Alesco is a limited liability corporation, with an office located in Pittsford, New York. Alesco was founded in 2000 by James G. Gould, who maintains primary ownership and is also the president. See Alesco’s ADV Part 1 for a more in-depth list of individuals with a material ownership interest. In November 2016, Alesco opened an office in Buffalo, New York. This location is a branch office of the firm, with the principal office located in Pittsford, New York. The address of the Buffalo location is 120 West Tupper Street; Buffalo, NY 14201. In 2019, Alesco purchased a minority interest in Layline Advisors, LLC. As of the date of this filing, Alesco’s ownership stake in Layline is less than 25 percent, though this is expected to increase over time. Layline Advisors, LLC is a Registered Investment Adviser with the SEC and offers, among other services, investment management services, comprehensive financial planning, and pension consulting services. For additional information regarding this arrangement, please see Item 10 of this document. Alesco provides investment management services primarily to institutions (such as foundations, endowments, for-profit organizations, retirement plans, trusts, and estates) and high net worth individuals. In the case of individuals, limited financial, tax, estate and insurance planning are provided to the extent agreed upon by the individuals and Alesco. The planning aspects are conducted in conjunction with the client’s other advisors. Of the clients that Alesco currently services, most clients grant day-to-day management authority to Alesco. This is accomplished through a pre-arranged investment management agreement or with an investment policy statement. Prior to managing client assets, an asset allocation plan is discussed with each client. Other information, such as client investment restrictions, fees (see Item 5), and the client’s tax situation, is gathered by Alesco prior to trading the account. Alesco will then make investments for the client with a view to achieving the client’s financial goals. In certain instances, Alesco is hired by a client to perform various consultative services. The extent of these services is pre-determined by Alesco and the client prior to entering into an agreement. Some examples of these services would include, but are not limited to, consolidated reporting, asset allocation recommendations, recommendations on securities held, and retirement plan advisory services (including employee education and security recommendations). In these instances, Alesco may not have discretionary investment authority – it will only make recommendations. Alesco may also act as a subadvisor for clients’ accounts. For example, Alesco may share investment advisory responsibilities with another advisor or third-party (such as a retirement plan administrator). Alesco currently participates in two Solicitor Arrangements. A Solicitor Arrangement is an agreement between an adviser (Alesco, in this case) and an outside party that is not affiliated with Alesco (the solicitor). The solicitor is compensated for introducing prospective clients to Alesco. The arrangement is disclosed to each client that is introduced to Alesco by the solicitor. The client must sign a document which discloses the material aspects of the agreement. Prior to opening an account that will be managed by Alesco, the client is also provided a copy of Alesco’s Form ADV Part 2a. These arrangements are discussed in greater detail in Item 5. In 2009, Alesco entered into two “wrap” programs. These are programs that combine several services (such as investment management, asset custody, and brokerage commissions) together for a single predetermined “wrap” (or bundled) fee. Generally, clients participating in a wrap fee program pay this single, all-inclusive fee quarterly (or at some other pre-arranged interval) in advance to the program sponsor, based on the net assets under management and any additional investment-related services provided. Alesco receives from the sponsor a portion of the wrap fee for the portfolio management services it provides, that may be less or more than the fees received from direct clients of similar size and mandate. Each program sponsor has prepared a brochure which contains detailed information about its wrap fee program, including the wrap fee charged. Copies of each brochure are available from the program sponsor upon request. The wrap program sponsor has retained Alesco through a separate investment advisory contract. Wrap program clients should note that Alesco will execute transactions for their accounts through the wrap sponsor. Execution prices through a wrap sponsor may be less favorable in some respects than Alesco’s clients whose trades are not executed through the wrap sponsor. This is because Alesco may not have the ability to negotiate price or take advantage of combined orders or volume discounts. Wrap program sponsors may limit (or altogether prohibit) Alesco’s ability to purchase certain mutual funds that would typically be held in a standard Alesco- managed account. In these instances, a comparable exchange traded fund is used as an alternative. This could have a small effect on the overall performance of the account when compared with non-wrap program accounts. Alesco participates as an investment manager with discretionary trading authority in the following wrap programs (program sponsors are listed parenthetically):
•LPL Financial Manager Access Select Program (LPL Financial Corporation)
•LPL Financial Manager Select (LPL Financial Corporation) Separately,

in 2011 Alesco entered into a “model program” (also known as an overlay program) arrangement with RBC Wealth Management. Under this program, Alesco provides RBC (known as the program sponsor) with an asset allocation for a model portfolio and provides updates of the model portfolio on a regular basis. RBC has investment discretion to accept, reject, or modify Alesco’s trade recommendations and apply them to their clients’ accounts. As a result, Alesco does not classify these accounts as discretionary assets under management. RBC is solely responsible to execute transactions and for providing best execution for such trades. RBC receives payment directly from the client, and compensates Alesco a percentage of the fee received. The program is formally referred to as the Consulting Solutions Program. In 2019, Alesco entered into a “model program” (also known as an overlay program) arrangement with American Portfolios Advisors, Inc. Under this program, Alesco provides American Portfolios (known as the program sponsor) with an asset allocation model portfolio and provides updates of the model portfolio on a regular basis. American Portfolios has investment discretion to accept, reject, or modify Alesco’s trade recommendations and apply them to their clients’ accounts. As a result, Alesco does not classify these accounts as discretionary assets under management. American Portfolios is solely responsible to execute transactions and for providing best execution for such trades. American Portfolios receives payment directly from the client, and compensates Alesco a percentage of the fee received. We offer an automated investment program (the “Schwab Program”) through which clients are invested in a range of investment strategies we have constructed and manage, each consisting of a portfolio of exchange-traded funds (“ETFs”) and a cash allocation. The client may instruct us to exclude up to three ETFs from their portfolio. The client’s portfolio is held in a brokerage account opened by the client at Charles Schwab & Co., Inc. (“CS&Co”). We use the Institutional Intelligent Portfolios® platform (“Platform”), offered by Schwab Performance Technologies (“SPT”), a software provider to independent investment advisors and an affiliate of CS&Co., to operate the Schwab Program. We are independent of and not owned by, affiliated with, or sponsored or supervised by SPT, CS&Co., or their affiliates (together, “Schwab”). We, and not Schwab, are the client’s investment advisor and primary point of contact with respect to the Schwab Program. We are solely responsible, and Schwab is not responsible, for determining the appropriateness of the Schwab Program for the client, choosing a suitable investment strategy and portfolio for the client’s investment needs and goals, and managing that portfolio on an ongoing basis. We have contracted with SPT to provide us with the Platform, which consists of technology and related trading and account management services for the Schwab Program. The Platform enables us to make the Schwab Program available to clients online and includes a system that automates certain key parts of our investment process. This system includes an online questionnaire that helps us determine the client’s investment objectives and risk tolerance and select an appropriate investment strategy and portfolio. Clients should note that we will recommend a portfolio via the system in response to the client’s answers to the online questionnaire. The client may then indicate an interest in a portfolio that is one level less or more conservative or aggressive than the recommended portfolio, but we then make the final decision and select a portfolio based on all the information we have about the client. The system also includes an automated investment engine through which we manage the client’s portfolio on an ongoing basis through automatic rebalancing and tax-loss harvesting (if the client is eligible and elects). We charge clients a fee for our services as described below under Item 5 Fees and Compensation. Our fees are not set or supervised by Schwab. Clients do not pay brokerage commissions or any other fees to CS&Co. as part of the Schwab Program. Schwab does receive other revenues in connection with the Schwab Program. We do not pay SPT fees for the Platform so long as we maintain $100 million in client assets in accounts at CS&Co. that are not enrolled in the Schwab Program. If we do not meet this condition, then we pay SPT an annual licensing fee. This fee arrangement gives us an incentive to recommend or require that our clients with accounts not enrolled in the Schwab Program be maintained with CS&Co. Schwab Program portfolios managed by Alesco are under no obligation to purchase or sell the same securities that it may be purchasing or selling for other portfolios under its management. In 2022, Alesco began providing financial planning services for individuals who are not currently investment management clients. For these services, Alesco receives a fixed financial planning fee. Alesco’s current regulatory Assets Under Management (as stated in its Part 1 of Form ADV) is approximately $4,187,470,805.98 as of February 28, 2023. In addition to Alesco’s Assets Under Management, Alesco provides consulting services, where Alesco does not have discretionary (or non- discretionary) trading authority, but provides advice on investment policy, security selection, investment manager analysis, and/or consolidated reporting. Alesco is paid a fee for these consulting services. As of February 28, 2022 the total of these assets was approximately $678,857,421.80.