Description of Services and Fees Castleton Partners, LLC ("Castleton") is registered as an investment adviser with the United States Securities and Exchange Commission and we are based in Clermont, NY. We are organized as a limited liability company under the laws of the State of Delaware and we have been providing investment advisory services since 2005. Reinoso & Company, LLC (which is owned by the Estate of Edward Reinoso) is our principal owner. We are a fee-only independent investment adviser that primarily provides fixed income asset management to high net worth clients.
The following paragraphs describe our services and fees. Please refer to the description of each advisory service listed below for information on how we tailor our advisory services to your individual needs. Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Asset Management Services We primarily offer discretionary asset management services to our clients and prospective clients. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for asset management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather from our initial meeting to develop a strategy and written investment policy statement ("IPS") that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. Once we construct a portfolio for you, we will monitor your portfolio on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and your financial circumstances. On occasion, we may also provide non-discretionary asset management services whereby we will receive authorization from clients prior to executing any transactions.
Castleton's main strategy is to analyze, recommend and invest in investment grade municipal securities and corporate debt, and may also extend to preferred equities, exchange traded funds, closed end funds and mutual funds ("Investment Grade Fixed Income Strategy"). In addition, from time to time Castleton may analyze, recommend and invest in situations with higher risk, and the potential for corresponding higher returns, including but not limited to investment in high yield securities and distressed issues and issues of distressed issuers ("Special Strategies"). These strategies are described more fully below in the section of this ADV "Recommendation of Particular Types of Securities" and "Risk of Loss".
We require you to grant our firm discretionary authority to manage your account unless you have engaged our firm for non-discretionary services. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the credit quality or interest coupon rates of fixed income securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing.
Additionally, as part of our portfolio management services, we may use one or more sub-advisers to manage a portion of your account on a discretionary basis. We will regularly monitor the performance of your accounts managed by sub-adviser(s), and may hire and fire any sub-adviser with prior notice to you. We may pay a portion of our advisory fee to the sub-adviser(s) we use; however, you will not pay our firm a higher advisory fee as a result of any sub-advisory relationships. 4 Our fee for asset management services is based on a percentage of your assets we manage as well as the types of securities in which we invest, and is set forth in the fee schedule below. For our Investment Grade Fixed Income Strategy, we may invest your account in Fixed Income Securities, Preferred Equity Securities, Mutual Funds, ETFs, Closed End Funds, or a combination of these. Portfolio SizeAnnual Fee** Investment Grade Fixed Income Strategy Value

of Securities $2,000,000 to $9,999,999.40% Value of Securities $10,000,000 to $49,999,999 .35% Value of Securities Over $50,000,000Negotiable Special Strategies Value of SecuritiesAll amounts1.0% ** We impose a minimum fee of $2,000 per quarter or .40% per annum of the value of assets we manage, whichever is greater.
Our annual asset management fee is billed and payable quarterly in advance based on the closing value of managed holdings as of the last day of the previous quarter. We may not include cash or cash equivalents in the value of accounts for purposes of calculating our fee. Our minimum account size is $2,000,000, however, at our discretion we may accept a lower account size.
At our discretion, we may combine the account values of family members living in the same household to determine the applicable advisory fee. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above.
We will send you an invoice for the payment of our advisory fee or we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. You should review all statements for accuracy.
You may terminate the asset management agreement upon 5 days' written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of those fees.
Portfolio Consulting and Concierge Services We offer portfolio consulting services to prospective high net worth and institutional clients. If you retain our firm for portfolio consulting services, we will meet with you to review your portfolio of investments and provide you with a summary analysis of your portfolio including but not limited to advice on your exposure to risk, maturity strategy and other relevant subjects.
5 We also offer concierge services where we provide you with an in depth analysis and on going reviews of your portfolio. In the event we provide any recommendations to you, it shall be your responsibility to implement any advice we provide.
Portfolio consulting/concierge services clients may also retain us to provide asset management services as described above for a separate fee. We charge either a negotiable hourly fee or a negotiable fee for portfolio consulting and concierge service. Fees and fee-paying arrangements will be determined with each client on a case by case basis and depend on the scope and complexity of the services provided.
You may terminate the portfolio consulting/concierge agreement upon 5 days' written notice to our firm.
You will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the amount of work we have performed. Types of Investments We primarily offer advice on a broad range of municipal bonds and corporate debt securities, and on occasion may provide advice on preferred equities, mutual funds, exchange traded funds, closed end funds, taxable securities, commercial paper, and United States Government securities.
Additionally, we may advise you on other types of investments that we deem appropriate based on your stated goals and objectives. We may also provide advice on other types of investments held in your portfolio at the inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of securities. You must provide these restrictions to our firm in writing.
Assets Under Management As of December 31, 2023, we provide continuous management services for $99,231,200 in client assets on a discretionary basis, and $48,645,000 in client assets on a non-discretionary basis.