9AT: BOLTON INVESTMENT

Adviser Profile

As of Date	03/28/2026
Registration	SEC, Approved, 07/06/1994
ADV Location	TOWSON, MD, United States
Contact Info	410 xxxxxxx
Websites

AUM^*	249,134,519 308%
of that, discretionary	249,134,519 308%
Number of Employees	11 22%
of those in investment advisory functions	7
Private Fund GAV^*	0
Avg Account Size	27,681,613 263%
SMA’s	Yes
Private Funds	0

Adviser Type

- Pension consultant

Client Types

- Pension and profit sharing plans
- Charitable organizations

Advisory Activities

- Pension consulting services
- Selection of other advisers

Compensation Arrangments

- A percentage of assets under your management
- Hourly charges
- Fixed fees (other than subscription fees)

Adviser	Hedge Fund	Liquidity Fund	Private Equity Fund	Real Estate Fund	Securitized Asset Fund	Venture Capital Fund	Other Fund	Total Private Fund GAV	AUM	#Funds
Adviser ALPHA GROWTH MANAGEMENT LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM19.6m	#Funds-
Adviser PARVIN FUND MANAGEMENT	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM10.1m	#Funds-
Adviser VALUE TREND CAPITAL MANAGEMENT LP	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM11.9m	#Funds-
Adviser VEGTECH LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM6.2m	#Funds-
Adviser R CUBED GLOBAL CAPITAL INC.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM25.2m	#Funds-
Adviser ARMADA ETFS	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM10.2m	#Funds-
Adviser GUIDANCE POINT RETIREMENT SERVICES, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM88.2m	#Funds-
Adviser EMERALD RESEARCH CORP.	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM9.4m	#Funds-
Adviser FINITE MANAGEMENT, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM3.0m	#Funds-
Adviser WRONA INVESTMENT MANAGEMENT, LLC	Hedge Fund-	Liquidity Fund-	Private Equity Fund-	Real Estate Fund-	Securitized Asset Fund-	Venture Capital Fund-	Other Fund-	Total Private Fund GAV-	AUM34.1m	#Funds-

Brochure Summary

Overview

Founded in 1994, Bolton Investment Consulting Group, Inc. (“BPICG”) provides investment consulting to institutional benefit plans such as trustee directed OPEB, Welfare, Pension, DROP and LOSAP and participant-directed 457(b), 403(b), 401(a) and 401(k) plans. These services include the formulation and review of investment goals and objectives, reviewing and updating Investment Policy Statements, developing and implementing asset allocation strategies, performance monitoring, measurement and reporting, analysis of financial and economic markets, plan design consulting, and reviewing plan fees. We are an independent investment consulting firm that acts as fiduciaries on the plans we advise, and strictly work in the best interest of our clients. We are an investment advisor under the Investment Advisor’s Act of 1940, and serve as both a discretionary or non-discretionary advisor. We are also certified by the Centre for Fiduciary Excellence (CEFEX). We do not receive any revenue sharing, soft dollars, and do not participate in wrap fee programs. 100% of our revenue is derived from institutional investment consulting and we do not receive any indirect or third-party compensation. Our parent company is BOD Group, Inc. and we are affiliated with Bolton Partners,

Inc., which is an actuarial and employee benefits consulting firm. We are a 100% employee-owned C corporation. BPICG provides both discretionary and non-discretionary investment advisory services to institutional investors. The majority of our consulting is non-discretionary and the services we provide include:
• Investment Policy Statement Creation and Review
• Asset Allocation Modeling and Analysis
• Performance Monitoring & Reporting
• Fee Benchmarking and Analysis
• Plan Provider Searches
• Committee Training and Education
• Selection and Monitoring of Investment Managers
• Plan Design and Review We tailor our advisory services to the needs of each client. We make every effort to ensure that we incorporate each client's objectives and constraints in our analysis so that we identify appropriate solutions. All our investment advice is at the plan and manager or fund level. We do not provide security- specific advice. As of December 31, 2023, BPICG’s Assets Under Advisement were approximately $6,849,072643, where we act as a 3(21) fiduciary. As of the same date, we had approximately $60,991,211 in Assets Under Management, where we act as an ERISA 3(38) Investment Manager. 5 | P a g e

BOLTON INVESTMENT

BOLTON INVESTMENT

BOLTON HEALTH

BOLTON RETIREMENT

BOLTON PARTNERS INVESTMENT CONSULTING GROUP, INC.

BOLTON OFFUTT DONOVAN INVESTMENT CONSULTING GROUP, INC.

BOLTON OFFUTT DONOVAN INVESTMENT CONSULTING GROUP INC.

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Brochure Summary

Overview

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BOLTON INVESTMENT BOLTON INVESTMENT BOLTON HEALTH BOLTON RETIREMENT BOLTON PARTNERS INVESTMENT CONSULTING GROUP, INC. BOLTON OFFUTT DONOVAN INVESTMENT CONSULTING GROUP, INC. BOLTON OFFUTT DONOVAN INVESTMENT CONSULTING GROUP INC.

Adviser Profile

Details

Adviser Type

Client Types

Advisory Activities

Compensation Arrangments

Reported AUM

Private Funds

Employees

Similar advisers

Brochure Summary

Overview

BOLTON INVESTMENT

BOLTON INVESTMENT

BOLTON HEALTH

BOLTON RETIREMENT

BOLTON PARTNERS INVESTMENT CONSULTING GROUP, INC.

BOLTON OFFUTT DONOVAN INVESTMENT CONSULTING GROUP, INC.

BOLTON OFFUTT DONOVAN INVESTMENT CONSULTING GROUP INC.