevant sub-advisory agreements and are described in greater detail in Item 5 – “Fees and
Expenses.” Typically, in cases where Appleton serves as a sub-advisor, the Firm receives the suitability
determination, investment objective, and any restrictions directly from the Advising Firm with which the client
has a primary relationship.
Appleton also manages separately managed accounts pursuant to dual contracts. A dual contract is an
investment management agreement executed by Appleton and the end investor. The dual contract identifies
the investor as a client of the investor’s investment adviser or financial services firm. Operationally, there is no
distinction between the way Appleton manages sub-advised accounts and the way Appleton manages dual
contract accounts. The fees that Appleton receives for the management of these dual contract accounts are
established in the relevant dual contract and are described in greater detail in Item 5 – “Fees and Expenses.” In
cases where Appleton manages an account pursuant to a dual contract, Appleton receives the suitability
determination, investment objective, and any restrictions directly from the investor’s investment adviser or
financial services firm with which the client has a primary relationship.
Appleton does not communicate directly with the investor in sub-advisory nor dual contract relationships unless
requested by the investor’s investment manager or financial services firm. All communication with the investor
typically runs through the investor’s investment manager or financial services firm.
AMOUNT OF MANAGED ASSETS
As of December 31, 2023, Appleton actively managed approximately $12,650,265,281 of client assets on a
discretionary basis. Appleton does not provide ongoing management or advisory services for any client assets
on a non-discretionary basis.
UNSUPERVISED ASSETS
Occasionally, clients ask Appleton to include in their managed accounts certain assets, including non-security
assets, for which the Firm does not provide ongoing management or advisory services (the “unsupervised
assets”). While Appleton includes these unsupervised assets in its reports to clients and may consider these
assets when making asset allocation decisions or recommendations for clients, the Firm does not include these
unsupervised assets when determining the total assets under management upon which the client’s fee is based.
Appleton does not research, review, monitor, or otherwise evaluate a client’s unsupervised assets. Clients
requesting this courtesy service should recognize that the Firm may be unaware of certain factors that could
lead an unsupervised asset to change in value, and that Appleton should not be expected to alert the client
should such a change be in progress or have already occurred. The client bears the sole responsibility to monitor
unsupervised assets and the client must alert their Portfolio Manager when they wish to effect transactions in
the unsupervised assets.