The Business Overview Alapocas Investment Partners, Inc. is a Massachusetts corporation formed in February 2019. AIP is an independent investment adviser registered with the Securities and Exchange Commission (“SEC”). David W. Lemons is the principal owner of AIP and the principal investment professional of AIP (the “Principal”).
AIP provides investment management services to individuals, high-net-worth individuals, charitable organizations, corporations, a profit-sharing plan, trusts (including pooled investment trusts), and other entities.
The Adviser primarily offers discretionary investment management services on a regular and continual basis that are customized to meet each client’s objectives and are comprehensive in nature. These services include the design and execution of an appropriate investment strategy and the research and selection of equity (including exchange-traded funds), fixed income, mutual fund, and cash reserve instruments. In certain circumstances, the Adviser will offer non-discretionary advisory services. These services include investment recommendations and arranging or effecting the purchase or sale of securities either directly or through a third-party manager, if the client accepts the recommendations.
AIP manages clients’ portfolios after creating and reviewing an investment strategy based on the client’s personal data, investment goals, and risk tolerance. This includes an allocation strategy to equity securities, fixed income securities, and cash reserve securities, as appropriate. See Item 8 — “Methods of Analysis, Investment Strategies, and Risk of Loss,” subsection: Investment Strategies for further details about these asset allocation strategies.
Clients may request restrictions on the purchase and/or sale of securities, industries, sectors, and asset classes. On a case-by-case basis, AIP is willing to work with clients who request such specific restrictions on their account(s) providing that, by doing so, the Adviser is able to substantially provide the comprehensive investment management strategy initially discussed with the client.
Retirement

Plan Advice When AIP provides investment advice to clients regarding their retirement Plan accounts or individual retirement accounts, the Adviser is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts.
4 The way AIP makes money creates some conflicts with clients’ interests. For example, because the Adviser charges an asset-based fee, it has a financial incentive to encourage clients to engage AIP to manage their assets. The fee a client pays AIP is shared between the firm and its representatives. In addition, if AIP is the investment adviser to the client’s employer’s Plan, this creates a further conflict of interest if the employer does not want former employees to continue to participate in the employer’s Plan (for example, if the employer does not want to continue to bear costs associated with maintaining former employees’ assets in the Plan), because the firm has an interest in maintaining its ongoing relationship with the client’s employer.
AIP operates under a special rule that requires the firm to act in the client’s best interest and not put the firm’s interest ahead of the client’s. Under this special rule’s provisions, AIP must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put the Adviser’s financial interests ahead of the client’s when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that AIP gives advice that is in the client’s best interest;
• Charge no more than is reasonable for the firm’s services; and
• Give clients basic information about conflicts of interest.
The Firm’s Assets Under Management As of December 31, 2023, AIP advises on $413,255,602 in assets, including $193,493,051 in assets under its discretionary management and $219,762,551 in assets to which AIP serves as adviser.