A. Company Information Bolton Securities Corporation (BSC) is a dually registered investment adviser and broker dealer. It conducts investment advisory activities as a federally registered investment adviser under the trade name Bolton Global Asset Management (BGAM). It conducts broker-dealer activities under the Bolton Securities Corporation trade name. Please note that SEC registration does not imply a certain level of skill or training. Except where necessary to distinguish between broker-dealer and investment advisory capacities, the BGAM name shall be used herein when discussing Bolton Securities Corporation. BGAM has been offering investment advisory services since 2002. BGAM is a privately-owned corporation with its principal place of business in Bolton, Massachusetts. Bolton Financial Group owns one hundred percent (100%) of the firm’s equity. Advisory services are offered through a network of investment advisor representatives (“IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or client statements. These business names have been adopted by BGAM as d/b/a names under which it provides advisory services. The client should understand that these businesses are legal entities of the IAR and not of BGAM. When using d/b/a names, BGAM may not always provide reference to the legal name of the company. Regardless, when used to refer to the company, the use of a d/b/a name is intended as a pseudonym for our legal company name. BGAM’s advisory services are made available to clients primarily through its IARs. Each IAR maintains a supplement to this Brochure (the “Brochure Supplement”) that discusses important information about the IAR. The Brochure Supplement is a separate document that is provided by the IAR along with this Brochure before or at the time client engages the IAR. In addition to reading this Brochure, clients should read the Brochure Supplement and understand its contents before engaging in advisory services through BGAM and the IAR. If the client did not receive a Brochure Supplement for the IAR, the client should contact the IAR or BGAM at [email protected] This Brochure provides information regarding the qualifications, business practices, and the advisory services provided by BGAM. The BGAM and its IARs serve as a fiduciary to clients, as defined under applicable laws and regulations. As a fiduciary, BGAM and the IARs uphold a duty of loyalty, fairness and good faith towards each client and seek to mitigate potential conflicts of interest. This fiduciary commitment is further described in the BGAM Code of Ethics. For more information regarding our Code of Ethics, please see Item 11 of this Brochure. B. Description of Advisory Business BGAM provides two core advisory services to clients – asset management and financial planning/consulting services. Asset management services entail the management of client investment assets on a discretionary or non-discretionary basis, depending on the arrangement with the client. Financial planning and consulting services entail assessment of the client’s expressed investment needs, development of a plan, or providing advice in a consulting arrangement that does not include the management of assets. Clients can engage with BGAM for either asset management or financial planning/consulting or the client can engage with BGAM for both services concurrently. None of the advisory services described herein are intended as, or meant to be a substitute for, legal, March 30, 2024, pg. 5 accounting, actuarial, or tax advice. Clients should coordinate and discuss the impact of the financial advice they receive from a BGAM IAR with their attorney, accountant, and other professionals. Asset Management Services BGAM provides customized wealth management solutions for its clients. This is achieved through continuous personal client contact and interaction through our IARs. BGAM IARs work with each client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. BGAM will implement the investment strategy with its internal management and/or the use of unaffiliated money managers or investment platforms (as described below). BGAM’s IARs are independent contractors. This means that BGAM’s financial advisors are free to implement investment strategies and plans on their own accord, subject to oversight and supervision by BGAM. This is distinguished from some other registered investment advisors that mandate the clients invest only in company-sponsored investment programs. BGAM believes strongly in the flexibility it provides to its IARs. To the extent that IARs employ BGAM-sponsored investment programs in client accounts, it is because the IAR deems the investment program to be suitable for the client and not because of any requirement to do so from BGAM. Asset management services are offered either on a non-discretionary or discretionary basis. Non- discretionary asset management entails client pre-approval of investment transactions before they can occur. Discretionary asset management allows the IAR to implement investment transactions in the account absent client pre-approval. Below is a description of BGAM’s asset management services. Internal Investment Management BGAM customizes its investment management services for its clients. Internal investment management services are provided by the IAR on a client-by-client basis, and sometimes employing universal strategies that are applicable to more than one client. Client portfolios are primarily constructed using mutual funds, exchange-traded funds (“ETFs”), individual stocks and fixed income securities. The IAR may also utilize other types of investments, as appropriate, to meet the needs of each particular client. BGAM generally employs a long-term investment approach for clients, but may buy, sell or re-allocate positions that have been held for less than one year to meet the objectives of the client or due to market conditions. BGAM will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the client. Each client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the IAR. The specific advisory program selected by the client will cost the client more or less than purchasing program services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but may not be limited to, the type and size of the account, the historical or expected size or number of trades for the account, the types of securities and strategies involved, and the number and range of supplementary advisory and client-related services provided to the account. BGAM may recommend, on occasion, redistributing investment allocations to diversify the portfolio. BGAM March 30, 2024, pg. 6 may recommend specific positions to increase sector or asset class weightings. The IAR may recommend employing cash positions as a possible hedge against market movement. The IAR may also recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of client, generating cash to meet client needs, or any risk deemed unacceptable for the client’s risk tolerance. Client should be aware that securities transferred into an account may have been subject to a commission or sales load when the security was originally purchased. After transfer into an advisory account, client should understand that an advisory fee will be charged based on the total assets in the account, including the transferred security. When transferring securities into an account, client should consider and speak to IAR about whether:
• a commission was previously paid on the security;
• client wishes for the security to be managed as part of the account and be subject to an advisory fee; or
• client wishes to hold the security in a brokerage account that is not managed and not subject to an advisory fee. The following paragraph contains important conflicts of interest to consider. With respect to certain types of accounts, clients do not pay any transaction charges (i.e. a wrap fee account as discussed in the Wrap Fee Appendix to this Disclosure Brochure). Clients should be aware that BGAM pays transaction charges to its custodians for the transactions in those accounts. The transaction charges paid by BGAM vary based on the type of transaction (e.g., mutual fund, equity or ETF) and, for mutual funds, based potentially on whether or not the mutual fund pays 12b-1fees (fees paid by the mutual fund to distributors of the funds to cover the cost of distribution and/or shareholder services) and/or recordkeeping fees to the custodian. In many instances, custodians make available mutual funds that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as "Class I," "institutional," "investor," "retail," "service," "administrative" or "platform" share classes ("Platform Shares"). The Platform Share class offered for a particular mutual fund on the custodial platform in many cases will not be the least expensive share class that the mutual fund makes available, and was selected by the custodian in certain cases because the share class pays the custodian compensation for the administrative and recordkeeping services it provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through the custodial platform. In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay the custodian a 12b-1fee for providing shareholder services, distribution, and marketing expenses ("brokerage-related services") to the mutual funds. Platform Shares generally are not subject to 12b-1fees. As a result of the different expenses of the mutual fund share classes, it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time, and keep more of his or her investment returns than an investor who holds Class A Shares of the same fund. BGAM has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares are available. This is a conflict of interest which might incline BGAM, consciously or unconsciously, to render advice that is not disinterested. Clients should understand this conflict and consider the additional indirect expenses borne as a result of the mutual fund fees when negotiating and discussing with your IAR the advisory fee for management of an account. March 30, 2024, pg. 7 Sub-Advisory/Consultant Investment Management BGAM can enter into consultant or sub-advisory relationships in which it contracts with other third- party asset managers (“TPAM”) to provide research, advice, and guidance or investment management services regarding assets BGAM manages for clients. Such arrangements might range from the other advisor providing research ideas that BGAM may or may not implement, to a sub-advisor having full discretion over a BGAM client’s assets. Since each TPAM is uniquely structured with different investment products, please ensure that you carefully review all documents provided to you on behalf of the TPAM. These include, but are not limited to:
• The TPAM’s Form ADV Part 2A and other disclosure brochures.
• The TPAM’s Client Agreement as well as any other agreement entered regarding a TPAM

Program, for specific contractual terms (including fees, billing methods, administrative and other fees, etc.)
• Any additional disclosure or offering documents provided by the TPAM in connection with investment products. The following paragraph contains important conflicts of interest to consider. Assets managed in a sub- advised account program are counted as assets under management of BGAM and the sub-adviser. Many investment advisory firms are measured, in part, by the amount assets under management as reported in this Brochure. In a sub-advised investment program, both the sub-adviser and BGAM are responsible for the management of the invested assets, though in practice, investment management is vested almost entirely in the sub-adviser. This increases BGAM’s risk of client grievances stemming from account management by the sub-adviser and prompts BGAM to engage in time consuming and costly oversight of sub-advisory relationships. This risk results in a conflict of interest inasmuch as it deters BGAM from employing sub-advisors. The effect of this conflict of interest is mitigated by the independence of BGAM’s Chief Compliance Officer, who determines the necessity of sub-advisory relationships without regard to the cost or oversight considerations. Third-Party Asset Management Program (TPAM) Services BGAM provides access to asset management programs offered by third party investment advisors (referred to as “TPAM sponsors”) with which BGAM has entered an agreement to make their services available. When acting as a solicitor for the TPAM, neither BGAM nor any IAR provides asset management services in relation to the TPAM Program. Instead, your IAR will assist you in selecting one or more TPAM programs believed to be suitable for you based on your stated financial situation, investment objectives, financial goals and suitability factors. TPAM services generally begin with the IAR obtaining the necessary financial data from the client to assist with setting an appropriate investment objective, determining the suitability of the program and in opening an account with the TPAM sponsor. Depending on the program, the IAR may also assist the client with selecting a model portfolio of securities designed and managed by either the TPAM sponsor or a selected portfolio management firm available through the TPAM sponsor responsible for providing discretionary asset management services. The TPAM sponsor or other third-party investment advisor is granted client authority in its client agreement to purchase and sell securities on a discretionary or non-discretionary basis pursuant to investment objective chosen by the client. In doing so, the TPAM sponsor or other third-party investment advisors typically construct various model investment portfolios that are managed according to specific investment strategies associated with the respective models, and that are not generally customized March 30, 2024, pg. 8 for individual clients (subject to the client’s ability to request reasonable investment restrictions on investing in securities or other special accommodations that may be made). In addition to portfolio management services, the TPAM sponsor will also generally arrange for custody of client assets, trade execution, cashiering services, and such other services as outlined in their separate client agreement and Brochure. In limited cases involving certain retirement plans, BGAM and the IAR may undertake to provide plan-level investment advisory and education services under a consulting arrangement specifying such additional services. Since the TPAM services provided by each TPAM sponsor or other third party investment advisor in the TPAM program are unique, clients should request and carefully review the applicable Brochure, client agreement and other account paperwork for each TPAM for more detailed information about the services provided by the TPAM sponsor, including without limitation, a description of the TPAM sponsor’s background, investment strategies, fees, custody arrangements, potential conflicts of interest, and other relevant information regarding the TPAM sponsor’s services and business practices. Clients may request a copy of their Brochure from the IAR or by visiting www.adviserin.sec.gov. Clients may also request the advisor’s Form ADV 2B Supplemental Brochure from their IAR for detailed information about the management personnel responsible for managing client investment portfolios. The following paragraph contains important conflicts of interest to consider. Assets managed by a TPAM are not considered assets under management of BGAM. Many investment advisory firms are measured, in part, by the amount assets under management as reported in this Brochure. The fact that BGAM cannot count assets advised in a TPAM program as its assets under management creates a conflict of interest inasmuch as it acts as a barrier to recommending TPAM programs. The effect of this conflict is mitigated by the independence of BGAM’s financial advisors, who are not required to have client account recommendations approved by BGAM. Financial Planning Services Financial planning and consulting services can be engaged on an ongoing or project-specific basis. Ongoing financial planning and consulting entails the tendering of advice over a long period of time with regular updates in consideration of changes in the overall parameters of the engagement. Project-based financial planning and consulting involves engagement for a finite period or project that has a measurable endpoint. That endpoint can be measured either in time or in completion of the services within the scope of the engagement. As part of BGAM’s financial planning services, BGAM, through its IARs, provides personal financial planning tailored to the individual needs of the client. These services may include, as selected by the client on the financial planning agreement, information and recommendations regarding tax planning, investment planning, retirement planning, estate needs, business needs, education planning, life and disability insurance needs, long-term care needs and cash flow/budget planning. The services consider information collected from the client such as financial status, investment objectives and tax status, among other data. The IAR delivers to the client a written financial plan. The engagement terminates upon delivery of the financial plan. BGAM and their IAR will not have any discretionary investment authority when offering financial planning. The following paragraph contains important conflicts of interest to consider. Financial planning recommendations may pose a conflict between the interests of BGAM/its IARs and the interests of the client. For example, a recommendation to engage BGAM and its IAR for investment management services or to increase the level of investment assets in an asset management account would pose a conflict, as it March 30, 2024, pg. 9 would increase the advisory fees paid to BGAM and its IAR. The effect of this conflict is mitigated by the independence of BGAM’s clients. Clients are not required to use BGAM or any of its IARs for investment services incorporated into a financial plan or consulting engagement. An additional agreement will be required if the client chooses to utilize the IAR for further investment management services. Financial planning services may be included in an overall wealth management engagement or provided as a separate service, pursuant to the terms of the agreement with the client. C. Client Role and Obligations Relative to BGAM’s Advisory Services BGAM relies on forthright communication from its clients in order to provide them with investment advice. It is imperative that clients be direct, honest, fulsome and timely with their investment criteria, investment knowledge, holdings, goals, time horizon and other important factors. Clients are obliged to report changes in their financial situation, including the factors enumerated above, to BGAM or the IAR as soon as possible. D. Tailored Relationships BGAM tailors its advisory services to the individual needs of its clients. It is the role of the IAR to meet with clients and determine which option(s) are most suitable in assisting the clients with meeting their investment needs. Certain programs available through BGAM may be utilized by multiple clients that have similar time horizons, needs and objectives. Advisory clients are permitted to impose restrictions on their accounts. In general, the restrictions may include security type, specific securities, and cash balance requirement. Under certain situations a restriction may prevent BGAM from providing investment choices to meet a client’s needs. BGAM can accept or not accept any reasonable limitation or restriction that clients wish to place on their account. All limitations and restrictions must be provided to BGAM in writing. In the event a restriction does impair BGAM’s ability to manage a portfolio effectively the client engagement may be terminated under the terms of the contract. E. Wrap Fee Programs For some clients, BGAM may include the securities transaction fees together with investment advisory fees to provide the client with a single, bundled fee structure. This combination of fees is typically referred to as a “Wrap Fee Program.” BGAM offers wrap accounts managed by third party investment managers on a discretionary basis. Currently, BGAM has arrangements with Pershing, LLC, Lockwood Asset Management and Envestnet Asset Management ("Platform Providers") to offer their asset management platforms, including access to investment managers on the platform, to BGAM clients. In all instances, BGAM is a sponsor of the wrap fee program. The Platform Provider may also be a sponsor, depending on the nature of the program and the role taken by the Platform Provider. In certain instances, BGAM acts solely as the sponsor and a referring adviser, with the Platform Provider serving as the client’s investment adviser. In other instances, BGAM acts as the client’s investment adviser by assisting the client in selecting investment managers and setting asset allocations. BGAM can also offer such services or access to investment managers through other sponsors in the future. BGAM receives a portion of the total wrap fee for referring the client to the program or assisting in the selection of managers and setting asset allocations. BGAM is also the provider of a wrap fee program managed on a discretionary or non-discretionary basis by BGAM investment adviser representatives. There is no difference in the investment management of wrap March 30, 2024, pg. 10 accounts and separately managed accounts. BGAM receives a portion of the total wrap fee for providing investment management services. BGAM’s Wrap Fee Program Brochure is included as Appendix 1 to this Disclosure Brochure to discuss the fees and potential conflicts associated with a bundled fee and its wrap fee programs. F. Assets Under Management As of December 31st, 2023, BGAM managed a total of $5,853,942,197 of which $3,340,417,519 is on a discretionary basis and $ 2,513,524,678 is on a non-discretionary basis. G. Conflicts of Interest Relative to Advisory Service Selection The following paragraph contains important conflicts of interest to consider. Clients should be aware that the compensation to BGAM and its IARs will differ according to the specific advisory program chosen. This compensation may be more than the amounts it would otherwise receive if you participated in another program or paid for investment advice, brokerage, and/or other relevant services separately. As a result of the differences that exist among the various advisory programs and services BGAM has a financial incentive to recommend a particular program or service over other programs or services available through BGAM. BGAM mitigates the impact of this conflict of interest by maintaining a compliance program that is designed to educate IARs of their fiduciary duty to clients and monitor investment decisions for suitability.